Tenet Fintech Group Inc. f/k/a Peak Fintech Group Inc.

On September 28, 2021, Tenet withdrew its Form 40-F for the period ended December 31, 2019 “while it works to comply with recent disclosure guidance provided by the SEC for companies either based in China or with the majority of their operations in China.”

On this news, the Company’s shares were delisted from NASDAQ and began trading over-the-counter – the price fell $1.59, or over 17%, from closing at $9.09 on September 20, 2021 to open at $7.50 per share on September 30, 2021.

Then on October 4, 2021, Grizzly Research published a report alleging that the acquisition of Heartbeat Insurance Platform, a Chinese insurance product management and brokerage platform, was rife with factual inaccuracies and suspicious transactions. The report also refuted the Company’s claim that it owns 51% of Asia Synergy Financial Capital Ltd. (“ASFC”) through its wholly-owned subsidiary and alleged that its acquisition of Cubeler Inc. “evidence[d] self-dealing.”

On this news, the Company’s stock price fell $1.31 per share, or 17.4%, to close at $6.19 per share on October 4, 2021, thereby injuring investors.

Then, on October 13, 2021, Grizzly Research published another report, rebutting the Company’s response to the original report. Among other things, this report presented evidence suggesting that ASFC was an undisclosed related party transaction.

On this news, the Company’s share price fell $0.57, or 6%, to close at $7.98 per share on October 13, 2021.

The complaint filed in this class action alleges that throughout the Class Period, Defendants made materially false and/or misleading statements regarding the Company’s business, operations, and prospects. Specifically, Defendants failed to disclose to investors that: (1) the Company did not own 51% of ASFC through Wuxi Aorong; (2) the Company did not disclose its actual ownership structure of ASFC, an undisclosed and potentially problematic nominee shareholder agreement; (3) Huayan did not own the Heartbeat platform; (4) the Heartbeat platform did not exist prior to the alleged acquisition; (5) the Company faced imminent delisting from NASDAQ due to non-compliance with known regulations; (6) the “recent disclosure guidance” was in fact published on November 23, 2020, nearly a full nine months prior to the Company’s uplisting; (7) as such, the Company knew or should have known that its Form 40-F submission was deficient; (8) Cubeler historically failed to make even minimum loan repayments to the Company; (9) the Company, instead of exercising its right on the assets, decided to purchase Cubeler; (10) in light of the foregoing, and consideration of the fact that Cubeler is owned by several Company insiders, the acquisition of Cubeler is not based on legitimate business interests; the largest ASFC shareholder had his assets frozen due to court sanctions; (11) the creation of ASFC itself was likely a related party transaction; and (12) as a result of the foregoing, defendants’ public statements were materially false and/or misleading at all relevant times.