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Robbins Geller Rudman & Dowd LLP Files Class Action Suit Against PureCycle Technologies, Inc.
[May 11, 2021]

Robbins Geller Rudman & Dowd LLP Files Class Action Suit Against PureCycle Technologies, Inc.

Robbins Geller Rudman & Dowd LLP ( today announced that it filed a class action seeking to represent purchasers of PureCycle Technologies, Inc. (NASDAQ:PCT) along with its predecessor, Roth CH Acquisition I Co. ("ROCH,") (collectively, "PureCycle" or the "Company"), publicly traded securities during the period between November 16, 2020 and May 5, 2021, inclusive, and all holders of ROCH securities entitled to participate in the March 16, 2021 shareholder vote on the merger with PureCycle (the "Class Period") (the "PureCycle class action lawsuit"). The PureCycle class action lawsuit was filed in the Middle District of Florida and is captioned Tennenbaum v. PureCycle Technologies, Inc.

The Private Securities Litigation Reform Act of 1995 permits any investor who purchased PureCycle publicly traded securities during the Class Period to seek appointment as lead plaintiff in the PureCycle class action lawsuit. A lead plaintiff is generally the movant with the greatest financial interest in the relief sought by the putative class who is also typical and adequate of the putative class. A lead plaintiff acts on behalf of all other class members in directing the PureCycle class action lawsuit. The lead plaintiff can select a law firm of its choice to litigate the PureCycle class action lawsuit. An investor's ability to share in any potential future recovery of the PureCycle class action lawsuit is not dependent upon serving as lead plaintiff. If you wish to serve as lead plaintiff in the PureCycle class action lawsuit, you must move the Court no later than 60 days from today. If you wish to serve as lead plaintiff of the PureCycle class action lawsuit or have questions concerning your rights regarding the PureCycle class action lawsuit, please visit our website by clicking here or contact Juan Carlos Sanchez (News - Alert) of Robbins Geller, at 800/449-4900 or 619/231-1058 or via e-mail at You can view a copy of the complaint as filed at

The PureCycle class action lawsuit charges PureCycle, ROCH, and certain of PureCycle's executives with violations of the Securities Exchange Act of 1934. PureCycle provides recycling services, and is developing a plastic purification recycling technology originally developed and patented by The Procter & Gamble Company ("P&G"). PureCycle claims its process recycles waste polypropylene into resin with "near-virgin" characteristics. PureCycle calls its resin ultra-pure recycled polypropylene ("UPRP"), and states that it can take used plastic feedstock and remove color, odor, and other contaminants, creating UPRP hat has nearly identical properties and applicability for reuse as virgin polypropylene. Through its global license with P&G, PureCycle claims to have the only patented, solvent-based purification recycling technology available for this process.

Through November 2020, ROCH was a publicly traded special purpose acquisition company ("SPAC"). On November 16, 2020, PureCycle announced that PureCycle would list its common stock on the NASDAQ through a reverse merger with the ROCH SPAC. At that time, PureCycle claimed that PureCycle was then modeling for its revenues to hit $8 million in 2022 as its first plant came on line. Revenues would then ramp up significantly to $224 million in 2023 with the first five plants coming on line. By 2024, PureCycle said it was modeling to hit $800 million in revenues, with earnings before interest, taxes, depreciation and amortization margins of over 50%. The price of PureCycle common stock (then still trading as ROCH) spiraled up as PureCycle made additional statements about the merger, which its shareholders approved at a special meeting held virtually on March 16, 2021.

The PureCycle class action lawsuit alleges that, throughout the Class Period, defendants made false and misleading statements and failed to disclose that: (i) the management team bringing PureCycle public had previously brought six other failed business public only to have each implode thereafter; (ii) the management team bringing PureCycle public had characterized rank speculation as financial projections to investors in the past; (iii) the primary motivation of the management team bringing PureCycle public was to complete any transaction, good or bad, to obtain tens of millions of dollars in cash and tradable shares; (iv) PureCycle faces higher competition for high quality feedstock than it has led investors to believe, materially undermining the management team's financial projections; (v) PureCycle's patent is nowhere as cogent or valuable as it has led investors to believe, and the technology underlying its business operations is unproven and presents serious issues even at lab scale; (vi) in reality, PureCycle's flammable pressurized process is not yet functional, especially at scale, and is dangerous; (vii) PureCycle purports to be advancing to commercial production scale despite still having operational issues at a lab scale; and (viii) as a result, defendants' positive statements during the Class Period about PureCycle's business performance, financial and operational metrics, and financial prospects were false and misleading and/or lacked a reasonable basis.

On May 6, 2021, stock research firm Hindenburg Research published a detailed report, supported by multiple former employees and industry experts, detailing that the management team bringing PureCycle public had: (a) previously brought six other businesses public only to have each implode thereafter, "resulting in 2 bankruptcies, 3 delistings, and 1 acquisition after a ~95% decline[,]" with "[o]ver $760 million in public shareholder capital [being] incinerated in the process"; (b) "based their financial projections" in those other failed companies on "'wild ass guessing,' [bringing] companies public far too early, and [having] deceived investors"; and (c) only brought PureCycle public to permit that same spurious management team to "collectively position[] themselves to clear ~$90 million in cash and tradable shares before the company generates a single dime in revenue." The report cited industry experts who explained that despite PureCycle's rosy projections, "PureCycle faces steep competition for high quality feedstock, and called the company's financial projections into question." The report included the account of a "30-year expert on polymers, with a background in advanced plastics recycling" who stated that PureCycle's "patent is 'indirect,' 'vague' and 'regurgitation' of prior art" and "referred to the company's flammable pressurized process as a 'bomb' and warned about the company foraging ahead to commercial scale despite still having issues at a lab scale." The report concluded that "PureCycle represents the worst qualities of the SPAC boom; another quintessential example of how executives and SPAC sponsors enrich themselves while hoisting unproven technology and ridiculous financial projections onto the public markets, leaving retail investors to face the ultimate consequences." On this news, the price of PureCycle's common stock declined by more than 40%, damaging investors.

The plaintiff is represented by Robbins Geller, which has extensive experience in prosecuting investor class actions including actions involving financial fraud.

Robbins Geller Rudman & Dowd LLP has launched a dedicated SPAC Task Force to protect investors in blank check companies and seek redress for corporate malfeasance. Comprised of experienced litigators, investigators, and forensic accountants, the SPAC Task Force is dedicated to rooting out and prosecuting fraud on behalf of injured SPAC investors. The rise in blank check financing poses unique risks to investors. Robbins Geller Rudman & Dowd LLP's SPAC Task Force represents the vanguard of ensuring integrity, honesty, and justice in this rapidly developing investment arena.

Robbins Geller Rudman & Dowd LLP is one of the world's leading law firms representing investors in securities litigation. With 200 lawyers in 9 offices, Robbins Geller has obtained many of the largest securities class action recoveries in history. ISS Securities Class Action Services has ranked Robbins Geller as one of the top law firms in the world in both amount recovered and total number of class action settlements for shareholders every year since 2010. The SCAS 2020 Top 50 Report ranked Robbins Geller first for recovering $1.6 billion for investors last year, more than double the amount recovered by any other plaintiffs' firm. Robbins Geller attorneys have helped shape the securities laws and have recovered tens of billions of dollars on behalf of aggrieved victims. Beyond securing financial recoveries for defrauded investors, Robbins Geller also specializes in implementing corporate governance reforms, helping to improve the financial markets for investors worldwide. Robbins Geller attorneys are consistently recognized by courts, professional organizations and the media as leading lawyers in the industry. Please visit for more information.

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