The complaint alleges that the Registration Statement issued in connection with the IPO contained misleading information and/or omitted material facts In particular  Inovalon failed to disclose that the Company derives substantial revenues from sales in the city and state of New York  both of which were reforming their corporate tax schemes in order to capture more taxes from out-of-state businesses doing substantial business within their borders  these corporate tax rate increases  which would take effect January 1  2016 -- more than a month prior to Inovalon's IPO -- would significantly increase the Company's effective tax rate and thus lower its 2015 earning potential