19.  The Class Period begins on May 12, 2014. On that day, Kandi filed with the SEC  its Quarterly Report on Form 10-Q for the quarter ended March 31, 2014, providing the Company’s  consolidated financial results for that period.     20.  The Company’s May 12, 2014 10-Q also summarized the Company’s investment  in the JV Company:  50.  Plaintiff brings this action as a class action pursuant to Rule 23 of the Federal Rules  of Civil Procedure on behalf of a class of all persons and entities who purchased or otherwise  acquired Kandi securities between May 12, 2014  through March 13, 2017, inclusive. Excluded  from the Class are Defendants, directors and officers of the Company, as well as their families and  affiliates.   52.  There is a well-defined community of interest in the questions of law and fact  involved in this case. Questions of law and fact common to the members of the Class which  predominate over questions which may affect individual Class members include:  a.  Whether the Exchange Act was violated by Defendants;  b.  Whether Defendants omitted and/or misrepresented material facts;  c.  Whether Defendants’ statements omitted material facts necessary in order to make  the statements made, in light of the circumstances under which they were made, not  misleading;  d.  Whether Defendants knew or recklessly disregarded that their statements were false  and misleading;  e.  Whether the price of the Company’s stock was artificially inflated; and  f.  The extent of damage sustained by Class members and the appropriate measure of  damages.   53.  Plaintiff’s claims are typical of those of the Class because Plaintiff and the Class  sustained damages from Defendants’ wrongful conduct alleged herein.   55.  A class action is superior to other available methods for the fair and efficient  adjudication of this controversy. Furthermore, as the damages suffered by individual Class  members may be relatively small, the expense and burden of individual litigation makes it  impossible for members of the Class to individually redress the wrongs done to them.  There will  be no difficulty in the management of this action as a class action.  60.  As alleged herein, Defendants acted with scienter in that Defendants knew that the  public documents and statements issued or disseminated in the name of the Company were  materially false and/or misleading; knew that such statements or documents would be issued or  disseminated to the investing public; and knowingly and substantially participated or acquiesced  in the issuance or dissemination of such statements or documents as primary violations of the  federal securities laws. As set forth elsewhere herein in detail, Defendants, by virtue of their receipt  of information reflecting the true facts regarding Kandi, his/her control over, and/or receipt and/or  modification of Kandi’s allegedly materially misleading misstatements and/or their associations  with the Company which made them privy to confidential proprietary information concerning  Kandi, participated in the fraudulent scheme alleged herein.   65.  Plaintiff repeats and re-alleges each and every allegation contained above as if fully  set forth herein.   67.  Defendants violated § 10(b) of the Exchange Act and Rule 10b-5 in that they (i)  employed devices, schemes, and artifices to defraud; (ii) made untrue statements of material fact  and/or omitted to state material facts necessary to make the statements not misleading; and (iii)  engaged in acts, practices, and a course of business which operated as a fraud and deceit upon  those who purchased or otherwise acquired the Company’s securities during the Class Period.   68.  Plaintiff and the Class have suffered damages in that, in reliance on the integrity of  the market, they paid artificially inflated prices for the Company’s common stock. Plaintiff and  the Class would not have purchased the Company’s common stock at the price paid, or at all, if  they had been aware that the market prices had been artificially and falsely inflated by Defendants’  misleading statements.  69.  Plaintiff repeats and re-alleges each and every allegation contained above as if fully  set forth herein.   71.  In particular, each of these Defendants had direct and supervisory involvement in  the day-to-day operations of the Company and, therefore, is presumed to have had the power to  control or influence the particular transactions giving rise to the securities violations as alleged  herein, and exercised the same.    72.  As set forth above, Kandi and the Individual Defendants each violated Section  10(b) and Rule 10b-5 by their acts and/or omissions as alleged in this Complaint. By virtue of their  positions as controlling persons, the Individual Defendants are liable pursuant to Section 20(a) of  the Exchange Act. As a direct and proximate result of Defendants’ wrongful conduct, Plaintiff and  other members of the Class suffered damages in connection with their purchases of the Company’s  securities during the Class Period.   A.  Materially False And Misleading Statements Made During the Class Period   Violation of § 20(a) of the Exchange Act  (Against The Individual Defendants)   Violation of § 10(b) of the Exchange Act and Rule 10b-5 Promulgated Thereunder  (Against All Defendants)  