on behalf of Tesla, against certain of Tesla’s current and former directors. Both suits assert claimsfor breach of fiduciary duty, unjust enrichment, and violation of the federal securities laws in connection with alleged race andgender discrimination and sexual harassment. Among other things, plaintiffs seek declaratory and injunctive relief, unspecifieddamages payable to Tesla, and attorneys’ fees. On July 22, 2022, the Court consolidated the two cases and on September 6,2022, plaintiffs filed a consolidated complaint. On November 7, 2022, the defendants filed a motion to dismiss the case and onSeptember 15, 2023, the Court dismissed the action but granted plaintiffs leave to file an amended complaint. On November 2,2023, plaintiff filed an amended complaint purportedly on behalf of Tesla, against Elon Musk. On December 19, 2023, thedefendants moved to dismiss the amended complaint, which the Court granted on April 12, 2024, with leave for plaintiffs toamend. On May 15, 2024, plaintiffs filed a second amended consolidated complaint purportedly on behalf of Tesla, against Mr.Musk. On July 1, 2024, the defendants moved to dismiss the second amended consolidated complaint.22