text: On October 21, 2022, a lawsuit was filed in the Delaware Court of Chancery by a purported shareholder of Tesla 
  
  alleging, among other things, that board members breached their fiduciary duties in connection with their oversight of the 
  Company’s 2018 settlement with the SEC, as amended. Among other things, the plaintiff seeks reforms to the Company’s 
  corporate governance and internal procedures, unspecified damages, and attorneys’ fees. The lawsuit has been stayed pending 
  resolution of a motion to consolidate certain derivative lawsuits in the Delaware Court of Chancery referenced below. 
  
  On November 15, 2021, JPMorgan Chase Bank (“JP Morgan”) filed a lawsuit against Tesla in the Southern District of 