That they falsely claimed MoviePass’s $9.95 “unlimited” plan was tested, sustainable, and would be profitable or break even on subscription fees alone.

That Farnsworth and Lowe knew MoviePass did not have non-subscription revenue streams that would make MoviePass self-sufficient or otherwise offset its losses.

Falsely claiming that MoviePass’s cost of goods was naturally declining over time as they expected.

That they allegedly directed MoviePass employees to implement numerous tactics to prevent certain subscribers from using the supposedly “unlimited” service.

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