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and DONALD OLDS, Defendants. Plaintiff, Lauden Bisel ( Plaintiff ), by his undersigned attorneys, alleges upon personal knowledge with respect to himself, and information and belief based upon,
inter alia, the investigation of counsel as to all other allegations herein, as follows:
NATURE OF THE ACTION 1.This is an action brought by Plaintiff against Acasti Pharma, Inc. ( Acasti or the Company ), and the members of Acasti s board of directors (the Board or the Individual Defendants and together with Acasti, the Defendants ) for their violations of Sections 14(a) and 20(a) of the Securities Exchange Act of 1934 ( Exchange Act ), 15 U.S.C. §§ 78n(a) and 78t(a), and SEC Rule 14a-9, 17 C.F.R. § 240.14a-9, in connection with the proposed merger between Acasti Pharma U.S., Inc., a wholly-owned subsidiary of Acasti and Grace Therapeutics Inc. ( Grace ) (the Proposed Merger ).