The filed complaint alleges that defendants made false statements and/or concealed that: (1) Paycom’s Beti product led to cannibalization of the Company’s services and revenues; (2) Paycom knew but failed to disclose that Beti was leading to cannibalization of the Company’s services and revenues, and failed to warn of cannibalization as a general risk; (3) as a result of cannibalization of revenue, Paycom missed its expected 3Q23 revenue and would have to revise its expected 2023 Revenues; (3) the cannibalization issue resulted in projected 2024 year-over-year revenue growth to between 10% and 12%, well below expectations; and (5) as a result, defendants’ statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.