According to the Complaint, Paycom Software, Inc. purports to be a “leading provider of a comprehensive, cloud-based human capital management solution delivered as “Software-as-a-Service."

On July 6, 2021, Paycom released a press release entitled “Paycom Launches Beti, an Industry-First Employee-Driven Payroll Solution.” Paycom characterized Beti as the “industry’s first self-service payroll technology allowing employees to do their own payroll, improving data accuracy, oversight and the user experience for businesses and their employees on each payroll cycle.”

The Complaint alleges that Defendants throughout the Class Period made materially false and/or misleading statements and/or failed to disclose that: (1) Paycom’s Beti product led to cannibalization of the Paycom’s services and revenues; (2) Paycom knew but failed to disclose that Beti was leading to cannibalization of Paycom’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; (4) 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.

On April 23, 2024, the Court issued an Order consolidating cases and appointing Lead Plaintiff and Counsel. All future docketing was ordered to be done in the lead case 23-CV-01019.

Lead Plaintiff filed an amended Complaint on July 8, 2024.