According to the Complaint, Fiserv is a global provider of transaction processing software for banks and retail merchants. Fiserv’s flagship product and most important growth driver is Clover, which provides merchants with a payment “gateway” to facilitate the secure processing of credit, debit, and mobile payment transactions on behalf of financial institutions and their customers. Clover revenue is primarily generated from transaction fees paid by merchants, which are computed as a percentage of the dollar value for goods and services charged through Clover. Fiserv positioned Clover as a comprehensive “operating system for small businesses” that also generates revenue from POS hardware sales and expensive subscription-based value-added services like payroll administration software, merchant financing, and cash flow management solutions. This lawsuit was filed against Fiserv and four of its Officers.

The Complaint alleges that, throughout the Class Period, Defendants misled investors by failing to disclose that: (a) due to cost issues and other problems with its Payeezy platform, Fiserv forced Payeezy merchants to migrate to its Clover platform; (b) Clover’s revenue growth and GPV growth were temporarily and unsustainably boosted by these forced conversions, which concealed a slowdown in new merchant business; (c) shortly after these conversions, a significant portion of former Payeezy merchants switched to competing solutions due to Clover’s high pricing, inadequate customer service, and other issues; (d) as a result of these merchant losses, Clover’s GPV growth was significantly slowing, and its revenue growth was unsustainable; and (e) based on the foregoing, Fiserv’s positive Class Period statements about Clover’s growth strategies, competition, attrition, GPV growth, and business prospects were materially false and misleading.