Allegations
(i) as Riskified expanded its user base, the quality of Riskified's machine learning platform had deteriorated (rather than improved as represented in documents issued in connection with the July 2021 initial public offering), because of, among other things, inaccuracies in the algorithms associated with onboarding new merchants and entering new geographies and industries; (ii) Riskified had expanded its customer base into industries with relatively high rates of fraud – including partnerships with cryptocurrency and remittance business – in which Riskified had limited experience and that this expansion has negatively impacted the effectiveness of Riskified's machine learning platform; (iii) as a result, Riskified was suffering from materially higher chargebacks and cost of revenue and depressed gross profits and gross profit margins during its third fiscal quarter of 2021; and (iv) thus, the representations in documents issued in connection with the July 2021 initial public offering regarding Riskified's historical financial and operational metrics and purported market opportunities did not accurately reflect the actual business, operations, and financial results and trajectory of Riskified prior to and at the time of the July 2021 initial public offering, and were materially false and misleading, and lacked a factual basis.