UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA 

CASE NO.: 

SECURITIES AND EXCHANGE COMMISSION, 

Plaintiff, 

v. 

PAUL A. PEREIRA, 

Defendant. 

__________________________________________/

COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF 

Plaintiff Securities and Exchange Commission (the “Commission”) alleges as follows: 

I. INTRODUCTION

1. This case concerns a fraudulent scheme by Defendant Paul A. Pereira (“Defendant” 

or “Pereira”), the former Chief Executive Officer (“CEO”) and co-founder of Alfi, Inc. (“Alfi”), 

an advertising technology company, to deceive investors about Alfi’s success and financial 

performance in order to generate interest in the company and boost Alfi’s stock price. 

2. From at least June 2021 to August 2021, Pereira made materially false and 

misleading statements regarding the company’s revenues, an alleged agreement with a third party 

to place Alfi technology in retail locations, and the company’s current and projected advertising 

inventory. The term “advertising inventory,” a key performance metric for Alfi, refers to the 

amount of advertising revenue that a company can generate from its media assets, such as 

billboards, devices, or other displays. 

3. Pereira made these false and misleading statements in pseudonymous social media 

posts, a YouTube interview, and in a company-issued press release. 

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4. By engaging in the conduct set forth in this Complaint, Pereira violated Sections 

17(a)(1) and 17(a)(3) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. § 77q(a)(1) and 

77q(a)(3)], Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. § 

78j(b)], and Exchange Act Rule 10b-5 [17 C.F.R. § 240.10b-5]. Unless enjoined, Pereira is 

reasonably likely to continue to violate the federal securities laws. In addition to permanent 

injunctive relief, the Commission also seeks an order requiring Pereira to pay a civil penalty and 

an officer and director bar. 

II. DEFENDANT AND RELEVANT ENTITY 

A. Defendant 

5. Pereira, age 62, resides in Miami Beach, Florida. In April 2018, Pereira co-founded 

Lectrefy, a company later renamed Alfi, and served as its CEO and on its Board of Directors from 

April 4, 2018, until he resigned on February 2, 2022. 

B. Relevant Entity 

6. Alfi, a Delaware corporation formed in 2018 and headquartered in Miami Beach, 

Florida, was an advertising technology company that purportedly developed technology to 

measure and generate reporting on audience presence, demographics, and responses to digital 

advertisements. Alfi’s common stock and warrants were registered with the Commission under 

Section 12(b) of the Exchange Act and traded on the NASDAQ Stock Market from May 3, 2021 

until October 27, 2022, when they were delisted. On October 14, 2022, Alfi filed a petition for 

Chapter 7 bankruptcy protection in the United States Bankruptcy Court for the District of 

Delaware. In re Alfi, Inc., Case No. 22-bk-10979 (Del. Bankr. Oct. 14, 2022).

 

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III. JURISDICTION AND VENUE 

7. This Court has jurisdiction over this action pursuant to Sections 20(b), 20(d)(1), 

and 22(a) of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d)(1), and 77v(c)], and Sections 21(d) 

and 27(a) of the Exchange Act [15 U.S.C. §§ 78u(d) and 78aa(a)].

8. This Court has personal jurisdiction over the Defendant and venue is proper in the 

Southern District of Florida because: (a) Pereira resides in the District; and (b) a substantial part 

of the events or omissions giving rise to the violations of the Securities Act and the Exchange Act 

occurred in the District.

9. In connection with the conduct alleged in this Complaint, Pereira, directly and 

indirectly, singly or in concert with others, made use of the means or instrumentalities of interstate 

commerce, the means or instruments of transportation and communication in interstate commerce, 

and the mails.

IV. FACTUAL ALLEGATIONS 

A. Alfi’s Business and Initial Public Offering 

10. In April 2018, Pereira cofounded Lectrefy, a company which was later renamed 

Alfi, along with his son and a business associate. Alfi was in the business of creating technology 

that purportedly used artificial intelligence and big data analytics to measure and predict human 

responses to advertisements. 

11. As part of its business strategy, Alfi developed advertising technology for tablets 

and kiosks, and attempted to contract with brands and advertising firms to display advertisements 

on the devices. 

12. According to the company’s amended Form S-1 filed with the Commission on 

April 26, 2021, the technology was able to “determine the age, gender, ethnicity, geolocation and 

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emotion” of someone in front of an Alfi-enabled tablet or kiosk, and then deliver, in real time, 

advertisements suited to that viewer based on the viewer’s profile. In media interviews, Pereira 

explained that Alfi-enabled devices were able to detect, for example, a 25-year-old female wearing 

a pair of yellow sunglasses in front of the device, and then show Louis Vuitton products or Gucci 

sunglasses to her instead of ads on retirement homes. 

13. Alfi’s success depended, in significant part, on the size of its advertising inventory, 

also known as revenue inventory, which means the amount of advertising revenue that a company 

is able to generate from its media assets, such as screens, devices, or other displays. 

14. One key element of Alfi’s business strategy was contracting with Uber, Lyft, and 

taxi drivers and distributing Alfi-enabled devices to their vehicles to play advertisements and 

generate revenue. 

15. By November 2020, however, the company had generated no revenue and was 

running out of funds to operate the business. To raise money, Pereira, other members of Alfi 

management, and the Board of Directors decided to conduct an initial public offering (“IPO”) of 

Alfi stock. 

16. Alfi filed a draft Form S-1 registration statement with the Commission on 

November 30, 2020. The registration statement became effective on May 3, 2021, and trading in 

Alfi common stock and warrants on the NASDAQ Stock Market began the following day. The 

company reportedly raised around $17.8 million in the initial public offering. Investors exercised 

Alfi warrants throughout the period from approximately June 18, 2021 through approximately 

September 20, 2021. During this period, the company received approximately $16 million from 

the sale of warrants. 

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B. Pereira Created a Pseudonymous Account on Stocktwits and Posted 

Material Misrepresentations Concerning Alfi’s Revenues 

17. In the months following Alfi’s May 4, 2021 IPO, the company received attention 

from members of the press and retail investors on social media, who began to describe Alfi as a 

so-called “meme stock.” The term “meme stock” generally refers to equity securities that 

experienced extreme price volatility during the periods of 2020 and 2021 due, at least in part, to 

abnormally high volumes of buying and selling in the stock by retail investors. 

18. Alfi’s stock price experienced significant price and volume volatility. On the day 

of its IPO, Alfi’s common stock opened at a price of $3.60 per share. By June 16, 2021, the stock 

price had increased to $9.22 per share and, on June 28, 2021, the stock was trading at more than 

$22 per share before declining steadily through July 2021. 

19. Increasing Alfi’s visibility on social media platforms with a large retail investor 

audience was a priority for Pereira. Pereira expressed concern to Alfi employees about the lack of 

attention being paid to Alfi on social media. He directed employees to post favorable information 

about Alfi to social media platforms, such as Stocktwits, a finance-focused social media platform 

popular among retail investors. 

20. On or around May 18, 2021, Pereira created an account on Stocktwits under the 

moniker “Uptix12.” Over the next five months, in violation of Alfi’s social media policy, Pereira 

posted information on Stocktwits about Alfi multiple times per week and, often, multiple times 

per day. 

21. Due to the pseudonymous nature of the “Uptix12” moniker, which did not identify 

Pereira, there was no way for Stocktwits users to determine that Pereira, the CEO of Alfi at the 

time, controlled the Uptix12 account. Through the account, Pereira often made posts praising 

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Alfi’s technology and strategy and, at times, he disparaged other Stocktwits users who criticized 

Alfi. 

22. On June 3, 2021, Pereira posted the following materially false and misleading 

statement on Stocktwits about Alfi’s reported revenues: “$ALF Read between the CEO lines. 

Focused execution. They know exactly what they are doing. I wouldn’t doubt that ALFI have [sic] 

$10 mm to $20 mm in revenues already in their back pocket!” 

23. When he posted this statement on Stocktwits, Pereira knew, or was reckless in not 

knowing, that Alfi did not have anywhere close to $10 million to $20 million in revenues. 

24. The day before his post, on June 2, 2021, Pereira received a near final draft of Alfi’s 

first Form 10-Q, reporting revenues of only $17,450 for the three-month period ending March 31, 

2021. The final version of the Form 10-Q, filed with the Commission on June 10, 2021, also 

reported $17,450. 

25. In its filings with the Commission, Alfi reported only $26,465 in revenues for the 

fiscal year ending December 31, 2021, and $63,303 and $129,302 for the quarters ending March 

31, 2022, and June 30, 2022, respectively. 

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C. Pereira Falsely Claimed that Alfi Entered into an Agreement with a Third 

Party for the Deployment of Alfi Technology 

26. On June 16, 2021, six days after Alfi reported revenues of only $17,450 for the 

period ending March 30, 2021, Pereira gave an interview on the YouTube channel of a financial 

media company. 

27. During the interview, Pereira told the host of the program that: “[T]he founder of 

[a large restaurant chain] . . . is an investor in Alfi. He was so intrigued by the technology that 

we’re going into contract with his chain and his restaurants to deploy Alfi in those restaurants.” 

28. At the time he made this statement, Pereira knew, or was reckless in not knowing, 

that no such contract had been contemplated by the parties. The founder never discussed a contract 

to deploy Alfi technology in his restaurant chain with Pereira or any other Alfi personnel. In fact, 

by the time he met Pereira, the founder had retired from the restaurant business and was not 

authorized to bind any restaurant chain to a contract. 

D. Pereira Made Material Misstatements and Omissions Concerning Alfi’s 

Current and Projected Advertising Inventory 

29. By July 2021, Alfi had engaged an advisor to identify companies as potential 

acquisition targets. Pereira hoped to increase the price and daily trading volume of Alfi stock to 

improve the company’s negotiating position in a potential acquisition. 

30. On July 15, 2021, Pereira emailed Alfi’s external investor relations consultant that 

the company “need[s]” daily trading volumes of 10 million shares and a stock price between $18 

and $20 to close an acquisition. Alfi common stock’s opening price that day was $10.64 per share, 

which was down from its high of $22.50 per share on June 28, 2021.   

31. By early August 2021, Alfi common stock was trading predominately in the $7 to 

$9 per share range. 

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32. Pereira was concerned about the continuing decline in Alfi’s stock price. On August 

12, 2021, Pereira emailed Alfi’s investor relations consultant, copying other Alfi senior executives, 

and explained that the company needed to regain some of its lost market capitalization. 

33. On August 16, 2021, Alfi’s in-house social media manager emailed Pereira that “the 

news among the retail community is not what we expect. The investors want to know about the 

earnings, and they don’t necessarily want to see study data....” He added that the company’s 

external investor relations consultant “is hopeful that the sentiment will change when the quarterly 

earnings comes [sic] out today.” 

34. However, later that day, Alfi reported revenue of only $936 for the quarter ending 

June 30, 2021, and on the following day, August 17, 2021, the company’s stock price opened at 

$6.90 per share, its lowest price in nearly two months. That very day, Pereira took action, issuing 

multiple materially false and misleading statements and omissions in a company press release and 

several Stocktwits posts concerning Alfi’s annual revenue inventory. 

35. On August 17, 2021, at 11:36 a.m. EST, Pereira, as CEO, approved the issuance of 

a press release announcing that the company planned to distribute Alfi-enabled devices to rideshare 

vehicles in 14 U.S. cities. The press release stated prominently that Alfi would have in “Excess of 

$100 million in advertising inventory available before end of 2021.” 

36. The press release also included the following quote inserted by, and attributed to, 

Pereira: “Launching our rideshare partner program nationally is a significant milestone for Alfi. 

Our available advertising inventory by the end of 2021 is expected to be in excess of $100 million 

and by the end of 2022 in excess of $500 million.” 

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37. Shortly after approving the press release, between 12:10 p.m. and 1:26 p.m. EST, 

Pereira made three separate posts on Stocktwits through his Uptix12 account, further representing 

that Alfi has $100 million in revenue inventory: 

38. Pereira’s statement that “Alfi has $100 million of revenue inventory” was false. At 

the time, Alfi had distributed, at most, 1,500 Alfi-enabled devices, and internal company estimates 

provided to Pereira showed that the company expected to generate approximately $238.63 per 

month from each device. Far short of $100 million, as of August 17, 2021, the company only had, 

at most, $4.3 million of revenue inventory. 

39. In addition, Pereira’s statements projecting that Alfi would have $100 million of 

revenue inventory by the end of 2021 lacked a reasonable basis. Pereira knew, or was reckless in 

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not knowing, that to achieve $100 million in annual advertising inventory by the end of 2021, Alfi 

would have had to distribute approximately 35,000 Alfi-enabled devices in rideshares by the end 

of 2021, with each device projected to generate approximately $238.63 per month. 

40. But, on July 30, 2021, just a few weeks before releasing his projections, Pereira 

received an email from Alfi staff, showing an internal target of 8,600 device distributions by the 

end of 2021. Pereira called the number of signed agreements with rideshare drivers “very 

concerning.” 

41. Pereira had reason to be concerned. Even the target of 8,600 device distributions 

by end of 2021 was optimistic. The July 30, 2021 email showed, at most, 1,323 devices had been 

distributed as of that date. In addition, the company experienced significant difficulties contacting 

drivers and procuring from them the documentation required to obtain a device, such as proof of 

insurance and drivers’ licenses. Alfi engineers also were still in the process of resolving technical 

issues that affected the ability of the devices to play advertisements reliably. 

42. By August 2021, Alfi only had around 20,000 tablets in physical inventory and had 

distributed no more than 1,500 devices. 

43. Not surprisingly, by the end of 2021, Alfi had no more than $5.4 million in 

advertising inventory and not the $100 million that Pereira had projected. 

E. Pereira’s Resignation and Alfi’s Bankruptcy 

44. On October 22, 2021, the Board of Directors placed Pereira on administrative leave 

and authorized an independent internal investigation conducted by a special committee of the 

Board regarding certain corporate transactions unrelated to the allegations in this Complaint. 

45. The Board’s special committee found that, in addition to corporate governance 

abuses and related misconduct by Pereira, inaccurate social media posts were made from a 

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pseudonymous account using Pereira’s computer. On February 2, 2022, Pereira resigned his 

position as a director and as CEO. 

46. On October 14, 2022, Alfi filed for Chapter 7 bankruptcy protection in the United 

States Bankruptcy Court for the District of Delaware. 

V. CLAIMS FOR RELIEF 

COUNT I 

Violations of Section 17(a)(1) of the Securities Act 

47. The Commission repeats and realleges paragraphs 1 through 46 of this Complaint 

as if fully incorporated herein

48. From at least May 2021 to September 2021, Defendant, in the offer or sale of 

securities by use of any means or instruments of transportation or communication in interstate 

commerce or by use of the mails, knowingly or recklessly, directly or indirectly, employed devices, 

schemes, or artifices to defraud. By reason of the foregoing, Defendant violated and, unless 

enjoined, is reasonably likely to continue to violate Section 17(a)(1) of the Securities Act [15 

U.S.C. § 77q(a)(1)].

COUNT II 

Violations of Section 17(a)(3) of the Securities Act 

49. The Commission repeats and realleges paragraphs 1 through 46 of this Complaint 

as if fully incorporated herein.

50. From at least May 2021 to September 2021, Defendant, in the offer or sale of 

securities by use of any means or instruments of transportation or communication in interstate 

commerce or by use of the mails, directly or indirectly, negligently engaged in transactions, 

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practices, or courses of business which have operated, are now operating, or will operate as a fraud 

or deceit upon the purchasers. 

51. By reason of the foregoing, Defendant violated and, unless enjoined, is reasonably 

likely to continue to violate Section 17(a)(3) of the Securities Act [15 U.S.C. § 77q(a)(3)]. 

COUNT III 

Violations of Section 10(b) and Rule 10b-5(a) of the Exchange Act 

52. The Commission repeats and realleges paragraphs 1 through 46 of this Complaint 

as if fully incorporated herein. 

53. From at least May 2021 to September 2021, Defendant, directly or indirectly, by 

the use of any means or instrumentality of interstate commerce, or of the mails, knowingly or 

recklessly employed devices, schemes, or artifices to defraud in connection with the purchase or 

sale of any security. 

54. By reason of the foregoing, Defendant violated and, unless enjoined, is reasonably 

likely to continue to violate Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)], and Exchange 

Act Rule 10b-5(a) [17 C.F.R. § 240.10b-5(a)]. 

COUNT IV 

Violations of Section 10(b) and Rule 10b-5(b) of the Exchange Act 

55. The Commission repeats and realleges paragraphs 1 through 46 of this Complaint 

as if fully incorporated herein. 

56. From at least May 2021 to September 2021, Defendant, directly or indirectly, by 

the use of any means or instrumentality of interstate commerce, or of the mails, knowingly or 

recklessly made untrue statements of material facts or omitted to state material facts necessary in 

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order to make the statements made, in the light of the circumstances under which they were made, 

not misleading, in connection with the purchase or sale of any security. 

57. By reason of the foregoing, Defendant violated and, unless enjoined, is reasonably 

likely to continue to violate Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)], and Exchange 

Act Rule 10b-5(b) [17 C.F.R. § 240.10b-5(b)]. 

COUNT V 

Violations of Section 10(b) and Rule 10b-5(c) of the Exchange Act 

58. The Commission repeats and realleges paragraphs 1 through 46 of this Complaint 

as if fully incorporated herein.

59. From at least May 2021 to September 2021, Defendant, directly or indirectly, by 

use of any means or instrumentality of interstate commerce, or of the mails, knowingly or 

recklessly engaged in acts, practices, and courses of business which have operated, are now 

operating, or will operate as a fraud upon any person in connection with the purchase or sale of 

any security.

60. By reason of the foregoing, Defendant violated and, unless enjoined, is reasonably 

likely to continue to violate Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)], and Exchange 

Act Rule 10b-5(c) [17 C.F.R. § 240.10b-5(c)]. 

VI. RELIEF REQUESTED 

WHEREFORE, the Commission respectfully requests the Court find the Defendant 

committed the violations alleged, and: 

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A.

Permanent Injunction Against Defendant 

Issue a Permanent Injunction enjoining Pereira from violating Sections 17(a)(1) and 

17(a)(3) of the Securities Act [15 U.S.C. § 77q(a)(1) and 77q(a)(3)] and Section 10(b) of the 

Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5]. 

B. 

Civil Penalty 

Issue an Order directing Pereira to pay civil money penalties pursuant to Section 20(d) of 

the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the Exchange Act [15 U.S.C. § 

78(d)(3)]. 

C.

Officer and Director Bar 

Issue an Order barring Pereira, pursuant to Section 20(e) of the Securities Act [15 U.S.C. 

§ 77t(e)], and Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)], from serving as an 

officer or director of any company that has a class of securities registered with the Commission 

pursuant to Section 12 of the Exchange Act [15 U.S.C. § 78l], or that is required to file reports 

pursuant to Section 15(d) of the Exchange Act [15 U.S.C. § 78o(d)]. 

D.

Further Relief 

Grant such other and further relief as may be necessary and appropriate. 

E.

Retention of Jurisdiction 

Further, the Commission respectfully requests the Court retain jurisdiction over this action 

to implement and carry out the terms of all orders and decrees that it may enter, or to entertain any 

suitable application or motion by the Commission for additional relief within the jurisdiction of 

this Court. 

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VII. JURY TRIAL DEMAND 

The Commission demands a trial by jury on all issues so triable. 

Dated: February 27, 2024 Respectfully submitted, 

s/Russell R. O’Brien 

Russell R. O’Brien 

Trial Counsel 

Fla. Bar No. 084542 

Direct Dial: (305) 982-6341 

Email: obrienru@sec.gov 

Alexander H. Charap 

 Senior Counsel 

 Fla. Bar No. 1035908 

 Direct Dial: (305) 416-6228 

Email: charapal@sec.gov 

Attorneys for Plaintiff 

SECURITIES AND EXCHANGE 

COMMISSION 

801 Brickell Avenue, Suite 1950 

Miami, Florida 33131 

Telephone: (305) 982-6300 

Facsimile: (305) 536-4146 

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