YayYo, Inc.

In November 2019, YayYo completed its initial public offering (“IPO”), in which it sold approximately 2.7 million shares of common stock at $4 per share.

Then, on February 10, 2020, the Company announced that its Board of Directors had decided to delist YayYo’s common stock from the NASDAQ.

Since the IPO, the Company’s shares have traded as low as $0.30, or 93% below the IPO price.

The complaint filed in this class action alleges that throughout the Class Period, Defendants made materially false and/or misleading statements, as well as failed to disclose material adverse facts about the Company’s business, operations, and prospects. Specifically, Defendants failed to disclose to investors that: (1) defendant El-Batrawi continued to exercise supervision, authority, and control over YayYo, and was intimately involved, on a day-to-day basis, with the business, operations, and finances of the Company, including assisting the Underwriter Defendants in marketing YayYo's IPO; (2) defendant El-Batrawi never sold the 12,525,000 "Private Shares" and continued to own a controlling interest in YayYo despite the NASDAQ's insistence that he retain less than a 10% equity ownership interest in connection with the listing agreement; (3) defendants promised certain creditors of YayYo that in exchange to their agreeing to purchase shares in the IPO in order to permit the Underwriter defendants to close the IPO YayYo would repurchase those shares after the IPO; (4) defendants intended to repurchase shares purchased by creditors of YayYo in the IPO using IPO proceeds: (5) YayYo owed its former President, CEO, and Director a half of million dollars at the time of the IPO; (6) YayYo owed SRAX, Inc. (formerly Social Reality, Inc.) $426,286 in unpaid social media costs, most of which was more than a year overdue as payment had been delayed while YayYo attempted to complete its IPO; and (7) that, as a result of the foregoing, Defendants’ positive statements about the Company’s business, operations, and prospects were materially misleading and/or lacked a reasonable basis.