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Uulala is a bitcoin MLM platform. The firm is headquartered in California, USA.

Moving on Oscar Garcia, the CEO of Uulala, is a California resident.

Garcia’s LinkedIn page states;

Mr. Garcia has spent the last 20 years as an entrepreneur building enterprises and accelerating the growth of small businesses.

Mr. Garcia has over 20 years of experience in technology and web development.

Garcia was the Executive Vice President of the Lucrazon Global Ponzi scam in 2014.

Garcia formerly worked at Melaleuca.

Garcia was mentioned as a defendant in a Melaleuca lawsuit filed in January 2014.

Melaleuca alleges in a lawsuit filed last week in U.S. District Court in Pocatello that one of its former “marketing executives,” Oscar Garcia, is now a vice president with Lucrazon Global, a network marketing e-commerce company based in Irvine, Calif., and is pitching his newest business to current and former Melaleuca marketing executives.

“Lucrazon attempts to grow the ranks of its brand partners by plundering Melaleuca’s marketing professionals,” the suit claims.

Garcia reached a settlement with Melaleuca in October 2016. A $5000 judgment was entered against him.

Lucrazon Global went bankrupt at the end of 2014. Lucrazon Global preyed on elderly victims, according to a civil lawsuit filed in 2016.

Garcia reinvented himself as a crypto bro after leaving Lucrazon Global. This brings us to the launch of Uulala in 2017.

Uualala’s original business model saw the company sell UULA and EUULA tokens.

The company’s ICO raised more than $9 million dollars.

The SEC launched a legal action against Uulala, Garcia, and co-founder Matthew Loughran in August 2021.

From December 2017 to January 2019, Uulala sold UULA tokens, which were allegedly to be used to record transactions in a financial application (“app”) that Uulala was developing and promoting to those without access to traditional banking services.

Throughout their UULA offering, Uulala, Garcia, and Loughran made materially false and misleading statements to investors about having “patent pending” technology that had been incorporated into their app and having a proprietary algorithm to assign credit scores to app users.

The litigation was settled between Uulala, Garcia, and Loughran.

Uulala, Garcia, and Loughran each paid civil fines of $300,000, $192,768 and $50,000.

If you’re wondering why the quantities are so small in comparison to the $9 million raised, Ualala argues;

The proceeds from the ICO were reinvested in the company to improve our technology, pay our employees, cover our operating expenses, and help us survive the first three years of our operation.

Today, there is no mention of Matthew Loughran on Uulala’s website. According to the SEC complaint, Loughran resigned as Uulala’s Chief Marketing Officer soon before the lawsuit was filed.

It is uncertain whether Loughran is still affiliated with Uulala.

Despite the fact that its early UULA and EUULA token schemes were “dismantled,” Uulala is still in business as an MLM organization.

Continue reading for a comprehensive assessment of Uulala’s MLM potential.

Uulala’s Products
Uulala sells a financial alternative platform called Batched.

Oscar Garcia claims that the Batched platform can “turn any company into their own digital bank.”

Batched is designed to be sold to third-party companies looking for a less expensive payment processing solution.

Uulala promises to charge far less than regular banks. Companies can also set their own fee rates and profit from them rather than paying fees to banks.

Prices for Uulala range from $5000 to $150,000.

Plan 01 – $5000, followed by $500 per month for up to 100 users.
Plan 02 – $25,000 up front, then $3000 per month for up to 5000 users.
Plan 03 – $50,000 up front, followed by $5000 per month for up to 5000 users.
Plan 04 – $150,000 up front, then $5000 per month for up to 10,000 users.In addition to user limits, Uulala provides additional services as fees are paid.

Uulala’s Compensation Scheme
Uulala’s compensation plan pays for company referrals to its Batched finance platform.

A “validation node” investment scheme is linked to this.

Referral Commissions in Batches
Uulala affiliates receive a 5% transaction fee override on any companies they personally refer to the Batched platform.

Validation Node Investment Scheme
Uulala represents transaction validation and is a critical component of Batched.

Rather than simply validating transactions in the background, Uulala has turned it into the hub of an investment scheme.

Affiliates with Uulala Sign up and invest $1100 on a validation node slot.

A validation node position enables a Uulala affiliate to log in and click a button.

This generates an unspecified number of “digital points.”

Once acquired, digital points are parked with Uulala with the promise of a return.

Park up to 15,000 digital points and receive 5 cents per point. Redeem park 15,001 to 99,999 digital points and receive 7 cents per point redeemed park 100,000+ points and receive 10 cents per point redeemed
Uulala controls the redemption of digital points.

According to the company, digital points are linked to transactions on the Batched platform.

Referral commissions are available on validation node investment, paid down two levels of recruitment (unilevel):

level 1 (personally recruited affiliates) – 30%
level 2 – 10%
Joining Uulala Uulala affiliate membership is contingent on the purchase of a $1100 validation node position.

It is worth noting that Uulala’s marketing materials state that the required investment amount will rise with every 500 positions purchased.

Conclusion
Lucrazon Global’s marketing ploy was a finance alternative platform.

Affiliates allegedly invested $1000 to $15,000 and received a passive return through the use of its platform.

Lucrazon Global was a Ponzi scheme that primarily recycled invested funds to pay returns to affiliate investors.

Uulala is essentially the same model, but with cryptocurrency and “digital points.”

The original plan was most likely to use UULA and EUULA tokens, but the SEC put a stop to that.

Regardless of whether UULA, EULLA, or digital points are used, Uulala’s validation node investment scheme is still a securities offering.

Oscar Garcia himself claims that validation node positions are worth $5000.

Garcia goes on to say that validation node positions are “worth quite a bit of money.”

He represents Uulala affiliate investors who will be able to sell their positions at a profit in the future.

Uulala’s requirement that affiliates sign in and click a button to receive digital points is analogous to Zeek Rewards’ requirement that affiliates log in each day to enter advertising URLs.

We can earn these daily points by logging in, clicking the start button, and assisting in the validation of these transactions.

They validate the transactions and are paid a percentage of the proceeds.

You can then enter those points into our transaction gateway after you have earned them.

It’s busywork that has nothing to do with generating profits.

Even if it did, clicking a button is entirely passive – whether anything happens or not, the “work” is still done passively via Uulala’s systems.

Thus, the criteria of an investment contract are met.

Uulala affiliates invest $1100 (or more) in the expectation of a passive return generated by the efforts of others.

Parking digital points with Uulala and waiting for them to be “used” is simply a mechanism for controlling the rate of withdrawal.

If new investment dries up, Uulala may reduce or discontinue the use of digital points. All they have to tell their affiliates is that there aren’t enough transactions taking place.

No doubt, Uulala will point to their Batched platform and claim that actual transactions are taking place and that everything is legal.

The issue is that Uulala’s validation node scheme is still an investment contract. This qualifies Uulala’s MLM opportunity as a security offering.

Companies that offer securities in the United States must register with the SEC and submit audited financial reports on a regular basis.

These reports are the only way for consumers to verify that Uulala is generating external revenue to pay for digital point returns.

Perhaps unsurprisingly, neither Uulala nor Oscar Garcia (right) are registered with the SEC as of this writing.

There are no financial reports, so the only verifiable source of revenue entering Uulala is new $1100 investments.

Any revenue claims made by any MLM company marketing a securities offering should never be taken at face value.

This is especially true with Uulala.

This is from the SEC’s August 2021 complaint.

This case involves Defendant Uulala, Inc. (“Uulala”)’s fraudulent and unregistered offer and sale of digital asset securities known as UULA tokens, as well as its subsequent fraudulent and unregistered offer and sale of promissory notes that could be converted to equity (the “Convertible Notes”).

Uulala bills itself as a “financial solutions platform that gives the world’s underbanked populations access to the financial inclusion tools they need to change their future.”

Uulala represented to investors that it had created a functional mobile phone application (“app”) that allows users to store, transfer, and borrow money, pay bills, make purchases, earn rewards for this activity, and establish a credit history to qualify for microcredit loans.

The UULA White Paper made false claims about Uulala’s technology, including that it used “Proprietary Patent Pending Decentralized Database Technology.”

This technology was actually owned and patented by a different company; Uulala had no rights to it, and Uulala had not incorporated it at the time of the UULA offering.

Beginning in 2019, Uulala and Garcia raised an additional $500,000 from four US investors through their Convertible Notes offering.

Garcia created a presentation slide deck to promote the offering, which they showed to potential investors.

This offering document contained false financial information about Uulala, including a claim that it had over $250,000 in revenue in 2019, which Garcia admitted was false.

Defendant Oscar Garcia (“Garcia”), co-founder and CEO of Uulala, was the primary architect of both fraudulent offerings.

We know Uulala has no problem with using 40% of validation node investments to pay referral commissions.

Even using a small portion of what’s left to fund digital point withdrawals would turn Uulala into a Ponzi scheme.

The more pressing issue, however, is securities fraud.

Oscar Garcia got away with security fraud at Lucrazon Global.

Uulala Garcia doubled down on securities fraud with his own platform and was caught.

He’s now tripled down with the Batched validation node investment scheme.

Thisisn’t going to end well.

In an email sent to Uulala investors on August 10th, the company admitted;

The investigation concluded with a settlement between Uulala and the SEC in which Uulala agreed to abide by the Securities Act of 1933, as do all other companies, and Uulala cannot sell any unregistered securities until and unless a registration statement is in effect.

Given Garcia’s history of deception, I’m confident that all we’re seeing here is a variant of the “staking” MLM crypto Ponzi model.

That is, participants invest in tokens/coins (digital points), park those tokens/coins with the company (staking), and collect a passive ROI.

Returns are paid entirely or primarily from subsequently invested funds, resulting in a Ponzi scheme model.

As with all MLM Ponzi schemes, once affiliate recruitment dries up, so will new investment.

This will deprive Uulala of ROI revenue (either partially or completely), resulting in a collapse.

The math behind Ponzi schemes ensures that the vast majority of participants lose money.

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