Pelican Way Research on CitroTech Inc.
Bottom Line
Activ8 Report Assessment
Activ8 evaluates every investigator report across three dimensions: the nature of the thesis, the type of evidence supporting it, and the catalyst for stock repricing. Scores are derived solely from the source report. New to these dimensions? Read our guide.
Pelican Way alleges deliberate deception including use of a misleading $13.6B TAM figure, over-promotional press releases calling the product 'revolutionary,' and marketing claiming 'weeks to months' of durable protection despite documented water-leaching failures. Governance concerns center on a $7.5mm Conboy royalty clause, ~$10mm in management stock awards on $2.4mm revenue, and insider stock structured to convert and sell into the public market. The stock trades at 57.5x sales on a product the firm believes has no viable commercial path.
Pelican Way cites analytical valuation work (57.5x sales multiple, management compensation vs. revenue), documentary evidence including SEC filings (FY25 10-K, patents, EcoBlu SEC records), FINRA censure records for Univest, and peer-reviewed academic research (Yun et al. 2024, University of Göttingen). Primary investigation includes review of patents via Justia, review of the CitroTech website, and field research into predecessor entities and their regulatory histories.
The primary thesis, that a 30-year-old failed chemistry is being promoted at 57.5x sales with no recurring customers, is the core repricing argument. A pending catalyst exists in the form of insider stock conversion and sale mechanics: the retiring of super-voting preferred converted to common with registration rights and a five-day legend strip covenant, which Pelican Way believes is machinery to sell into the public.
Not Present: Specific Event
How CitroTech Makes Money
CitroTech Inc. (NYSE American: CITR) describes itself as an 'environmentally sustainable specialty chemical company focused on fire inhibitor products.' Its fire retardant products are based on Tri-Potassium Citrate (TPC), a commodity food-grade potassium salt whose primary commercial uses are sports drinks, pharmaceuticals, and food processing. The company reported approximately $2.4mm in FY25 revenues per its 10-K and carries a ~$150mm market capitalization. Its products are reportedly blended at a 10,000-square-foot warehouse in Oceanside, CA. The company's FY25 10-K states it 'does not have major sales from recurring customers.' CitroTech's core chemistry originates from formulations developed by Indonesian inventor Randall Hartolaksono in the 1990s.
Main Report Evidence
Insiders Extract Millions While Business Receives Almost Nothing
Pelican Way's analysis of the FY25 10-K shows management received approximately $10mm in stock awards in FY25 alone, roughly 7% of total market capitalization as of May 29, 2026, against only ~$2.4mm in annual revenue. When Craig Huff's ~$5.7mm in stock awards paid to BoltRock Holdings LLC during 2025 is included, total insider extraction balloons to over $15mm. Capital actually invested in the business (R&D, capex in property and equipment, and acquired cash from loan financing) is shown to be a fraction of that extraction.
Insider Extraction vs. Capital Invested in Business — FY25
| Item | Amount |
|---|---|
| Management stock awards (named executives) | ~$10mm |
| Craig Huff stock awards (to BoltRock Holdings LLC) | ~$5.7mm |
| Total insider extraction (including Craig Huff) | >$15mm |
| FY25 Total Revenue | ~$2.4mm |
| Management stock awards as % of market cap (as of 5/29/26) | ~7% |
Source: CitroTech FY25 10-K (Page 48 for Craig Huff / BoltRock Holdings disclosure)
Key Allegations
TPC Loses Effectiveness After Rain Exposure
A 2024 peer-reviewed study by Sanghun Yun, Adele Chabert, and Holger Militz at the University of Göttingen tested TPC-treated Scots pine at concentrations of 10%, 20%, and 30% via vacuum and impregnation, evaluating fire performance before and after the EN 84:2020 leaching procedure. The study concluded: 'While TPC exhibited high flame retardancy prior to leaching, its efficacy diminished post-leaching, underscoring challenges in fixation and the need for improved retention strategies.' Cone calorimetry, a more rigorous quantitative test than the Bunsen burner test, 'showed less favorable outcomes' on leached specimens. Pelican Way notes that CitroTech's own product-page marketing claims a durable layer lasting 'weeks to months,' and that no rain-resistance test was found in any CitroTech SEC filing or on their website.
Same Failed Chemistry, Five Prior Entities
Pelican Way found evidence that the underlying TPC-based chemistry was developed by Indonesian inventor Randall Hartolaksono in the 1990s and marketed through Newstar Chemicals in Malaysia without lasting success. Five separate entities have attempted to commercialize the identical chemistry in North America: Megola Inc. (executed a technology purchase agreement in 2007 with Hartolaksono's Newstar Chemicals, claimed to blend AF21 from 2008, was subsequently sued by Hartolaksono, and is now effectively defunct); EcoBlu Products (OTCBB, led by Steve Conboy, eventually merged into Eco Building Products and had its registration revoked for failure to file); M-Fire Suppression Inc. (a third Conboy-led venture per his LinkedIn); Mighty Fire Holdings LLC (received IP from M-Fire Suppression); and the current CitroTech iteration (GEVI/CITR, received IP from Mighty Fire Holdings). Pelican Way states it could not find a single instance where this technology worked out for investors, and that none have ever generated meaningful revenue. A patent uncovered by Pelican Way further states that a predecessor EcoBlu product was 'produced using… Hartindo AF21 total fire inhibitor' and that 'it was later discovered that these chemical components interacted chemically in an undesired manner, to significantly reduce the fire-inhibiting performance of Hartindo AF21.'
No Exclusivity, No ISO Certification, No Recurring Customers
Pelican Way found that CitroTech holds no commercial exclusivity rights to its base chemicals, corroborated by the FY25 10-K statement: 'There are no contracts in place with the suppliers.' Randall Hartolaksono's independent US entity, M-Fire Technologies, markets the same base chemistry under different branding for industrial and structural fire protection applications, and Pelican Way found no acknowledgement of this entity in any CitroTech SEC filing. The company also lacks ISO 9001 certification, the recognized standard for quality management systems. On the customer side, the FY25 10-K states the company 'does not have major sales from recurring customers,' and accounts receivable concentration from three customers stood at ~61.1% at year-end 2025 (down from ~86.3% in 2024), which Pelican Way reads as a small number of one-off municipal and commercial buyers rather than a diversified or recurring revenue stream.
Univest Securities: Placement Agent Tied to Pump-and-Dumps
Pelican Way found that Univest Securities LLC has served as sole placement agent for nearly every CitroTech capital raise. Univest was previously censured and fined approximately $20,000 by FINRA for failing to develop an AML program reasonably designed for BSA compliance, involving approximately $37mm in proceeds from foreign clients liquidating low-priced securities. Univest's clearing firm, Velox Clearing, was subject to an SEC Cease-and-Desist for willful Exchange Act violations including failing to file at least 218 SARs, and was fined and censured by FINRA for an inadequate AML program and for not preserving over 10,000 WeChat messages. Among Univest's prior clients: Ostin Technology Group (whose co-CEO was indicted in connection with a $100mm securities fraud pump-and-dump scheme); Faraday Future Intelligent Electric (covered by Wolfpack Research, with shares down ~86% since that September 2025 report; Univest did $175mm+ in placements for FFAI); Super X AI / SUPX (covered by Pelican Way in September 2025 for allegedly fabricating products and being a 'China Hustle,' shares down ~80%+ since that report); and Ebang / EBON (covered by Hindenburg Research, with Univest working with EBON after the Hindenburg report was published).
Extreme Overcompensation and Insider-Exit Governance Structure
In FY25, Pelican Way calculated that the named management team received approximately $10mm in stock awards combined, equal to roughly 7% of total market capitalization as of May 29, 2026, against only ~$2.4mm in annual revenue. Craig Huff received an additional ~$5.7mm in stock awards paid to BoltRock Holdings LLC during 2025, bringing total insider extraction to over $15mm. Former CTO Steve Conboy's transition advisory agreement includes a $7.5mm royalty payable in $1.5mm-per-year annual tranches of restricted common stock, triggered only if CitroTech hits $10mm in revenues; Pelican Way notes that even if CitroTech were to quadruple revenue to that threshold, the stock would still trade at ~13.8x sales at current prices, meaning common holders capture zero multiple expansion for hitting the milestone while Conboy begins receiving $1.5mm per year in stock. Separately, Pelican Way found that Chairman Ted Ralston settled a lawsuit by handing over stock he marked at $0.28 per share, versus the ~$6.87 closing price on June 3, 2026, and that the retirement of super-voting preferred stock, framed as a governance cleanup, resulted in insiders swapping into common stock carrying registration rights and a five-day legend strip covenant, which Pelican Way believes is 'the machinery to sell into the public, and NOT a governance reform.'
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