Exhibit A: Comparison of Alleged Communications Between Citadel Securities and Robinhood (Dkt. 456-1, S.D. Fla.)

Summary

Exhibit A, a table comparing alleged communications between Citadel Securities and Robinhood in the DAC (ECF No. 416) and the AAC (ECF No. 451), was filed as Document 456-1 (8 pages) in Case 1:21-md-02989-CMA and entered February 18, 2022. The table sets paragraphs of the dismissed complaint beside the current complaint, such as the allegation that high-level executives of Citadel Securities regularly communicated and coordinated with high-level executives of Robinhood in the lead up to, during and after the restrictions imposed on or around January 28, 2021. Other rows quote alleged contacts with Josh Drobnyk, Robinhood's newly hired Vice President of Corporate Relations and Communications, including an allegation that Citadel Securities connected Drobnyk to coordinate the narrative in response to the trading restrictions.

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Date: 2021-01-28

Cite this document

“Exhibit A: Comparison of Alleged Communications Between Citadel Securities and Robinhood (Dkt. 456-1).” Original at archive.org, dated 2021-01-28. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2021-01-28-covid-era-misc/, SHA-256 971de96dcea6224a09cbade2fb0017be11c589018a8453f9be077e96ad5dc40b.

Full text

Case 1:21-md-02989-CMA Document 456-1 Entered on FLSD Docket 02/18/2022 Page 1 of 8

Exhibit A

Comparison of Alleged Communications Between Citadel Securities and Robinhood
Between the DAC (ECF No. 416) and the AAC (ECF No. 451)

Dismissed Complaint Current Complaint Comparison
296. “The Market Maker Defendants 226. “Citadel Securities was able to
were able to communicate with the communicate with Robinhood swiftly
brokerages swiftly and effectively and effectively because of their pre-
because of their pre-existing existing relationship. Indeed, high-
relationships. Indeed, high-level level executives of Citadel Securities
executives of Citadel Securities regularly communicated with and
regularly communicated with and coordinated with high-level
coordinated with high-level executives of Robinhood in the lead
executives of Robinhood and others up to, during and after the restrictions
in the lead up to, during and after the imposed on or around January 28,
restrictions imposed on or around 2021.”
January 28, 2021.”

297. “For example, on January 20, 227. “For example, on January 20, Same.
2021, [●], Head of Execution 2021, [●], Head of Execution
Services for Citadel Securities, and Services for Citadel Securities, and
Josh Drobnyk, the newly hired Vice Josh Drobnyk, the newly hired Vice
President of Corporate Relations and President of Corporate Relations and
Communications for Robinhood, Communications for Robinhood,
agreed to communicate. [●] and agreed to communicate. [●] and
Drobnyk had a prior relationship Drobnyk had a prior relationship
through Drobnyk’s employment at through Drobnyk’s employment at
FINRA when [●] served on FINRA’s FINRA when [●] served on FINRA’s
board.” board.”

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Dismissed Complaint Current Complaint Comparison
298. “During this communication, [●] 228. “During this communication, [●] Same.
extended a proposition to Drobnyk. extended a proposition to Drobnyk.
Drobnyk discussed with Dan and Drobnyk discussed with Dan and
Lucas, likely Daniel Gallagher and Lucas, likely Daniel Gallagher and
Lucas Moskowitz, Robinhood’s chief Lucas Moskowitz, Robinhood’s chief
legal officer and deputy general legal officer and deputy general
counsel respectively and agreed to counsel respectively and agreed to
revert to [●] ‘by early next week at revert to [●] ‘by early next week at
the latest.’” the latest.’”

299. “[●] responded it was ‘good to 229. “[●] responded it was ‘good to Same.
reconnect and very happy that we reconnect and very happy that we
will be working together.’ will be working together.’
Additionally, [●] responded for Additionally, [●] responded for
Drobnyk to ‘just let us know if Drobnyk to ‘just let us know if
interested and who the main contact interested and who the main contact
should be.’” should be.’”

300. “On Monday, January 25, 2021, 230. “On Monday, January 25, 2021,
Drobnyk emails [●] and says ‘[w]e Robinhood, through Drobnyk emails
are on board.’ Drobnyk says Lucas [●]: ‘We are on board.’ Drobnyk says
Moskowitz, Robinhood’s deputy Lucas Moskowitz, Robinhood’s
general counsel, would be the main Deputy General Counsel, Moskowitz,
point of contact.” would be the main point of contact
for Robinhood.”

301. “[●] in turn extends an invitation 231. “[●] in turn extends an invitation Same.
to Moskowitz to ‘chat’ and expressed to Moskowitz to ‘chat’ and expressed
that ‘we obviously have a strong that ‘we obviously have a strong
relationship between the two firms.’” relationship between the two firms.’”

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Dismissed Complaint Current Complaint Comparison
302. “[●] and Moskowitz then 232. “[●] and Moskowitz then
arranged a call for 11 a.m. Eastern arranged a call for 11 a.m. EST on
time on January 26, 2021.” January 26, 2021.”

303. “While the details of these 233. “While the details of these
communications have not been communications have not yet been
disclosed, it is clear that these disclosed, it is clear that these high-
representatives of Citadel Securities level representatives of Citadel
and Robinhood reached an agreement Securities and Robinhood reached an
on January 25, 2021, and each took explicit agreement on January 25,
affirmative steps in furtherance of the 2021, and each took affirmative steps
illicit scheme.” in furtherance of the illicit scheme.”

304. “On January 27, 2021, the day 235. “On January 27, 2021, the day
before the restrictions were before the restrictions were
implemented, high level employees implemented, high level employees
of Citadel Securities and Robinhood of Citadel Securities and Robinhood
had numerous communications with had numerous communications with
each other that indicate that Citadel each other that indicate that Citadel
applied pressure on Robinhood.” Securities applied pressure on
Robinhood.”

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Dismissed Complaint Current Complaint Comparison
305. “In an internal Slack chat 237. “In an internal Slack chat Same.
conversation, Gretchen Howard, conversation, Gretchen Howard,
Robinhood’s Chief Operating Robinhood’s Chief Operating
Officer, informs Vlad Tenev that Officer, informs Vlad Tenev that
‘Dan and I are joining Jim at 5pm on ‘Dan and I are joining Jim at 5pm on
a call with Citadel.’ Dan and Jim a call with Citadel.’ Dan and Jim
likely refer to Dan Gallagher and Jim likely refer to Dan Gallagher and Jim
Swartwout, President and Chief Swartwout, President and Chief
Operating Officer of Robinhood Operating Officer of Robinhood
Securities. Citadel Securities had Securities. Citadel Securities had
requested to speak that evening. requested to speak that evening.
Howard indicated that she believed Howard indicated that she believed
Citadel Securities would make Citadel Securities would make
demands on limiting payment for demands on limiting payment for
order flow.” order flow.”

307. “Tenev muses that ‘Maybe this 239. “Tenev muses that ‘Maybe this Same.
would be a good time for me to chat would be a good time for me to chat
with Ken griffin [sic]’ and tells with Ken griffin [sic]’ and tells
Howard, ‘You guys can mention Howard, ‘You guys can mention
that.’” that.’”

309. “Swartwout responds that 241. “Swartwout responds that Same.
‘everyone is. you wouldnt [sic] ‘everyone is. you wouldnt [sic]
believe the convo we had with believe the convo we had with
Citadel. total mess.’” Citadel. total mess.’”

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Dismissed Complaint Current Complaint Comparison
310. “At 8:16 p.m., Swartwout emails 242. “At 8:16 p.m., Swartwout emails Same.
[●] at Citadel Securities looking for [●] at Citadel Securities looking for
‘new Citadel numbers.’ [●] informs ‘new Citadel numbers.’ [●] informs
Swartwout at 9:31 p.m. that the Swartwout at 9:31 p.m. that the
numbers were ‘[f]irming up right numbers were ‘[f]irming up right
now in light of the follow up now in light of the follow up
conversation between Gallagher and conversation between Gallagher and
[●].’” [●].’”

311. “At 8:29 p.m., [●], Citadel 243. “At 8:29 p.m., [●], Citadel Same.
Securities’s Vice President of Securities’s Vice President of
Business Development, emailed Business Development, emailed
Robinhood personnel including Robinhood personnel including
Swartwout that [●], ‘whom Vlad has Swartwout that [●], ‘whom Vlad has
met before, is available until 10pm met before, is available until 10pm
EST to speak to Vlad.’ [●] offers to EST to speak to Vlad.’ [●] offers to
set up a call.” set up a call.”

312. “Swartwout, in turn responds 244. “Swartwout, in turn responds Same.
minutes later, ‘Because of our minutes later, ‘Because of our
partnership, Vlad would like to have partnership, Vlad would like to have
a discussion with Ken [Griffin] at a discussion with Ken [Griffin] at
some point, just given our some point, just given our
relationship. Not specific to this relationship. Not specific to this
crazy issue.’” crazy issue.’”

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Dismissed Complaint Current Complaint Comparison
313. “Swartwout later cryptically 245. “Swartwout later cryptically Same.
tells [●], ‘I have to say I am beyond tells [●], ‘I have to say I am beyond
disappointed in how this went down. disappointed in how this went down.
It’s difficult to have a partnership It’s difficult to have a partnership
when these kind of things go down when these kind of things go down
this way.’” this way.’”

332. “In order to disguise their illegal 257. “In order to disguise their illegal
agreement after the restrictions on or agreement after the restrictions on or
around January 28, 2021, high-level around January 28, 2021, high-level
executives and communications executives and communications
professionals at Citadel Securities professionals at Citadel Securities
and Robinhood communicated and Robinhood communicated to
between each other to coordinate coordinate their messaging.”
their messaging.”

333. “On January 30, 2021, Citadel 258. “On January 30, 2021, Citadel Same.
Securities’s [●] sent an email to Josh Securities’s [●] sent an email to Josh
Drobnyk, Robinhood’s Vice Drobnyk, Robinhood’s Vice
President of Corporate President of Corporate
Communications. In this email, [●] Communications. In this email, [●]
introduced Drobnyk to [●], who [●] introduced Drobnyk to [●], who [●]
described as the person ‘running described as the person ‘running
point on this narrative for us.’ [●] point on this narrative for us.’ [●]
indicated he ‘wanted to generally indicated he ‘wanted to generally
coordinate messaging.’ Additionally, coordinate messaging.’ Additionally,
[●] cc’d two individuals he described [●] cc’d two individuals he described
as ‘our GCs’ ‘for privilege.’” as ‘our GCs’ ‘for privilege.’”

335. “[●] called Drobnyk twice after 260. “[●] called Drobnyk twice after Same.
the flight landed.” the flight landed.”

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Dismissed Complaint Current Complaint Comparison
N/A 320. “Indeed, communications
between executives and high-level
employees of Robinhood and Citadel
Securities demonstrates [sic]
Robinhood and Citadel’s PFOF
relationship was precisely a topic of
discussion during the week of
January 25, 2021, and on the eve of
the trading restrictions on the
Relevant Securities.”

309. “Swartwout responds that 321. “In the evening of January 27,
‘everyone is. you wouldnt [sic] 2021, the night before Robinhood
believe the convo we had with enacted restrictions, Robinhood’s
Citadel. total mess.’” Gretchen Howard indicated to Vlad
310. “At 8:16 p.m., Swartwout emails Tenev that she and Jim Swartwout
were going to have a call with Citadel
[●] at Citadel Securities looking for
wherein she believed that ‘they
‘new Citadel numbers.’ [●] informs
[Citadel] will make some demands on
Swartwout at 9:31 p.m. that the
limiting PFOF across the board.’
numbers were ‘[f]irming up right
Later that evening, Swartwout
now in light of the follow up
indicated that the conversation was a
conversation between Gallagher and
‘total mess.’ Robinhood’s Dan
[●].’”
Gallagher and Citadel’s [●] also had
311. “At 8:29 p.m., [●], Citadel discussions, which as Citadel
Securities’s Vice President of Securities’s [●] noted to Robinhood’s
Business Development, emailed Swartwout, altered certain ‘Citadel
Robinhood personnel including numbers’ that required ‘[f]irming up.’
Swartwout that [●], ‘whom Vlad has Robinhood’s Swartwout later emailed
met before, is available until 10pm Citadel Securities’s [●] that he was
‘beyond disappointed in how this
went down,’ and that ‘[i]t’s difficult

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Dismissed Complaint Current Complaint Comparison
EST to speak to Vlad.’ [●] offers to to have a partnership when these kind
set up a call.” of things go down this way.’”
312. “Swartwout, in turn responds
minutes later, ‘Because of our
partnership, Vlad would like to have
a discussion with Ken [Griffin] at
some point, just given our
relationship. Not specific to this
crazy issue.’”
313. “Swartwout later cryptically
tells [●], ‘I have to say I am beyond
disappointed in how this went down.
It’s difficult to have a partnership
when these kind of things go down
this way.’”

453. “Additionally, Robinhood’s N/A
Drobnyk appeared to accept Citadel
Securities’s [●] proposition made on
January 20, 2021.”

456. “For example, Citadel N/A
Securities’s [●] connected Citadel
Securities’s [●] and Robinhood’s
Drobnyk to coordinate the narrative
in response to the January 28, 2021
trading restrictions.”

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