IN RE January 2021 Short Squeeze Trading Litigation — Complaint, Doc. 565-7

Summary

Exhibit E, entered on the Southern District of Florida docket on 05/26/2023 as Document 565-7 in In re January 2021 Short Squeeze Trading Litigation, Case 1:21-md-02989-CMA. It reproduces an April 10, 2023 PRNewswire notice from Klafter Lesser LLP announcing a class action, filed with Pessah Law Group, PC and Chelin Law Firm in the Central District of California (Case No. 2:23-cv-02622), for investors holding call options on AAL, AMC, BB, BBBY, GME or NOK on the Robinhood platform as of the close on January 27, 2021. The suit alleges that Robinhood's purchase and exercise prohibitions from January 28, 2021 were market manipulation under Sections 9(a) and 10(b) of the Securities Exchange Act of 1934. The notice sets June 9, 2023 as the deadline to move for lead plaintiff and says the case may be transferred into the multidistrict litigation.

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Case 1:21-md-02989-CMA Document 565-7 Entered on FLSD Docket 05/26/2023 Page 1 of 3




             EXHIBIT E
     Case 1:21-md-02989-CMA Document 565-7 Entered on FLSD Docket 05/26/2023 Page 2 of 3




Notice of Filing of Securities Class Action Against
Robinhood Markets, Inc. - HOOD

NEWS PROVIDED BY
Klafter Lesser LLP 
10 Apr, 2023, 11:26 ET




RYE BROOK, N.Y., April 10, 2023 /PRNewswire/ -- Klafter Lesser LLP, a highly experienced class action law firm,
announces that it has filed a class action lawsuit, together with Pessah Law Group, PC and Chelin Law Firm, in the
United States District Court for the Central District of California, Case No. 2:23-cv-02622, seeking to represent investors
who held call options on the Robinhood Trading Platform as of the close on January 27, 2021 to purchase any of the
following stocks: American Airlines Group Inc. (NASDAQ: AAL), AMC Entertainment Holdings Inc. (NYSE: AMC),
BlackBerry Limited (NYSE: BB), Bed Bath & Beyond Inc. (NASDAQ: BBBY), GameStop Corp. (NYSE: GME), or Nokia
Corporation (NYSE: NOK) (the "Affected Options"), sold such options or such options expired, during the period January
28, 2021 through and including February 19, 2021 (the "Class Period"), and thereby suffered a loss.


WHAT THIS CASE IS ABOUT: The lawsuit alleges that, on January 28, 2021, Robinhood Markets, Inc. and two of its wholly
owned subsidiaries, Robinhood Financial, LLC and Robinhood Securities, LLC (collectively, Robinhood) prohibited
purchases of the stocks underlying the Affected Options on its platform and also prohibited purchases or the exercise of
the Affected Options, and thereby only allowed the closing out of such positions. The lawsuit further alleges that during
the period January 29, 2021, through February 4, 2021, Robinhood imposed significant limits on any such purchases and
continued to prevent the exercise of Affected Options on its trading platform. Consequently, the value of the Affected
Options dropped dramatically and remained depressed through at least February 19, 2021, and individual retail investors
holding Affected Options suffered significant losses. It is alleged that by virtue of these purchase and exercise
prohibitions and limitations. Robinhood engaged in market manipulation in violation of Sections 9(a) and 10(b) of the
Securities Exchange Act of 1934 (15 U.S.C. §§ 78i(a) and 78(j)(b), and Rule 10b-5 promulgated thereunder by the U.S.
Securities and Exchange Commission (17 C.F.R. § 240.10b-5)). By this lawsuit, Plaintiffs seek to recover damages for those
holders of the Affected Options who suffered losses resulting from this alleged market manipulation.


THE LEAD PLAINTIFF PROCESS: The Private Securities Litigation Reform Act of 1995 permits any investor who held
Affected Options on the Robinhood trading platform as of the close on January 27, 2021, who sold such options, or such
options expired, during the Class Period to seek appointment as lead plaintiff in this class action lawsuit. A lead plaintiff
is generally the movant with the greatest financials interest in the relief sought by the putative class who is also typical
and adequate of the putative class. A lead plaintiff acts on behalf of all other class members in directing a class action
lawsuit. The lead plaintiff can select a law firm of its choice to litigate the class action lawsuit. Pursuant to the Private
Securities Litigation Reform Act of 1995 (15 U.S.C. § 78u-4(a)(3)(A)(i)(II)), if you wish to serve as lead plaintiff, you must
move the Court that this action is pending in no later than June 9, 2023. While this action is currently pending in the
                                                                                                                                 
United States District Court for the Central District of California, it may be transferred and consolidated into the
    Case 1:21-md-02989-CMA
multidistrict                            Document
              litigation, In re January 2021        565-7 Trading
                                             Short Squeeze Entered   on FLSD
                                                                  Litigation,    Docket 05/26/2023
                                                                              1:21-md-02989,          Pagethe
                                                                                             pending before 3 of 3
Honorable Cecilia M. Altonaga in the United States District Court for the Southern District of Florida, before whom a
securities fraud class action only concerning investors in the stocks listed above (and others) is pending. You can contact
the Clerk of the Northern District of California, at 450 Golden Gate Avenue, San Francisco, CA 94102-3489, or by calling
(415) 522-2000, to find out if this lawsuit has been transferred to the Southern District of Florida and also for a copy of
the Complaint.



No class has yet been certified in the above action. Until a class is certified, you are not represented by counsel unless
you retain one, but you are not required to retain counsel. You may remain an absent class member and do nothing at
this point. An investor's ability to share in any potential future recovery is not dependent upon serving as lead plaintiff or
retaining counsel at this time.



To discuss your rights or interests regarding this class action, you are free to consult counsel of your choosing.


You may also contact Nancy Velasquez of the Klafter Lesser LLP law firm at (914) 934-9200 or via email at
nancy.velasquez@klafterlesser.com, or Pessah Law Group, PC at (310) 772-2261 or via email at info@pessahgroup.com or
Stuart Chelin at (310) 556-9664 or via email at stuart@chelinlaw.com.



Klafter Lesser LLP has extensive experience in prosecuting class actions and the founding partners of the firm, who have
extensive class action experience, have recovered over $1 billion for the benefit of classes in numerous cases. Please visit
our website for more information about the Firm.



Attorney Advertising. Prior results do not guarantee a similar outcome.


Contact:
Jeffrey Klafter
KLAFTER LESSER LLP
2 International Drive, Suite 350
Rye Brook, NY 10573
(914) 934-9200
SOURCE Klafter Lesser LLP



SOURCE Klafter Lesser LLP




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