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EXHIBIT A
Case 1:21-md-02989-CMA Document 572-3 Entered on FLSD Docket 06/09/2023 Page 1 of 4
Notice of Filing of Securities Class Action
Against Robinhood Markets, Inc. -
HOOD
Klafter Lesser LLP
April 10, 2023
RYE BROOK, NEW YORK, April 5, 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
Case 1:21-md-02989-CMA Document 572-3 Entered on FLSD Docket 06/09/2023 Page 2 of 4
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 multidistrict litigation, In re January 2021 Short Squeeze
Trading Litigation, 1:21-md-02989, pending before the 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.
Case 1:21-md-02989-CMA Document 572-3 Entered on FLSD Docket 06/09/2023 Page 3 of 4
.
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
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