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Home Source documents Exhibit D: Defendants’ Responses and Objections to Plaintiffs’ Rule 30(b)(6) Deposition Notice (Document 586-4)

Exhibit D: Defendants’ Responses and Objections to Plaintiffs’ Rule 30(b)(6) Deposition Notice (Document 586-4)

Summary

Exhibit D to Document 586 in In re: January 2021 Short Squeeze Trading Litigation (Case 1:21-md-02989-CMA, Document 586-4), entered on the FLSD docket August 7, 2023: the 54-page responses and objections of the Robinhood defendants to Plaintiffs' Rule 30 corporate-representative deposition notice, dated June 2, 2023. Robinhood Markets, Inc., Robinhood Financial LLC and Robinhood Securities, LLC respond to the deposition notice dated May 5, 2023 served by Lead Plaintiff Blue Laine-Beveridge and the named Plaintiffs with general objections and specific responses to Topics 1 through 59, the last of which Defendants call an impermissible catch-all topic. The responses are signed /s/ Antony Ryan for Cravath, Swaine & Moore LLP with Hunton Andrews Kurth LLP, and a certificate of service by Kathleen Young records electronic-mail service on The Rosen Law Firm, P.A. on June 2, 2023.

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Date
2023-08-07

Cite this document

“Exhibit D: Defendants’ Responses and Objections to Plaintiffs’ Rule 30(b)(6) Deposition Notice (Document 586-4).” Original at archive.org, dated 2023-08-07. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-08-07-covid-era-misc-635041f4-1/, SHA-256 635041f4a79eabff1a962e2c56e4230fa8034d997f8646c249de598576b5c4da.

Full text

Case 1:21-md-02989-CMA Document 586-4 Entered on FLSD Docket 08/07/2023 Page 1 of 54




             EXHIBIT D
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                               UNITED STATES DISTRICT COURT
                               SOUTHERN DISTRICT OF FLORIDA


    In re: JANUARY 2021 SHORT SQUEEZE                     Case No. 21-2989-MDL-
    TRADING LITIGATION                                    ALTONAGA/Damian


    This Document Relates to the Federal Securities Tranche


                      DEFENDANTS’ RESPONSES AND OBJECTIONS TO
                      PLAINTIFFS’ RULE 30(b)(6) DEPOSITION NOTICE

                   Pursuant to Federal Rule of Civil Procedure 30, the Local Civil Rules for the

    Southern District of Florida (“Local Rules”) and any other applicable laws or rules, Robinhood

    Markets, Inc., Robinhood Financial LLC and Robinhood Securities, LLC (collectively,

    “Defendants”) hereby submit the following responses and objections (“Responses”) to Lead

    Plaintiff Blue Laine-Beveridge, named Plaintiffs Abraham Huacuja, Ava Bernard, Brendan

    Clarke, Brian Harbison, Cecilia Rivas, Doi Nguyen, Joseph Gurney, Marcel Poirier, Sandy Ng,

    Santiago Gil Bohórquez and Thomas Cash’s (collectively “Plaintiffs”) Notice of Rule 30(b)(6)

    Deposition dated May 5, 2023 (the “Notice”), inclusive of the Topics for Robinhood 30(b)(6)

    Deposition in Schedule A of the Notice (the “Topics”), in the above-captioned litigation

    (“Action”).

                                      GENERAL OBJECTIONS

                   The General Objections set forth below are incorporated in Defendants’ Specific

    Responses to each Topic set forth in Schedule A of the Notice. Defendants’ response to any

    Topic is not and shall not be deemed a waiver of Defendants’ General Objections.

           1.      Defendants object generally to the Notice, including, without limitation, the

    Definitions therein, on the ground and to the extent that they purport to impose duties and

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    obligations beyond those imposed by the Federal Rules of Civil Procedure, the Local Rules of

    the United States District Court for the Southern District of Florida and/or any applicable rule or

    law (together, the “Applicable Rules”). Subject to and without waiving any General or Specific

    Objections, to the extent Defendants provide information in response to the Notice, Defendants

    will construe the Topics in accordance with the Applicable Rules.

           2.      Defendants object generally to the Notice, including the Definitions set forth

    therein, to the extent that it seeks information that is cumulative or duplicative, including of

    Plaintiffs’ First Requests for Production of Documents, dated September 30, 2022. It would be

    premature to offer 30(b)(6) testimony on any Topics cumulative or duplicative of document

    requests for which Defendants will apply search terms to identify responsive material. Plaintiffs

    have failed to respond to Defendants’ proposed search terms for more than three months, which

    has substantially delayed Defendants’ review of custodial documents.

           3.      Defendants object generally to the Notice to the extent it requires Defendants to

    designate a witness from a particular corporate entity to testify with respect to Topics about

    which it has no knowledge or requires Defendants to designate duplicative witnesses from

    different corporate entities to testify with respect to the same Topic.

           4.      Defendants object generally to the Notice, including the Definitions set forth

    therein, to the extent that it would require disclosure of information that comes within the scope

    of the attorney-client privilege; the common interest or joint defense privilege; the attorney

    work product doctrine; privilege from disclosure of communications with litigation consultants

    and insurers to the extent recognized by applicable law; or any other applicable privilege,

    protection or immunity (collectively, “Privilege”). Defendants hereby claim such Privilege to

    the extent implicated by each Topic and, to the extent Defendants provide information in


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    response to the Notice, will exclude such privileged information from its Responses.

    Defendants’ Response to any Topic should not be construed as an acknowledgement by

    Defendants that the Topic is proper or calls for anything other than privileged information.

    Further, any inadvertent disclosure of information protected by any Privilege shall not be

    deemed a waiver of that Privilege.

           5.      Defendants object generally to the Notice, including the Definitions set forth

    therein, to the extent that it assumes disputed facts or purports to characterize facts in describing

    the Topics. Defendants hereby deny any such disputed facts or characterizations to the extent

    assumed by any of the Topics. Any provision of information in response to the Notice with

    respect to any such Topic is without prejudice to this Objection.

           6.      Defendants object generally to the Notice, including the Definitions set forth

    therein, to the extent that it contains inaccurate, incomplete or misleading descriptions of the

    facts, persons, relationships and/or events underlying the Action. Defendants further object to

    the Notice, including the Definitions set forth therein, to the extent that it assumes the existence

    of facts that do not exist or the occurrence of events that did not take place. Any provision of

    information in response to the Notice is not intended to provide, and shall not constitute or be

    construed as providing, an admission that any factual predicates stated in the Notice are

    accurate.

           7.      Defendants object generally to the Notice, including the Definitions set forth

    therein, as overbroad and unduly burdensome to the extent it seeks or inquires as to “any,” or

    “all,” documents related to a Topic.

           8.      Defendants object generally to the Notice, including the Definitions set forth

    therein, as overbroad to the extent that it seeks information unrelated to Counts I and II alleged


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    in Plaintiffs’ Amended Consolidated Class Action Complaint (“Claims”) in the Federal

    Securities Tranche. To the extent Defendants agree to provide information, they will do so only

    to the extent such information relates to the Claims currently pending in the Southern District of

    Florida. Defendants further object to the Notice to the extent it seeks information related to

    other claims alleged in the Antitrust Tranche.

           9.      Defendants object generally to the Notice, including the Definitions set forth

    therein, to the extent that it is vague and ambiguous, overly broad, unduly burdensome, lacking

    in particularity, unreasonable or seeks the discovery of information that is not relevant to the

    claims or defenses of any party to the pending Action, as well as to the extent that it is unduly

    burdensome because it imposes a significant expense and inconvenience on Defendants.

           10.     Defendants object generally to the Notice to the extent it calls for discovery that

    is more easily available through other, less burdensome means, including other discovery

    devices such as document requests, interrogatories and individual depositions.

           11.     Defendants object generally to the Notice to the extent that any Topic set forth

    therein calls for expert testimony.

           12.     Defendants object generally to the Notice to the extent that it calls for legal

    conclusions as to Defendants’ beliefs or is predicated on legal conclusions or arguments.

           13.     Defendants object generally to the Notice, including the Definitions set forth

    therein, to the extent that it purports to require Defendants to designate and produce for

    examination a witness to testify about matters: (i) beyond those that are known or reasonably

    available to Defendants, (ii) that are more appropriate for examination of individual witnesses in

    their individual capacities or (iii) about which Plaintiffs will have the opportunity to examine

    individual witnesses in their individual capacities. For any witnesses designated to testify


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    regarding a Topic in the Notice, Defendants will object to any attempt by Plaintiffs to depose

    that witness in their personal capacity at a later date; Defendants only agree to make witnesses

    available for a deposition on one occasion.

           14.     Defendants object generally to the Notice to the extent that it seeks information

    from a time period that is overbroad and disproportionate to the needs of this case. Defendants

    further object to the Notice to the extent that it purports to require Defendants to search for

    information not centrally maintained by, or on behalf of, persons believed to have had a

    significant connection to the parties’ claims or defenses in this Action.

           15.     Defendants object generally to the Notice to the extent that it seeks testimony

    without limitation as to time. Subject to and without waiving any General or Specific

    Objections, Defendants will apply the Relevant Period to each Topic unless otherwise specified.

           16.     To the extent Defendants provide information in response to the Notice,

    Defendants do so without waiver of or prejudice to (a) their rights at any later time to raise

    objections as to the competence, relevance, materiality, privilege, work product character and

    admissibility as evidence, for any purpose, of (i) the Notice or any part thereof or (ii) statements

    made in response to the Notice or any part thereof; or (b) the right to object to the use of any of

    the information disclosed in any subsequent proceedings or the trial of this or any other Action;

    or (c) the right to object on any ground at any time to a demand for further response to these or

    other discovery requests in these Action. Any response or objection to an individual Topic is

    not an acknowledgement that the information requested therein exists or is in Defendants’

    possession, custody or control.

           17.     Defendants provide the General Objections subject to further discovery in this

    Action as well as further verification and research. Defendants reserve the right to modify,


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    supplement or amend any or all of the General Objections, if necessary or appropriate, and to

    produce additional non-privileged information. Moreover, any purported failure on Defendants’

    part to provide information, or to set forth a particular legal argument, in response to the Notice

    shall not constitute any waiver or forfeiture of Defendants’ right to identify or rely upon

    additional relevant facts, documents and/or witnesses, or to make specific legal arguments, as

    this litigation progresses.

            18.     Defendants reserve the right, but do not assume any obligation to revise, correct,

    supplement or clarify the content of the Responses herein.

                                   OBJECTIONS TO DEFINITIONS

            19.     Defendants object to the Definitions and any directions, definitions or

    instructions contained in the Notice to the extent that they alter the generally understood

    definitions under the Federal Rules or seek to impose on Defendants obligations beyond those

    required by the Applicable Rules.

            20.     Defendants object to the Notice’s definition of “Action” on the ground that it

    should refer only to the Federal Securities Tranche.

            21.     Defendants object to the Notice’s definition of “Alleged Omissions and Half-

    Truths” because the statements referred to in Topics 25, 26 and 27 do not contain actionable

    omissions and are not “half-truths.”

            22.     Defendants object to the Notice’s definition of “Email” to the extent that it

    purports to impose any obligation on Defendants to search particular “personal computing

    devices, smartphones, [or] tablets” not used by potential custodians in the regular course of

    business.

            23.     Defendants object to the Notice’s definition of “Employee” as vague and


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    ambiguous as to the terms “agents” and “representatives”, and overbroad, unduly burdensome

    and not proportional to the needs of this case to the extent the definition includes “any Person

    acting or authorized or act on behalf of an entity.” For purposes of responding to this Notice,

    Defendants will construe “Employee” to refer to individuals employed by Defendants, and will

    exclude from the definition agents or representatives who are not directly employed by

    Defendants.

           24.     Defendants object to the Notice’s definition of “Financial Statements” as vague

    and ambiguous as to the terms “budget plans,” “commentary” and “workpapers.” Defendants

    further object to this definition as overbroad, unduly burdensome and not proportional to the

    needs of this case to the extent this definition includes “all notes or other commentary” and “all

    underlying work papers and all drafts” related to Financial Statements.

           25.     Defendants object to the Notice’s definition of “‘Identify’ when used to refer to a

    Document” as overbroad, unduly burdensome and not proportional to the needs of the case as to

    subparts (ii)-(iv), which would require an impossible, impracticable or unreasonable amount of

    preparation or memorization of information to permit any witness or group of witnesses to be

    able to address comprehensively.

           26.     Defendants object to the Notice’s definition of “‘Identify’ when used to refer to a

    natural person” as overbroad, unduly burdensome and not proportional to the needs of the case

    as to subparts (ii)-(iv), which would require an impossible, impracticable or unreasonable

    amount of preparation or memorization of information to permit any witness or group of

    witnesses to be able to address comprehensively.

           27.     Defendants object to the Notice’s definition of “Meme Stock Market Event” as

    vague and ambiguous as to the terms “facts and circumstances” and “gave rise to.” Defendants


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    further object to this definition as overbroad, unduly burdensome and not proportional to the

    needs of this case to the extent this definition includes no time limitation and goes beyond

    information related to the claims and defenses in this Action. For purposes of responding to this

    Notice, Defendants will construe “Meme Stock Market Event” to refer to the volatility

    experienced in the pricing and trading of volatile stocks, including the Later-Restricted Stocks,

    between December 2020 and February 2021, and the trading restrictions implemented by

    various broker-dealers, relevant to the claims and defenses in this Action.

           28.     Defendants object to the Notice’s definition of “Regard,” “regarding,” “refer,”

    “referring,” “relate,” relating,” “pertain,” or “pertaining” as vague and ambiguous. Defendants

    further object to this definition as overbroad, unduly burdensome and not proportional to the

    needs of this case to the extent this definition includes documents that “implicitly refer to” or

    were “reviewed in conjunction with” the “subject matter of the Request.”

           29.     Defendants object to the Notice’s definition of “Restrictions” as overbroad,

    unduly burdensome and not proportional to the needs of this case to the extent this definition

    does not include a specific time period. Defendants further object to this definition to the extent

    its assumes that Defendants forced the sale of stocks or options. For purposes of responding to

    this Notice, Defendants will construe “Restrictions” as the trading restrictions referenced in the

    Complaint and that were imposed on the Affected Stocks and Later-Restricted Stocks during the

    putative Class Period.

           30.     Defendants object to the Notice’s definition of “Restriction Period” as vague and

    ambiguous as to the terms “first imposition” and “lifting.” Defendants further object to this

    definition as overbroad, unduly burdensome and not proportional to the needs of this case to the

    extent this definition includes “any form of restriction.”


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          31.     Defendants object to the Notice’s definition of “Robinhood” and “Company” as

   overbroad, unduly burdensome and not proportional to the needs of this case to the extent this

   definition includes “partners” and “affiliates” of Robinhood. For the purposes of responding to

   this Notice, Defendants will construe “Robinhood” to mean Robinhood Markets, Inc.,

   Robinhood Financial LLC and Robinhood Securities, LLC.




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                           SPECIFIC RESPONSES AND OBJECTIONS

                   Defendants incorporate their General Objections to each of the Responses that

   follow as if such General Objections were set forth therein. Any Specific Objections set forth in

   the Responses are in addition to those General Objections and, unless otherwise specified,

   Defendants’ Responses are limited in accordance with both the General Objections and Specific

   Objections.

    Topic No. 1.

                 The communications media, devices, platforms, and applications used by
   Robinhood’s employees for work-related communications.

    Response to Topic No. 1.

                    Defendants object to this Topic on the grounds that it is unreasonably cumulative

   or duplicative of Plaintiffs’ Request for Production No. 79, in response to which Defendants have

   answered Plaintiffs’ questions at the meet and confer on November 28, 2022 and in their March

   1, 2023 letter. Defendants further object to this Topic on the grounds that it seeks information

   more easily available through other, less burdensome means (e.g., interrogatories). Defendants

   further object to this Topic on the grounds that terms in this Topic such as “communications

   media,” “platforms” and “work-related communications” are vague and ambiguous. Defendants

   further object to this Topic on the grounds that it seeks information neither relevant to the claims

   or defense of the parties nor proportionate to the needs of the case.

                    Defendants agree to designate a witness to testify regarding Topic No. 1.

    Topic No. 2.

                    The hardware devices used by Robinhood’s employees to perform their work-
   related functions.




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    Response to Topic No. 2.

                    Defendants object to this Topic on the grounds that it is unreasonably

   cumulative or duplicative of Plaintiffs’ Request for Production No. 79, in response to which

   Defendants have answered Plaintiffs’ questions at the meet and confer on November 28, 2022

   and in their March 1, 2023 letter. Defendants further object to this Topic on the grounds that it

   seeks information more easily available through other, less burdensome means (e.g.,

   interrogatories). Defendants further object to this Topic on the grounds that terms in this Topic

   such as “work-related functions” are vague and ambiguous. Defendants further object to this

   Topic on the grounds that it seeks information neither relevant to the claims or defense of the

   parties nor proportionate to the needs of the case.

                    Defendants agree to designate a witness to testify regarding Topic No. 2.

    Topic No. 3.

                   Robinhood’s policies and procedures related to the use of personal
   communications devices, personal email, personal computing devices or any non-Robinhood
   maintained device work related communications or any work-related functions, including but not
   limited to the location and identification of all Documents related to this topic.

    Response to Topic No. 3.

                   Defendants object to this Topic on the grounds that it is unreasonably cumulative

   or duplicative of information that Defendants have previously provided to Plaintiffs in their

   March 1, 2023 letter. Defendants further object to this Topic on the grounds that it seeks

   information more easily available through other, less burdensome discovery means (e.g.,

   interrogatories or document requests). Defendants further object to this Topic on the grounds

   that terms in this Topic such as “the location and identification of all Documents related to this

   topic” are vague, ambiguous and overbroad. Defendants further object to this Topic on the

   grounds that it seeks information neither relevant to the claims or defense of the parties nor

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   proportionate to the needs of the case.

                   Defendants agree to designate a witness to testify regarding Topic No. 3.

    Topic No. 4.

                   Robinhood’s record retention policies and practices, including but not limited to:
            (a)     The location, format, accessibility, architecture, and quantity of Robinhood’s
                    electronically stored information, including all personal computing devices
                    (including phones and tablets), network servers, cloud servers, instant
                    messaging, enterprise servers, and email servers;
            (b)     Robinhood’s litigation hold, if any, concerning Documents relevant to this
                    litigation; specifically, when such a hold was instituted, to whom, and how
                    such a hold is being monitored for compliance.

    Response to Topic No. 4.

                   Defendants object to this Topic on the grounds that it is unreasonably cumulative

   or duplicative of Plaintiffs’ Request for Production No. 78, in response to which Defendants

   have answered Plaintiffs’ questions about the litigation hold at the meet and confer on

   November 28, 2022 and in their March 1, 2023 letter, and that it is unreasonably cumulative or

   duplicative of Plaintiffs’ Request for Production No. 77, in response to which Defendants agreed

   in their March 1, 2023 letter to produce data retention policies. Defendants further object to this

   Topic on the grounds that it seeks information more easily available through other, less

   burdensome means (e.g., interrogatories or document requests). Defendants further object to this

   Topic on the grounds that terms in this Topic such as “accessibility,” “architecture” and

   “quantity” are vague and ambiguous and subsection (a) is overbroad and unduly burdensome as

   to all of Defendants’ ESI. Defendants further object to the use of the term “architecture” in

   subsection (a) to the extent it seeks confidential, trade secret, competitive, business, or other

   proprietary information. Defendants further object to this Topic on the grounds that it seeks

   information neither relevant to the claims or defense of the parties nor proportionate to the needs

   of the case. Defendants further object to this Notice to the extent subsection (b) seeks

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   information protected from disclosure by the attorney-client privilege, the work-product doctrine

   or any other applicable privileges or immunities.

                   Defendants agree to designate a witness to testify regarding Topic No. 4, with the

   exception of those to whom Robinhood’s litigation hold was sent.

    Topic No. 5.

                  Document production: Robinhood’s production of Documents in this litigation,
   including but not limited to the manner in which Documents responsive to Plaintiffs’ Requests
   For Production of Documents, were searched for, identified, and retrieved, and the databases,
   hardware, and devices searched.

    Response to Topic No. 5.

                   Defendants object to this Topic on the grounds that it would be premature to offer

   30(b)(6) testimony on this Topic, as Defendants are waiting on an agreement on search terms to

   begin their review. Defendants further object to this Topic on the grounds that it is unreasonably

   cumulative or duplicative of information that Defendants have previously provided to Plaintiffs

   in correspondence and meet and confers regarding Plaintiffs’ document requests. Defendants

   further object to this Topic to the extent Plaintiffs seek information about the format of

   Defendants’ productions to which the parties’ ESI protocol requires a specific format.

   Defendants further object to this Topic on the grounds that terms in this Topic such as

   “Robinhood’s production of Documents” are vague and ambiguous. Defendants further object

   to this Topic on the grounds that it is overbroad and unduly burdensome as to the production of

   tens of thousands of documents responsive to dozens of Plaintiffs’ document requests.

   Defendants further object to this Topic on the grounds that it seeks information neither relevant

   to the claims or defense of the parties nor proportionate to the needs of the case. Defendants

   further object to this Notice to the extent subsection (b) seeks information protected from

   disclosure by the attorney-client privilege, the work-produce doctrine or any other applicable

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   privileges or immunities.

                   Defendants are willing to meet and confer with Plaintiffs regarding Topic No. 5.

    Topic No. 6.

                 Custodians whose files were searched in connection with Robinhood’s production
   of Documents in this litigation, including but not limited to, the location and identification of all
   documents related to this topic

    Response to Topic No. 6.

                   Defendants object to this Topic on the grounds that it is unreasonably cumulative

   or duplicative of information that Defendants have previously provided to Plaintiffs, as reiterated

   in their March 1, 2023 letter. Defendants further object to this Topic on the grounds that terms

   in this Topic such as “in connection with” are vague and ambiguous. Defendants further object

   to this Topic on the grounds that it is overbroad and unduly burdensome as to “the location an

   identification of all Documents related to this topic.”

                   Defendants are willing to provide a response to an interrogatory seeking this

   information.

    Topic No. 7.

                  Robinhood’s public statements concerning the Meme Stock Market Event,
   including but not limited to, the location and identification of all Documents related to this topic.

    Response to Topic No. 7.

                   Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories or document

   requests). Defendants further object to this Topic to the extent that Plaintiffs seek the “location

   and identification of all Documents,” including those that are publicly available or already in

   their possession. Defendants further object to this Topic on the grounds that terms in this Topic

   such as “public statements” are vague and ambiguous.

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                   Defendants agree to designate a witness to testify regarding Topic No. 7.

    Topic No. 8.

                    Robinhood’s public statements about the Restrictions it imposed on trading in the
   Affected Stocks, including but not limited to, the location and identification of all Documents
   related to this topic.

    Response to Topic No. 8.

                   Defendants object to this Topic on the grounds that it seeks information more easily

   available through other, less burdensome means (e.g., interrogatories or document requests).

   Defendants further object to this Topic to the extent that Plaintiffs seek the “location and identification

   of all Documents,” including those that are publicly available or already in their possession. Defendants

   further object to this Topic on the grounds that terms in this Topic such as “public statements” are vague

   and ambiguous.

                   Defendants agree to designate a witness to testify regarding Topic No. 8.

    Topic No. 9.

                   Robinhood’s statements to its customers about the Restrictions it imposed on
   trading or lifted on the Affected Stocks, including but not limited to, the location and
   identification of all Documents related to this topic.

    Response to Topic No. 9.

                   Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories or document

   requests). Defendants further object to this Topic on the grounds that it is unreasonably

   cumulative or duplicative of Plaintiffs’ Request for Production Nos. 19-23, for which Defendants

   agreed to produce a representative sample of customer communications. Defendants further

   object to this Topic on the grounds that terms in this Topic such as “statements” are vague and

   ambiguous. Defendants further object to this Topic on the grounds that it is overbroad and

   unduly burdensome as to seeking “the location and identification of all Documents related to this
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   topic.”

                  Defendants agree to designate a witness to testify regarding Topic No. 9.

    Topic No. 10.

                  The trading Restrictions Robinhood imposed during the Meme Stock Market
   Event. In particular:
           (a)     The nature and extent of each of the Restrictions;
           (b)     The precise time each Restriction was announced, imposed and lifted;
           (c)      The details of the processes by which Robinhood’s decision to impose (and
                   lift) each of the Restrictions was discussed, evaluated, approved,
                   implemented, and publicized, including the identities, by job title and
                   specific roles and responsibilities, of any persons involved in such decisions;
           (d)     The reasons Robinhood imposed and lifted each of the trading Restrictions
                   at the various times during the Restrictions Period;
           (e)     The basis for how Robinhood selected the stocks on which to impose and lift
                   Restrictions during the two weeks prior to, and during, the Restrictions
                   Period, including but not limited to each factor Robinhood considered in
                   determining whether or not to impose or lift Restrictions and the sources of
                   information from which those factors were evaluated and determined;
           (f)     Robinhood’s consideration of its customers’ reactions to the imposition and
                   lifting of the Restrictions;
           (g)     Robinhood’s consideration of the possibility that purchasing demand for the
                   Affected Stocks or Later Affected Stocks might decline when Robinhood
                   imposed the Restrictions;
           (h)     Robinhood’s consideration of the possibility that selling pressure for the
                   Affected Stocks or Later Affected Stocks might increase when Robinhood
                   imposed the Restrictions;
           (i)     Robinhood’s consideration of the possibility that the prices of the Affected
                   Stocks or Later Affected Stocks might decline when Robinhood imposed the
                   Restrictions;
           (j)     Robinhood’s consideration and discussion of the impact a decline in the
                   prices of the Affected Stocks or Later Affected Stocks would have on its
                   customers, the market as a whole, market participants with positions in the
                   Later Affected Stocks, Robinhood itself and its business relationships,
                   including the Identity of any participants in any such discussions;
           (k)     The names, titles, functions, and roles of all persons responsible for and/or
                   participating in the decisions to implement or lift any such Restrictions;
           (l)     The location and identification of all Documents related to this topic.

    Response to Topic No. 10.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories or document

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   requests). Defendants further object to this Topic on the grounds that it is unreasonably

   cumulative or duplicative of information that Defendants have indicated they will provide to

   Plaintiffs (e.g., Plaintiffs’ Request for Production Nos. 3, 28, 30-31, 48, 57-58, 61-63, which are

   subject to search terms). Defendants further object to this Topic on the grounds that Topic 10(b)

   is partially duplicative of Topic 9. Defendants further object to this Topic on the grounds that

   terms in this Topic such as “nature and extent” and “customers’ reactions” are vague and

   ambiguous. Defendants further object to this Topic on the grounds that it is overbroad and

   unduly burdensome as to seeking “the identities, by job title and specific roles and

   responsibilities, of any persons involved in such decisions” in subsections (c), (j) and (k).

   Defendants further object to this Topic on the grounds that it is overbroad and unduly

   burdensome as to seeking “location and identification of all Documents related to this topic” in

   subsection (l). Defendants further object to this Topic on the grounds that it assumes disputed

   facts and calls for improper 30(b)(6) testimony on legal theories, contentions or conclusions as to

   Defendants’ consideration of purchasing demand (subsection (g)), Defendants’ consideration of

   selling pressure (subsection (h)) and Defendants’ consideration of price decline (subsections (i)-

   (j)). Defendants further object to this Topic on the grounds that it seeks information that would

   require an impossible, impracticable, or unreasonable amount of preparation or memorization of

   information to permit any witness or group of witnesses to be able to address comprehensively.

                  Defendants are willing to meet and confer with Plaintiffs regarding Topic No. 10.

    Topic No. 11.

                   Why Robinhood maintained position limits on several of the Affected Stocks as
   late as the market close on February 4, 2021, given that “Robinhood’s collateral deposit
   requirements were within manageable levels by January 29, 2021, and the company had raised
   the capital that its models suggested was sufficient to handle shock scenarios by the end of the
   day on February 2, 2021,” as referenced in the HFSC Report at 75, including but not limited to,
   the location and identification of all Documents related to this topic.

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    Response to Topic No. 11.

                  Defendants object to this Topic to the extent Plaintiffs seek information regarding

   a third party’s characterization of relevant events. Defendants further object to this Topic on the

   grounds that it seeks information more easily available through other, less burdensome means

   (e.g., interrogatories or document requests). Defendants further object to this Topic on the

   grounds that it is unreasonably cumulative or duplicative of Topic 10(c)-(d). Defendants further

   object to this Topic on the grounds that it is overbroad and unduly burdensome as to seeking

   “the location and identification of all Documents related to this topic.” Defendants further

   object to this Topic on the grounds that it assumes disputed facts or purports to characterize

   facts, including that “Robinhood maintained position limits on several of the Affected Stocks as

   late as the market close on February 4, 2021” due to its “collateral deposit requirements.”

                  Defendants agree to designate a witness to testify regarding Topic No. 11.

    Topic No. 12.

                    All bases for the comment (see RHMDL00077158) that Robinhood’s customers
   represented more than 10% of the market for the Affected Stocks just prior to and/or during the
   Restrictions Period including but not limited to, the location and identification of all Documents
   related to this topic.

    Response to Topic No. 12.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., a fact deposition of the individual

   who made the relevant statement). Defendants further object to this Topic on the grounds that it

   assumes disputed facts or purports to characterize facts, including that “Robinhood’s customers

   represented more than 10% of the market for the Affected Stocks just prior to and/or during the

   Restrictions Period.” Defendants further object to this Topic to the extent it seeks personal

   mental impressions or personal knowledge and not Defendants’ position, beliefs and opinions or

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   facts within the knowledge of the corporation.

                  Defendants agree to designate a witness to testify regarding Topic No. 12.

    Topic No. 13.

                   The existence and nature of any testimony or interviews with Robinhood
   employees regarding the Meme Stock Market Event, including but not limited to, the location
   and identification of all Documents related to this topic.

    Response to Topic No. 13.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories). Defendants further

   object to this Topic on the grounds that terms in this Topic such as “nature of” are vague and

   ambiguous. Defendants further object to this Topic on the grounds that it is overbroad as it

   seeks “any testimony or interviews with Robinhood Employees.” Defendants further object to

   this Topic on the grounds that it is partially duplicative of Plaintiffs’ Request for Production

   No. 4, which requested testimony of Vlad Tenev before the House Financial Services Committee

   that is publicly available, as Defendants noted in their January 5, 2023 letter. Defendants further

   object to this Topic to the extent it seeks information protected from disclosure by the attorney-

   client privilege, the work-produce doctrine or any other applicable privileges or immunities,

   such as interviews held by legal personnel.

                  Defendants are willing to provide a response to an interrogatory seeking this

   information.

    Topic No. 14.

                   The daily amount of PFOF earned by Robinhood from each of its six market
   makers on each of the Later Restricted Stocks during the Relevant Period, including any
   communications about this subject that occurred during the Relevant Period, including but not
   limited to the location and identification of all Documents related to this topic.



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    Response to Topic No. 14.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., document requests). Defendants

   further object to this Topic on the grounds that terms in this Topic such as “this subject” are

   vague and ambiguous. Defendants further object to this Topic on the grounds that it is

   unreasonably cumulative or duplicative of Plaintiffs’ Request for Production Nos. 65 and 66.

   Defendants further object to this Topic on the grounds that it is overbroad as it seeks “any

   communications about this subject” and “the location and identification of all Documents related

   to this topic.” Defendants further object to this Topic on the grounds that PFOF is not relevant

   to Plaintiffs’ allegations, which Defendants noted in the meet and confer on December 15, 2022.

   Defendants further object to this Topic on the grounds that it assumes disputed facts or purports

   to characterize facts, including that defendants earned PFOF “from each of its six market makers

   on each of the Later Restricted Stocks during the Relevant Period” and that Defendants can

   provide data on a daily basis as requested by this Topic. Defendants further object to this Topic

   on the grounds that it seeks information that would require an impossible, impracticable, or

   unreasonable amount of preparation or memorization of information to permit any witness or

   group of witnesses to be able to address comprehensively.

                  Defendants are willing to meet and confer with Plaintiffs regarding Topic No. 14.

    Topic No. 15.

                  How Robinhood’s PFOF from Citadel and other market makers was calculated
   during the Relevant Period, any changes, adjustments to the fees paid by Citadel or other brokers
   for PFOF, how and why the formulas for PFOF changed over that time period, and any contracts
   pursuant to which they were paid, including but not limited to, the location and identification of
   all Documents related to this topic.




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    Response to Topic No. 15.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories or document

   requests). Defendants further object to this Topic on the grounds that it is unreasonably

   cumulative or duplicative of Plaintiffs’ Request for Production No. 65. Defendants further

   object to this Topic on the grounds that terms in this Topic such as “calculated,” “changes” and

   “adjustments” are vague and ambiguous. Defendants further object to this Topic on the grounds

   that PFOF is not relevant to Plaintiffs’ allegations, which Defendants noted in the meet and

   confer on December 15, 2022.

                  Defendants are willing to meet and confer with Plaintiffs regarding Topic No. 15.

    Topic No. 16.

                  The project or proposal that Robinhood discussed with Citadel beginning on or
   around January 20, 2021, as referenced in ¶¶ 226-32 of the Antitrust Complaint (Dkt. No 451),
   including but not limited to, the location and identification of all Documents related to this topic.

    Response to Topic No. 16.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., fact depositions or document

   requests). Defendants further object to this Topic on the grounds that it is unreasonably

   cumulative or duplicative of Plaintiffs’ Request for Production No. 56. Defendants further

   object to this Topic on the grounds that terms in this Topic such as “project or proposal” are

   vague and ambiguous. Defendants further object to this Topic on the grounds that it seeks

   information neither relevant to the claims or defense of the parties nor proportionate to the needs

   of the case, as evidenced by its references to the Antitrust Tranche complaint.

                  Defendants are willing to meet and confer with Plaintiffs regarding Topic No. 16.


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    Topic No. 17.

                   All Robinhood’s communications with Citadel on January 27, 2021, including
   but not limited to those referenced in the HFSC Report at 47-51, e.g., the 8 p.m. call between
   Robinhood and Citadel referenced in the HFSC Report at 50-51, and including but not limited
   to, the location and identification of all Documents related to this topic.

    Response to Topic No. 17.

                    Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., fact depositions or document

   requests). Defendants further object to this Topic on the grounds that it is unreasonably

   cumulative or duplicative of Plaintiffs’ Request for Production No. 55. Defendants further

   object to this Topic on the grounds that it is overbroad and unduly burdensome as to seeking the

   “location and identification of all Documents related to this topic.”

                    Defendants are willing to meet and confer with Plaintiffs regarding Topic

   No. 17.

    Topic No. 18.

                  The importance to Robinhood’s financial performance, liquidity and financial
   condition of PFOF during the Relevant Period, including the percentage of its revenues that
   PFOF and in particular PFOF from Citadel had to its financial performance, liquidity and
   financial condition.

    Response to Topic No. 18.

                  Defendants further object to this Topic on the grounds that terms in this Topic

   such as “importance,” “financial performance,” “liquidity” and “financial condition.” are vague

   and ambiguous. Defendants further object to this Topic on the grounds that it assumes disputed

   facts or purports to characterize facts including “[t]he importance to Robinhood . . . of PFOF.”

   Defendants further object to this Topic on the grounds that PFOF is not relevant to Plaintiffs’

   allegations, which Defendants noted at the meet and confer on December 15, 2022.

                  Defendants are willing to meet and confer with Plaintiffs regarding Topic No. 18.
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    Topic No. 19.

                    Robinhood’s liquidity position and financial condition during the Relevant
   Period, as it related to its ability to meet its collateral and deposit requirements with all of its
   regulators during that time period, including but not limited to, the location and identification of
   all Documents related to this topic.

    Response to Topic No. 19.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories or document

   requests). Defendants further object to this Topic on the grounds that it is overbroad and unduly

   burdensome as to “the location and identification of all Documents related to this topic.”

   Defendants further object to this Topic on the grounds that terms in this Topic such as “liquidity

   position” and “financial condition” are vague and ambiguous.

                  Defendants agree to designate a witness to testify regarding Topic No. 19.

    Topic No. 20.

                 Robinhood’s communications with the NSCC and DTCC during the Meme
   Stock Market Event, including but not limited to, the location and identification of all such
   communications and all Documents memorializing both any part of the interactions with the
   NSCC and DTCC, as well as Robinhood’s strategy in its dealings with the NSCC and DTCC,
   and Documents gathered in response to requests by the NSCC and DTCC.

    Response to Topic No. 20.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories or document

   requests). Defendants further object to this Topic on the grounds that it is unreasonably

   cumulative or duplicative of Plaintiffs’ Request for Production Nos. 9-15, 17. Defendants

   further object to this Topic on the grounds that it would be premature to offer 30(b)(6) testimony

   on this Topic, as Defendants are waiting on an agreement on search terms to begin their review.

   Defendants further object to this Topic on the grounds that terms in this Topic such as “strategy”

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   and “dealings with” are vague and ambiguous. Defendants further object to this Topic on the

   grounds that it is overbroad and unduly burdensome as to “the location and identification of all

   such communications and all Documents.” Defendants further object to this Topic on the

   grounds that it seeks information that would require an impossible, impracticable, or

   unreasonable amount of preparation or memorization of information to permit any witness or

   group of witnesses to be able to address comprehensively.

                  Defendants agree to designate a witness to testify regarding Topic No. 20.

    Topic No. 21.

                   Robinhood’s ability or inability to meet the collateral and deposit requirements of
   the NSCC/DTCC during the Meme Stock Market Event, including the necessity of a capital
   infusion to meet such requirements, and including but not limited to, the location and
   identification of all Documents related to this topic, e.g., cash or liquidity projections, bank
   records, financial statements, fundraising efforts, and responses to requests made by the NSCC
   and DTCC.

    Response to Topic No. 21.

                    Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories or document

   requests). Defendants further object to this Topic on the grounds that it is unreasonably

   cumulative or duplicative of Plaintiffs’ Request for Production Nos. 12 and 38. Defendants

   further object to this Topic on the grounds that it would be premature to offer 30(b)(6) testimony

   on this Topic, as Defendants are waiting on an agreement on search terms to begin their review.

   Defendants further object to this Topic on the grounds that terms in this Topic such as “necessity

   of a capital infusion” are vague and ambiguous. Defendants further object to this Topic on the

   grounds that it is overbroad and unduly burdensome as to “cash or liquidity projects, bank

   records, financial statements, fundraising efforts, and responses to requests.”

                    Defendants agree to designate a witness to testify regarding Topic No. 21.

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    Topic No. 22.

                  The bases for CEO Vlad Tenev’s statement that Robinhood would have
   continued to allow unrestricted trading in the Later Affected Stocks during the Restrictions
   Period had Robinhood been more adequately capitalized as stated by CEO Tenev to Mark
   Portnoy and others.

    Response to Topic No. 22.

                    Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., a fact deposition of the individual

   who made the relevant statement). Defendants further object to this Topic on the grounds that it

   purports to characterize statements made in the referenced interview. Defendants further object

   to this Topic on the grounds that terms in this Topic such as “others” are vague and ambiguous.

   Defendants further object to this Topic on the grounds that it discusses an interview with “Mark

   Portnoy”; Defendants understand the referenced interview to have been with David Portnoy.

                    Defendants agree to designate a witness to testify regarding Topic No. 22.

    Topic No. 23.

                   The reasons why Robinhood did not disclose to the market during the Restrictions
   period the complete detailed set of reasons for imposing, lifting and reimposing Restrictions,
   including that it did not have adequate capitalization or liquidity to meet the collateral and
   deposit requirements of the NSCC/DTCC on January 28, 2021, and that had it not maintained
   the Restrictions during the Restrictions Period it might not have had adequate capitalization or
   liquidity to meet the collateral and deposit requirements of the NSCC/DTCC during the entirety
   of the Restrictions Period.

    Response to Topic No. 23.

                  Defendants object to this Topic on the grounds that terms in this Topic such as

   “adequate capitalization or liquidity” and “complete detailed set of reasons” are vague and

   ambiguous. Defendants further object to this Topic on the grounds that it assumes disputed

   facts or purports to characterize facts including that Defendants “did not disclose to the market

   during the Restrictions period the complete detailed set of reasons for imposing, lifting and

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   reimposing Restrictions” or “did not have adequate capitalization or liquidity to meet the

   collateral and deposit requirements of the NSCC/DTCC on January 28, 2021” and that had

   Defendants “not maintained the Restrictions during the Restrictions Period [they] might not

   have had adequate capitalization or liquidity to meet the collateral and deposit requirements of

   the NSCC/DTCC during the entirety of the Restrictions Period.” Defendants further object to

   this Topic to the extent it calls for testimony about a hypothetical. Defendants further object to

   this Topic on the grounds that it calls for improper 30(b)(6) testimony on legal theories,

   contentions or conclusions.

                  Defendants agree to designate a witness to testify regarding Topic No. 23.

    Topic No. 24.

                   The reasons why Robinhood did not announce publicly (i) the date when
   Robinhood intended to fully remove the Restrictions, and (ii) the contingencies affecting when
   it would fully remove the Restrictions.

    Response to Topic No. 24.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories or fact depositions).

   Defendants further object to this Topic on the grounds that it is unreasonably cumulative or

   duplicative of Plaintiffs’ Request for Production Nos. 30 and 31. Defendants further object to

   this Topic on the grounds that it would be premature to offer 30(b)(6) testimony on this Topic,

   as Defendants are waiting on an agreement on search terms to begin their review. Defendants

   further object to this Topic on the grounds that terms in this Topic such as “reasons why” and

   “contingencies” are vague and ambiguous. Defendants further object to this Topic on the

   grounds that it assumes disputed facts or purports to characterize facts, including that

   Defendants did not contemporaneously announce when they intended to ease or remove

   restrictions or the factors impacting when they would do so.
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                  Defendants agree to designate a witness to testify regarding Topic No. 24.

    Topic No. 25.

                   Robinhood’s belief as to whether the Alleged Omissions and Half-Truths were in
   fact disclosed and if so the basis for any such belief.

    Response to Topic No. 25.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories). Defendants further

   object to this Topic on the grounds that it is unreasonably cumulative or duplicative of Plaintiffs’

   Request for Production No. 26. Defendants further object to this Topic on the grounds that terms

   in this Topic such as “Alleged Omissions and Half-Truths” are vague and ambiguous.

   Defendants further object to this Topic on the grounds that it calls for legal conclusions as to

   Defendants’ beliefs. Defendants further object to this Topic on the grounds that it assumes

   disputed facts or purports to characterize facts, including that Defendants had any such belief.

   Defendants further object to this Topic on the grounds that it calls for improper 30(b)(6)

   testimony on legal theories, contentions or conclusions.

                  Defendants agree to designate a witness to testify regarding Topic No. 25.

    Topic No. 26.

                    Robinhood’s belief as to whether the Alleged Omissions and Half-Truths during
   the Restrictions Period: (1) caused or contributed to decreased demand for the purchase of the
   Affected Stocks, (3) caused or contributed to decreased demand for the Affected Stocks, which
   in turn caused a decrease in the share prices of the Affected Stock, (4) caused or contributed to a
   sell-off for the Affected Stocks that detrimentally affected the prices of the Affected Stocks or
   (3) caused or contributed to damages to Robinhood customers and other investors with positions
   in the Affected Stocks who sold shares of the Affected Stocks during the Class Period, and (4)
   the bases for any such beliefs.

    Response to Topic No. 26.

                  Defendants object to this Topic on the grounds that it seeks information more easily

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   available through other, less burdensome means (e.g., interrogatories). Defendants further object

   to this Topic on the grounds that terms in this Topic such as “Alleged Omissions and Half-Truths,”

   “sell-off” and “damages to Robinhood customers” are vague and ambiguous. Defendants further

   object to this Topic on the grounds that it is the subject of expert testimony. Defendants further

   object to this Topic on the grounds that it assumes disputed facts or purports to characterize facts,

   including that there was a decrease in demand for Affected Stocks, that there was a decrease in

   the share prices of the Affected Stocks, that there was a “sell-off” in the Affected Stocks and that

   Robinhood customers and other investors experienced damages. Defendants further object to this

   Topic on the grounds that it calls for improper 30(b)(6) testimony on legal theories, contentions

   or conclusions.

    Topic No. 27.

                   Robinhood’s beliefs or positions as to whether during the Restrictions Period the
   Alleged Omissions and Half-Truths had an effect on: (i) Robinhood customers, (ii) investors with
   positions in the Affected Stocks, or (iii) the prices of the Affected Stocks, and the bases for any of
   Robinhood’s beliefs or positions related to this topic.

    Response to Topic No. 27.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories). Defendants further

   object to this Topic on the grounds that terms in this Topic such as “beliefs or positions” and

   “investors with positions in the Affected Stocks” are vague and ambiguous. Defendants further

   object to this Topic on the grounds that it is the subject of expert testimony. Defendants further

   object to this Topic on the grounds that it assumes disputed facts or purports to characterize

   facts, including that Defendants had such beliefs or positions and that any Alleged Omissions

   and Half-Truths could have the effect claimed. Defendants further object to this Topic on the

   grounds that it calls for improper 30(b)(6) testimony on legal theories, contentions or

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   conclusions.

                  Defendants agree to designate a witness to testify regarding subsections (i) and

   (ii) of Topic No. 27.

    Topic No. 28.

                   Robinhood’s awareness of, and methods for, its internal calculations of its deposit
   and collateral requirements owed to the NSCC and DTCC during the Relevant Period, including
   but not limited to VaR and ECP charges, and including the location and identification of all
   Documents related to this topic.

    Response to Topic No. 28.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories or document

   requests). Defendants further object to this Topic on the grounds that it is unreasonably

   cumulative or duplicative of Plaintiffs’ Request for Production Nos. 13, 14 and 18. Defendants

   further object to this Topic on the grounds that it would be premature to offer 30(b)(6) testimony

   on this Topic, as Defendants are waiting on an agreement on search terms to begin their review.

   Defendants further object to this Topic on the grounds that terms in this Topic such as

   “awareness” and “internal calculation” are vague and ambiguous. Defendants further object to

   this Topic on the grounds that it is overbroad and unduly burdensome as to seeking “the location

   and identification of all Documents related to this topic.”

                  Defendants agree to designate a witness to testify regarding Topic No. 28.

    Topic No. 29.

                  The specific amounts for Robinhood’s collateral deposit and capital charges
   associated with each of the restricted stocks during each day of the Relevant Period and how
   those compared to other stocks that were heavily bought on Robinhood at the same time and the
   reasons and calculations therefore including but not limited to, the location and identification of
   all Documents related to this topic.




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    Response to Topic No. 29.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories or document

   requests). Defendants further object to this Topic on the grounds that it is unreasonably

   cumulative or duplicative of Plaintiffs’ Interrogatory No. 2, dated May 10, 2023. Defendants

   further object to this Topic on the grounds that terms in this Topic such as “collateral deposit and

   capital charges,” “how those compared to other stocks,” “heavily bought on Robinhood at the

   same time” and “the reasons and calculations therefore” are vague and ambiguous. Defendants

   further object to this Topic on the grounds that it is overbroad for failing to specify the relevant

   time “during each day of the Relevant Period” and unduly burdensome as to “the location and

   identification of all Documents related to this topic.” Defendants further object to this Topic on

   the grounds that it assumes disputed facts or purports to characterize facts, including that the

   “restricted stocks” are different from “other stocks that were heavily bought.” Defendants

   further object to this Topic on the grounds that it seeks information that would require an

   impossible, impracticable, or unreasonable amount of preparation or memorization of

   information to permit any witness or group of witnesses to be able to address comprehensively.

                  Defendants are willing to meet and confer with Plaintiffs regarding Topic No. 29.

    Topic No. 30.

                   The day and time Robinhood first discovered the potential for a liquidity problem
   during the Relevant Period, and how it discovered it, including but not limited to, the location
   and identification of all Documents related to this topic.

    Response to Topic No. 30.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories, fact depositions or

   document requests). Defendants further object to this Topic on the grounds that terms in this
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   Topic such as “discovered ” and “the potential for a liquidity problem” are vague and

   ambiguous. Defendants further object to this Topic on the grounds that it assumes disputed facts

   or purports to characterize facts, including that Defendants “discovered the potential for a

   liquidity problem” and that Defendants had any such potential liquidity problem. Defendants

   further object to this Topic on the grounds that it is overbroad and unduly burdensome as to “the

   location and identification of all Documents related to this topic.”

                  Defendants agree to designate a witness to testify regarding Topic No. 30.

    Topic No. 31.

                   The liquidity problem that Robinhood experienced during the Restriction Period,
   such as that referenced in the HFSC Report at 24, 30, 31, 54, 55, 61, 66, 68 and 69, including but
   not limited to, the location and identification of all Documents related to this topic.

    Response to Topic No. 31.

                  Defendants object to this Topic on the grounds that it is unreasonably cumulative

   or duplicative of Plaintiffs’ Request for Production No. 49. Defendants further object to this

   Topic on the grounds that it would be premature to offer 30(b)(6) testimony on this Topic, as

   Defendants are waiting on an agreement on search terms to begin their review. Defendants

   further object to this Topic on the grounds that it assumes disputed facts or purports to

   characterize facts, including that Defendants experienced a liquidity problem. Defendants

   further object to this Topic on the grounds to the extent Plaintiffs seek information regarding a

   third party’s characterization of relevant events.

                  Defendants agree to designate a witness to testify regarding Topic No. 31.

    Topic No. 32.

                   Robinhood’s belief that it would not be shut down or forced to liquidate its
   customers’ positions by the NSCC/DTCC because it was “to[o] big to fail,” as referenced in the
   HFSC Report at 65 (citing RH_HFSC_00007111), including but not limited to the location and
   identification of all documents related to this topic.

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    Response to Topic No. 32.

                   Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., a fact deposition of the individual

   who made the relevant statement). Defendants further object to this Topic on the grounds that it

   is unreasonably cumulative or duplicative of Plaintiffs’ Request for Production No. 50.

   Defendants further object to this Topic on the grounds that terms in this Topic such as “shut

   down or forced to liquidate” are vague and ambiguous. Defendants further object to this Topic

   on the grounds that it assumes disputed facts or purports to characterize facts, including that

   Robinhood “would not be shut down or forced to liquidate its customers’ positions.” Defendants

   further object to the Topic on the grounds that it improperly characterizes the source document.

   Defendants further object to this Topic on the grounds that it calls for improper 30(b)(6)

   testimony on legal theories, contentions or conclusions. Defendants further object to this Topic

   to the extent it seeks personal mental impressions or personal knowledge and not Defendants’

   position, beliefs and opinions or facts within the knowledge of the corporation.

                   Defendants agree to designate a witness to testify regarding Topic No. 32.

   Topic No. 33.

                   Robinhood’s predictions for its customers’ daily demand (i.e. likely purchase and
   sale quantities) for the Affected Stocks in the two weeks prior to, and during, the Restrictions
   Period, including but not limited to, the location and identification of all Documents related to
   this topic.

    Response to Topic No. 33.

                   Defendants further object to this Topic on the grounds that terms in this Topic such

   as “Robinhood’s predictions,” “likely purchase and sale quantities” and “Restrictions Period” are

   vague and ambiguous. Defendants further object to this Topic on the grounds that it is overbroad

   and unduly burdensome as to seeking information “in the two weeks prior to . . . the Restrictions

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   Period” and as to “the location and identification of all Documents related to this topic.”

   Defendants further object to this Topic on the grounds that it assumes disputed facts or purports

   to characterize facts, including that Defendants has “predictions for its customers’ daily demand.”

                  Defendants agree to designate a witness to testify regarding Topic No. 33.

    Topic No. 34.

                   Robinhood’s view that Robinhood’s systems were having trouble handling the
   volume of trades on its platform, e.g., “handling scale,” such as those referenced in the HFSC
   Report at pp. 23-25, 31, 36 and 57, and reasons why, including but not limited to the location
   and identification of all documents related to this topic.

    Response to Topic No. 34.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., document requests). Defendants

   further object to this Topic on the grounds that it is unreasonably cumulative or duplicative of

   Plaintiffs’ Request for Production No. 51. Defendants further object to this Topic on the

   grounds that it would be premature to offer 30(b)(6) testimony on this Topic, as Defendants are

   waiting on an agreement on search terms to begin their review. Defendants further object to this

   Topic on the grounds that terms in this Topic such as “Robinhood’s view,” “Robinhood’s

   systems,” “trouble handling the volume of trades,” “handling scale” and “reasons why” are

   vague and ambiguous. Defendants further object to this Topic on the grounds that it assumes

   disputed facts or purports to characterize facts, including the “view that Robinhood’s systems

   were having trouble.” Defendants further object to this Topic to the extent it seeks personal

   mental impressions or personal knowledge and not Defendants’ position, beliefs and opinions or

   facts within the knowledge of the corporation.

                  Defendants agree to designate a witness to testify regarding Topic No. 34.




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    Topic No. 35.

                  Robinhood’s awareness that imposing Restrictions on the Affected Stocks could
   cause a decline in the market price of the Affected Stocks, including but not limited to that
   referenced in the HFSC Report at 31 (citing RH_HFSC_00029118) (“us PCO will trigger a
   crash, I am certain”), including but not limited to the location and identification of all
   Documents related to this topic.

    Response to Topic No. 35.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., a fact deposition of the individual

   who made the relevant statement). Defendants further object to this Topic on the grounds that it

   is unreasonably cumulative or duplicative of Plaintiffs’ Request for Production No. 48.

   Defendants further object to this Topic on the grounds that terms in this Topic such as

   “awareness” are vague and ambiguous. Defendants further object to this Topic on the grounds

   that it is overbroad and unduly burdensome as to seeking information related to Defendants’

   “awareness . . . including but not limited to that referenced in the HFSC Report” and as to “the

   location and identification of all Documents related to this topic.” Defendants further object to

   this Topic to the extent it seeks personal mental impressions or personal knowledge and not

   Defendants’ position, beliefs and opinions or facts within the knowledge of the corporation.

   Defendants further object to this Topic on the grounds to the extent Plaintiffs seek information

   regarding a third party’s characterization of relevant events. Defendants further object to this

   Topic on the grounds that it assumes disputed facts or purports to characterize facts, including

   that “Restrictions on the Affected Stocks could cause a decline in the market price of the

   Affected Stocks” and that Defendants were aware of the same. Defendants further object to this

   Topic on the grounds that it calls for improper 30(b)(6) testimony on legal theories, contentions

   or conclusions.

                     Defendants agree to designate a witness to testify regarding Topic No. 35.
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    Topic No. 36.

                   Robinhood’s consideration of, and its decision to, limit in any way the number or
   pace of new account sign-ups during the Relevant Period, and the reasons therefor such as those
   referenced in the HFSC Report at 31, 56, and 58, including but not limited to the location and
   identification of all documents related to this topic.

    Response to Topic No. 36.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories, fact depositions or

   document requests). Defendants further object to this Topic on the grounds that it is

   unreasonably cumulative or duplicative of Plaintiffs’ Request for Production No. 32.

   Defendants further object to this Topic on the grounds that terms in this Topic such as “new

   account sign-ups” and “consideration of, and its decision to” are vague and ambiguous.

   Defendants will construe the term “new account sign-ups” to mean new accounts opened in the

   prior 24 hours during the Relevant Period. Defendants further object to this Topic to the extent

   Plaintiffs seek information regarding a third party’s characterization of relevant events.

   Defendants further object to this Topic on the grounds that it assumes disputed facts or purports

   to characterize facts, including that Defendants considered and decided to “limit in any way the

   number or pace of new account sign-ups.” Defendants further object to this Topic on the

   grounds that it is overbroad and unduly burdensome as to the discussion of “limit[ing] in any

   way the number or pace of new account sign-ups” and as to “the location and identification of all

   Documents related to this topic.”

                  Defendants agree to designate a witness to testify regarding Topic No. 36.

    Topic No. 37.

                   The number of total Robinhood accounts, daily new Robinhood account sign-ups,
   and the total dollar amount held in Robinhood accounts on a daily basis during the Relevant
   Period, including but not limited to the location and identification of all Documents related to
   this topic.
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    Response to Topic No. 37.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories or document

   requests). Defendants further object to this Topic on the grounds that it is unreasonably

   cumulative or duplicative of Plaintiffs’ Request for Production Nos. 33-35. Defendants further

   object to this Topic on the grounds that terms in this Topic such as “new account sign-ups” are

   vague and ambiguous. Defendants will construe the term “new account sign-ups” to mean new

   accounts opened in the prior 24 hours during the Relevant Period. Defendants further object to

   this Topic on the grounds that it is overbroad and unduly burdensome as to “the location and

   identification of all Documents related to this topic.” Defendants further object to this Topic on

   the grounds that it seeks information that would require an impossible, impracticable, or

   unreasonable amount of preparation or memorization of information to permit any witness or

   group of witnesses to be able to address comprehensively.

                  Defendants are willing to provide a response to an interrogatory seeking this

   information.

    Topic No. 38.

                 The volume and type of trading (buys, sells, options, stocks) in the Affected
   Stocks by new accounts in the period, including but not limited to the location and identification
   of all Documents related to this topic.

    Response to Topic No. 38.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories or document

   requests). Defendants further object to this Topic on the grounds that it is unreasonably

   cumulative or duplicative of Plaintiffs’ Request for Production Nos. 34-35. Defendants further

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   object to this Topic on the grounds that terms in this Topic such as “new accounts in the period”

   are vague and ambiguous. Defendants further object to this Topic on the grounds that it is

   overbroad and unduly burdensome as to the lack of a time limitation because the term “the

   period” is vague and as to “the location and identification of all Documents related to this topic.”

   Defendants further object to this Topic on the grounds that it seeks information that would

   require an impossible, impracticable, or unreasonable amount of preparation or memorization of

   information to permit any witness or group of witnesses to be able to address comprehensively.

                  Defendants are willing to provide a response to an interrogatory seeking this

   information.

    Topic No. 39.

                  The amount and the changes in total daily volume of trading in Robinhood
   accounts in the stock and options of the Affected Stocks during the Relevant Period, including
   but not limited to, the location and identification of Documents related to this topic.

    Response to Topic No. 39.

                    Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories or document

   requests). Defendants further object to this Topic on the grounds that it is unreasonably

   cumulative or duplicative of Plaintiffs’ Request for Production Nos. 34-35 and Plaintiffs’

   Interrogatory No. 1. Defendants further object to this Topic on the grounds that it is overbroad

   and unduly burdensome as to “the location and identification of all Documents related to this

   topic.” Defendants further object to this Topic on the grounds that it seeks information that

   would require an impossible, impracticable, or unreasonable amount of preparation or

   memorization of information to permit any witness or group of witnesses to be able to address

   comprehensively.

                    Defendants are willing to provide a response to an interrogatory seeking this
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   information.

    Topic No. 40.

                   Robinhood’s efforts to raise capital from investors or any other source of funding
   during the Relevant Period, including but not limited to the reasons for Robinhood raising
   capital, the search for and identification of investors, negotiations, and Robinhood’s
   representations of the reasons for the capital infusion, and the terms and nature of the
   transactions by which Robinhood raised additional capital during the Relevant Period, including
   but not limited to the location and identification of all Documents related to this topic.

    Response to Topic No. 40.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories, fact depositions or

   document requests). Defendants further object to this Topic on the grounds that it is

   unreasonably cumulative or duplicative of Plaintiffs’ Request for Production No. 38.

   Defendants further object to this Topic on the grounds that terms in this Topic such as “efforts to

   raise capital” and “any other source of funding” are vague and ambiguous. Defendants further

   object to this Topic on the grounds that it is overbroad and unduly burdensome as to covering all

   potential aspects of fundraising and for seeking “the location and identification of all Documents

   related to this topic.” Defendants further object to this Topic on the grounds that it seeks

   information neither relevant to the claims or defense of the parties nor proportionate to the needs

   of the case, including “the search for and identification of investors[ and] negotiations.”

   Defendants further object to this Notice to the extent it seeks information protected from

   disclosure by the attorney-client privilege, the work-produce doctrine or any other applicable

   privileges or immunities.

                  Defendants agree to designate a witness to testify regarding Topic No. 40.

    Topic No. 41.

                 The impact of the Meme Stock Market Event on Robinhood’s efforts to pursue
   and complete an initial public offering, including but not limited to the location and
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   identification of all documents related to this topic.

    Response to Topic No. 41.

                  Defendants object to this Topic on the grounds that terms in this Topic such as

   “impact” and “efforts to pursue and complete an initial public offering” are vague and

   ambiguous. Defendants further object to this Topic on the grounds that it assumes disputed facts

   or purports to characterize facts, including that the Meme Stock Market Event impacted

   Defendants’ IPO efforts. Defendants further object to this Topic on the grounds that it does not

   specify the information sought with reasonable particularity. Defendants further object to this

   Topic on the grounds that it is overbroad and unduly burdensome as to “the location and

   identification of all Documents related to this topic.”

                  Defendants agree to designate a witness to testify regarding Topic No. 41.

    Topic No. 42.

                    Robinhood’s insurance policies covering (i) securities fraud claims, and (ii) errors
   and omissions, including but not limited to the location and identification of all Documents
   related to this topic.

    Response to Topic No. 42.

                    Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories or document

   requests). Defendants further object to this Topic on the grounds that it is unreasonably

   cumulative or duplicative of Plaintiffs’ Request for Production No. 70, in response to which

   Defendants have answered Plaintiffs’ questions at the meet and confer on December 15, 2022

   and in their January 5, 2023 letter. Defendants repeat that there is no litigation insurance.

   Defendants further object to this Topic on the grounds that terms in this Topic such as “errors”

   are vague and ambiguous. Defendants further object to this Topic on the grounds that it is

   overbroad and unduly burdensome as to “the location and identification of all Documents related
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   to this topic.”

                     Defendants agree to designate a witness to testify regarding Topic No. 42.

    Topic No. 43.

                  Robinhood’s policies governing its employees’ trading of stocks and options
   during the Relevant Period, including but not limited to the location and identification of all
   Documents related to this topic.

    Response to Topic No. 43.

                     Defendants object to this Topic on the grounds that terms in this Topic such as

   “policies governing” are vague and ambiguous.

                     Defendants agree to designate a witness to testify regarding Topic No. 43.

    Topic No. 44.

                   How Robinhood uses Workday, its human resources management system,
   including its capabilities, the information available on it, and what types of information related
   to individual custodians and key employees are available on it.

    Response to Topic No. 44.

                     Defendants object to this Topic on the grounds that terms in this Topic such as

   “types of information,” “key employees” and “capabilities” are vague and ambiguous.

   Defendants further object to this Topic on the grounds that it is overbroad and unduly

   burdensome as to “information available” on Workday with no restriction. Defendants further

   object to this Topic on the grounds that it seeks information neither relevant to the claims or

   defense of the parties nor proportionate to the needs of the case, including Defendants “human

   resources management system.” Defendants previously informed Plaintiffs in their March 1,

   2023 letter that Defendants do not use Workday to track workflow process or make individual

   work assignments.

                     Defendants agree to designate a witness to testify regarding Topic No. 44.



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    Topic No. 45.

                   The trading Restrictions Robinhood imposed during the Meme Stock Market
   Event. In particular:
            (a)     a description Looker’s capabilities;
            (b)      a description of Looker’s functions;
            (c)     The tasks Robinhood uses Looker to perform;
            (d)     how Robinhood uses Looker in its business;
            (e)     The type of data does Robinhood use Looker to analyze;
            (f)     The type of data analyses Looker performs for Robinhood; and;
            (g)     The final product or output Looker produces;
            (h)     Whether and how Looker allows Robinhood to access its data lake;
            (i)     Whether and how Looker can be used to create, identify or obtain any of the
                    documents Plaintiffs have requested from Robinhood in their various First Set of
                    Requests for Production.

    Response to Topic No. 45.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories). Defendants further

   object to this Topic on the grounds that terms in this Topic such as “capabilities,” “functions,”

   “type of data,” “use” and “the final product or output Looker produces” are vague and

   ambiguous. Defendants further object to this Topic on the grounds that it seeks information

   neither relevant to the claims or defense of the parties nor proportionate to the needs of the case,

   including Defendants’ internal “data analytics platform.” Defendants previously informed

   Plaintiffs in their March 1, 2023 letter that Looker can be programmed with Structured Query

   Language (“SQL”) queries and submits them against databases and that Looker is capable of

   generating reports. Defendants further object to this Topic to the extent subsection (i) suggests

   Defendants are under any obligation to generate documents or information that does not already

   exist in Defendants’ custody or control to satisfy Plaintiffs’ document requests. Defendants

   further object to this Topic on the grounds that it is overbroad and unduly burdensome as to

   evaluating how Looker could be “used” in connection with Plaintiffs’ 88 document requests.


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   Defendants further object to this Topic on the grounds that it seeks information that would

   require an impossible, impracticable, or unreasonable amount of preparation or memorization of

   information to permit any witness or group of witnesses to be able to address comprehensively.

                  Defendants agree to designate a witness to testify regarding Topic No. 45.

    Topic No. 46.

                   The nature, purpose, participants, dates, times, and outcome(s) of the scaling
   meeting(s) described in RHMDL0049839, including but not limited to the location and
   identification of all other Documents related to this topic.

    Response to Topic No. 46.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories, document requests

   or a fact deposition of the individual who made the relevant statement). Defendants further

   object to this Topic on the grounds that terms in this Topic such as “nature,” “purpose” and

   “outcome” are vague and ambiguous. Defendants further object to this Topic on the grounds

   that it is overbroad and unduly burdensome as to “the location and identification of all

   Documents related to this topic.”

                  Defendants agree to designate a witness to testify regarding Topic No. 46.

    Topic No. 47.

                   The existence, nature and use of any algorithm or optimization program
   (“Algorithm”) Robinhood used to identify the stocks that are driving the greatest fees as
   referenced in RHMDL 0072580, including but not limited to: (i) when it was developed; (ii)
   when Robinhood first started using it; (iii) whether Robinhood used it during the Relevant
   Period; (iv) the reasons it was developed; (v) the uses it was put to; (vi) the identify of all
   persons at Robinhood that analyzed the output of the Algorithm; (vii) the decisions the
   Algorithm supported; (viii) the decisions the Algorithm affected; (ix) the Identity of all persons
   at Robinhood that used any aspect of the Algorithm to make decisions during the Relevant
   Period; (x) the identity and location of all documents that relate to this topic.




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    Response to Topic No. 47.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories, document requests

   or a fact deposition of the individual who made the relevant statement). Defendants further

   object to this Topic on the grounds that terms in this Topic such as “existence, nature and use,”

   “any algorithm or optimization program,” “driving the greatest fees,” “decisions the Algorithm

   supported,” “affected” and “used any aspect of the Algorithm” are vague and ambiguous.

   Defendants further object to this Topic on the grounds that it is overbroad and unduly

   burdensome as to the “identif[ication] of all persons . . . that used any aspect of the Algorithm.”

   Defendants further object to this Topic on the grounds that it assumes disputed facts or purports

   to characterize facts, including that any such algorithm exists as described. Defendants further

   object to the Topic on the grounds that it improperly characterizes facts and the source

   document. Defendants further object to this Topic on the grounds that it is overbroad and

   unduly burdensome as to “the location and identification of all Documents related to this topic.”

                  Defendants agree to designate a witness to testify regarding Topic No. 47.

    Topic No. 48.

                   The process Robinhood undertook to monitor Reddit, WallStreetBets, StockTwits
   or other social media channels for potential increases in demand for specific stocks, which
   stocks it monitored and identified, and in what channels during the Relevant Period, including
   but not limited to which stocks it monitored, the reasons therefore, how it selected such stocks to
   monitor, and how Robinhood used the information found on these social media channels to
   determine in which stocks to consider restricting. The location and identification of all
   Documents related to this topic.

    Response to Topic No. 48.

                  Defendants object to this Topic on the grounds that terms in this Topic such as

   “monitor,” “potential increases in demand for specific stocks” and “other social media channels”

   are vague and ambiguous. Defendants further object to this Topic on the grounds that it assumes
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   disputed facts or purports to characterize facts, including that Defendants monitored social

   media, that Defendants monitored for increases in demand of certain stocks and that Defendants

   “used the information found on these social media channels to determine in which stocks to

   consider restricting.” Defendants further object to this Topic on the grounds that it is overbroad

   and unduly burdensome as to “the location and identification of all Documents related to this

   topic.”

                  Defendants agree to designate a witness to testify regarding Topic No. 48.

    Topic No. 49.

                   The nature, extent and methods by which Robinhood engaged in advertising or
   postings of any kind on social media linked to WallStreetBets or other social media channels to
   induce traders to open accounts on Robinhood during or prior to the Class Period. The location
   and identification of all Documents related to this topic.

    Response to Topic No. 49.

                  Defendants object to this Topic on the grounds that terms in this Topic such as

   “nature, extent and methods,” “advertising or postings of any kind,” “social media linked to

   WallStreetBets” and “other social media channels” are vague and ambiguous. Defendants

   further object to this Topic on the grounds that it is overbroad and unduly burdensome as to

   “postings of any kind.” Defendants further object to this Topic on the grounds that it

   characterizes “advertising or postings” as “induc[ing] traders to open accounts on Robinhood.”

   Defendants further object to this Topic on the grounds that it assumes disputed facts or purports

   to characterize facts, including that Defendants advertised or posted on social media and that

   Defendants attempted to induce traders to open Robinhood accounts. Defendants further object

   to this Topic on the grounds that it is overbroad and unduly burdensome as to “the location and

   identification of all Documents related to this topic.”

                  Defendants agree to designate a witness to testify regarding Topic No. 49.

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    Topic No. 50.

                  When, why and the methods by which Robinhood removed their advertising or
   other postings at any time during or prior to the class period. The location and identification of
   all Documents related to this topic.

    Response to Topic No. 50.

                  Defendants object to this Topic on the grounds that terms in this Topic such as

   “methods,” “advertising or other postings” and “prior to the class period” are vague and

   ambiguous. Defendants further object to this Topic on the grounds that it assumes disputed facts

   or purports to characterize facts, including that Defendants advertised or posted on social media

   and that Defendants removed any advertising or postings. Defendants further object to this

   Topic on the grounds that it is overbroad and unduly burdensome as to “the location and

   identification of all Documents related to this topic.”

                  Defendants agree to designate a witness to testify regarding Topic No. 50.

    Topic No. 51.

                  Whether Robinhood possessed any internal company estimates of the impact of
   changes in Robinhood customer demand for certain stocks on those stocks’ prices and what
   these estimates were for the nine Affected Stocks during the Relevant Period. If so, the amount
   and other specifics of these estimates each day and what were the bases for the estimates. The
   location and identification of all Documents related to this topic.

    Response to Topic No. 51.

                    Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories or document

   requests). Defendants further object to this Topic on the grounds that it is unreasonably

   cumulative or duplicative of Topic 10(h). Defendants further object to this Topic on the

   grounds that terms in this Topic such as “internal company estimates of the impact of

   changes,” “Robinhood customer demand for certain stocks” and “amount and other specifics

   of these estimates” are vague and ambiguous. Defendants further object to this Topic on the
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   grounds that it is overbroad and unduly burdensome as to “the location and identification of all

   Documents related to this topic.”

                    Defendants agree to designate a witness to testify regarding Topic No. 51.

    Topic No. 52.

                  Robinhood’s beliefs, including any discussions, as to whether a decrease in
   demand to purchase any of the nine Affected Stocks or an increase in selling pressure for the
   nine Affected Stocks would lead to lower share prices for such stocks during the Relevant
   Period.

    Response to Topic No. 52.

                    Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories or document

   requests). Defendants further object to this Topic on the grounds that it is unreasonably

   cumulative or duplicative of Topic 10(h). Defendants further object to this Topic on the grounds

   that terms in this Topic such as “beliefs,” “any discussions” and “selling pressure” are vague and

   ambiguous. Defendants further object to this Topic on the grounds that it is the subject of expert

   testimony. Defendants further object to this Topic to the extent it calls for testimony about a

   hypothetical. Defendants further object to this Topic on the grounds that it is overbroad and

   unduly burdensome as to “any discussions.” Defendants further object to this Topic on the

   grounds that it calls for improper 30(b)(6) testimony on legal theories, contentions or

   conclusions.

    Topic No. 53.

                  The number of in the money options that Robinhood closed out early from
   January 27 to February 4, 2021, including but not limited to the location and identity of
   relevant documents and including a thorough explanation of the meaning, source and
   completeness of RHMDL00004341 and RHMDL00004343.




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    Response to Topic No. 53

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories or document

   requests). Defendants further object to this Topic on the grounds that it is unreasonably

   cumulative or duplicative of Plaintiffs’ Request for Production Nos. 19-23. Defendants further

   object to this Topic on the grounds that terms in this Topic such as “thorough explanation” and

   “afforded an opportunity” are vague and ambiguous. Defendants further object to this Topic on

   the grounds that it is overbroad and unduly burdensome as to “the location and identity of relevant

   documents and including a thorough explanation of the meaning, source and completeness.”

                  Defendants are willing to provide a response to an interrogatory seeking this

   information.

    Topic No. 54.

                  Robinhood’s policies for selling out or liquidating positions based on margin calls
   during the Relevant Period, including any changes in such policies and the reasons for such
   changes including but not limited to the location and identification of all other documents related
   to this topic.

    Response to Topic No. 54.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories or document

   requests). Defendants further object to this Topic on the grounds that information about

   “changes in such policies” is not limited to a particular timeframe.

                  Defendants agree to designate a witness to testify regarding Topic No. 54.

    Topic No. 55.

                 The identity of customers who were and were not given notice of margin calls
   from January 27, 2021 to February 5, 2021 for the nine Affected Stocks and whether they were
   afforded an opportunity to meet such margin calls and the notice and time provided and whether
                                                   47
Case 1:21-md-02989-CMA Document 586-4 Entered on FLSD Docket 08/07/2023 Page 49 of
                                      54


   the notice and time provided for the nine Affected Stocks differed from margin calls for other
   stocks, including but not limited to the location and identification of all other Documents related
   to this topic.

    Response to Topic No. 55.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories or document

   requests). Defendants further object to this Topic on the grounds that terms in this Topic such as

   “notice” and “afforded an opportunity” are vague and ambiguous. Defendants further object to

   this Topic on the grounds that it is overbroad and unduly burdensome as to “the location and

   identification of all Documents related to this topic.” Defendants further object to this Topic on

   the grounds that it seeks personally identifiable information (“PII”). Defendants further object

   to this Topic on the grounds that it seeks information that would require an impossible,

   impracticable, or unreasonable amount of preparation or memorization of information to permit

   any witness or group of witnesses to be able to address comprehensively. Defendants further

   object to this Topic on the grounds that it assumes disputed facts or purports to characterize

   facts, including that Defendants did not provide notice to certain customers regarding margin

   calls.

    Topic No. 56.

                    All rules and requirements that Robinhood had for customers seeking to move
   their assets from Robinhood to other brokerage firms from January 27, 2021 to February 5, 2021,
   including but not limited to the existence or non-existence of any rules that customers must sell
   their securities before moving their assets to a new brokerage account, and including but not
   limited to the location and identification of all Documents related to this topic.

    Response to Topic No. 56.

                  Defendants object to this Topic on the grounds that terms in this Topic such as

   “rules” and “requirements” are vague and ambiguous. Defendants further object to this Topic on

   the grounds that it is overbroad and unduly burdensome as to “the location and identification of
                                                   48
Case 1:21-md-02989-CMA Document 586-4 Entered on FLSD Docket 08/07/2023 Page 50 of
                                      54


   all Documents related to this topic” and to the extent Plaintiffs seek proof of the “non-existence

   of any rules.” Defendants further object to this Topic on the grounds that it calls for improper

   30(b)(6) testimony on legal theories, contentions or conclusions concerning regulatory

   requirements. Defendants further object to this Topic on the grounds that it seeks information

   that would require an impossible, impracticable, or unreasonable amount of preparation or

   memorization of information to permit any witness or group of witnesses to be able to address

   comprehensively.

                  Defendants agree to designate a witness to testify regarding Topic No. 56.

    Topic No. 57.

                   The nature and extent of any proceedings, suits, investigations, regulatory actions
   of any nature, and enforcement proceedings commenced against Robinhood that are in any way
   related to the Meme Stock Market Event, including but not limited to, the location and
   identification of all Documents related to this topic.

    Response to Topic No. 57.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories). Defendants further

   object to this Topic on the grounds that it is unreasonably cumulative or duplicative of Plaintiffs’

   Request for Production Nos. 4-6. Defendants further object to this Topic on the grounds that it

   is overbroad and unduly burdensome as to “in any way related to the Meme Stock Market

   Event,” “regulatory actions of any nature” and “any proceeding.” Defendants further object to

   this Topic on the grounds that it seeks information neither relevant to the claims or defense of

   the parties nor proportionate to the needs of the case; Plaintiffs do not articulate how other

   actions or proceedings are relevant to the claims or defenses of the parties in this Action.

   Defendants further object to this Topic to the extent it seeks information protected from

   disclosure by the attorney-client privilege, the work-produce doctrine or any other applicable

                                                    49
Case 1:21-md-02989-CMA Document 586-4 Entered on FLSD Docket 08/07/2023 Page 51 of
                                      54


   privileges or immunities.

                  Defendants are willing to provide a response to an interrogatory seeking this

   information.

    Topic No. 58.

                   Robinhood’s organizational structure and the management structure of the
   Company’s business functions, for each of the entities that are Robinhood in this Action during
   the Relevant Period, including the names of the heads of relevant departments and their
   reporting structure and the financial and reporting interaction and interrelationships between and
   amongst the Robinhood’s parent holding company and its subsidiaries, including whether
   officers of one entity are officers or others and whether officers of one entity that are not officers
   of another entity are allowed to give orders to employees of entities for which such officer does
   not work.

    Response to Topic No. 58.

                  Defendants object to this Topic on the grounds that it seeks information more

   easily available through other, less burdensome means (e.g., interrogatories or document

   requests). Defendants further object to this Topic on the grounds that it is unreasonably

   cumulative or duplicative of Plaintiffs’ Request for Production No. 8. Defendants further object

   to this Topic on the grounds that terms in this Topic such as “business functions,” “relevant

   departments” and “give orders” are vague and ambiguous. Defendants further object to this

   Topic on the grounds that it fails to describe the information sought with reasonable particularity

   such that Defendants could prepare a witness to testify about the entire organizational and

   management structure. Defendants further object to this Topic on the grounds that it seeks

   information neither relevant to the claims or defense of the parties nor proportionate to the needs

   of the case, as to Defendants’ organizational and management structure. Defendants further

   object to this Topic on the grounds that it seeks information that would require an impossible,

   impracticable, or unreasonable amount of preparation or memorization of information to permit

   any witness or group of witnesses to be able to address comprehensively.

                                                     50
Case 1:21-md-02989-CMA Document 586-4 Entered on FLSD Docket 08/07/2023 Page 52 of
                                      54


                  Defendants agree to designate a witness to testify regarding Topic No. 58.

    Topic No. 59.

                   The identities, by job title or description and the specific roles and
   responsibilities, of any persons who were responsible for or may possess information concerning
   any of the topics in the preceding paragraphs.

    Response to Topic No. 59.

                  Defendants object to this Topic on the grounds that it is an impermissible catch-

   all topic. Defendants further object to this Topic on the grounds that it is overbroad and unduly

   burdensome to the extent it requires Defendants to identify all individuals who “may possess

   information concerning any of” the 58 preceding Topics.




                                                   51
Case 1:21-md-02989-CMA Document 586-4 Entered on FLSD Docket 08/07/2023 Page 53 of
                                      54



   Dated: June 2, 2023


                                     Respectfully submitted,


                                                  /s/ Antony Ryan
                                     CRAVATH, SWAINE & MOORE LLP
                                     Antony L. Ryan
                                     Kevin J. Orsini
                                     Brittany L. Sukiennik
                                     825 Eighth Avenue
                                     New York, NY 10019
                                     Telephone: (212) 474-1000
                                     aryan@cravath.com
                                     korsini@cravath.com
                                     bsukiennik@cravath.com

                                     HUNTON ANDREWS KURTH LLP
                                     Samuel A. Danon (FBN 892671)
                                     María Castellanos Alvarado (FBN 116545)
                                     333 S.E. 2 Avenue, Suite 2400
                                     Miami, FL 33131
                                     Telephone: (305) 810-2500
                                     Facsimile:(305) 810-2460
                                     sdanon@HuntonAK.com
                                     mcastellanos@HuntonAK.com


                                     Attorneys for Robinhood Robinhood Markets, Inc.,
                                     Robinhood Financial LLC and Robinhood
                                     Securities, LLC




                                        52
Case 1:21-md-02989-CMA Document 586-4 Entered on FLSD Docket 08/07/2023 Page 54 of
                                      54



                                    CERTIFICATE OF SERVICE

          I hereby certify that on June 2, 2023, I caused copies of the foregoing Responses and

   Objections to Plaintiffs’ Rule 30(b)(6) Deposition Topics to be served via electronic mail on the

   following parties:

          Laurence M. Rosen
          Robin Bronzaft Howald
          Michael A. Cohen
          Phillip C. Kim
          Jon Stern
          Brent J. LaPointe
          THE ROSEN LAW FIRM, P.A.
          275 Madison Avenue 40th Floor
          New York, New York 10016
          Tel: (212) 686-1060
          Fax: (212) 202-3827
          lrosen@rosenlegal.com
          rhowald@rosenlegal.com
          mcohen@rosenlegal.com
          pkim@rosenlegal.com
          jstern@rosenlegal.com
          blapointe@rosenlegal.com
          Counsel for Plaintiffs

          I certify under penalty of perjury under the laws of the United States of America that the

   foregoing is true and correct.

                                                              /s/ Kathleen Young
                                                             Kathleen Young


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