Exhibit B — Case 1:21-md-02989-CMA (Document 571-3)

Summary

Exhibit B (Document 571-3) in Case 1:21-md-02989-CMA, entered on the FLSD docket 06/09/2023, is an email dated Friday, May 5, 2023 from Jeff Klafter, addressed to Larry, with the subject RH Securities Fraud Options Claims. The email states that a securities action was filed on behalf of a class of option holders as of the close of trading on January 27, 2021, and that Lead Plaintiff motions in that action are not due until June 9, 2023. It notes a Court-ordered mediation on May 17, 2023 in a case limited to stockholders and asks for confirmation that the options claims of the alleged class will not be settled or compromised, or else appropriate relief will be sought from the Court. The email is signed Jeffrey A. Klafter of Klafter Lesser LLP, Rye Brook, NY.

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Case 1:21-md-02989-CMA Document 571-3 Entered on FLSD Docket 06/09/2023 Page 1 of 3

EXHIBIT B
Case 1:21-md-02989-CMA Document 571-3 Entered on FLSD Docket 06/09/2023 Page 2 of 3
Friday, June 9, 2023 at 11:46:17 Eastern Daylight Time

Subject: RH Securities Fraud Options Claims
Date: Friday, May 5, 2023 at 5:01:53 PM Eastern Daylight Time
From: Jeff Klafter

To: lrosen@rosenlegal.com
Cc: maurice @pessahgroup.com, Stuart Chelin
Larry,

As you are no doubt aware, we filed a securities action on behalf of a class of option holders
who held options in certain affected securities as of the close of trading on January 27, 2021.
The putative options class sold their options, or had to let them expire, at a loss. Lead Plaintiff
motions in our action are not due until June 9, 2023.

You are due to participate in a Court-ordered mediation on May 17, 2023. The case you have
prosecuted is limited to only stockholders as of the close of trading on January 27, 2021. This
has been consistent across the PSLRA notice you published, your Amended Complaint and
the motion for class certification you filed last week.

As we are pursuing claims on behalf of a different class which was harmed by the same
underlying conduct which damaged your class, we are writing to obtain confirmation from you
that you will not seek to settle or compromise the options claims of the members of our
alleged class. If you do intend to seek a settlement or compromise on behalf of option-
holders, or for whatever reason are unable to provide the confirmation we are requesting, we
will seek appropriate relief from the Court.

We hope to be appointed lead counsel for the options class, and, if you have not settled your
stockholder claims by then, we would like to explore working in tandem with you to obtain an
appropriate settlement from Robinhood covering both the stockholder and option holder

claims.

Your prompt response to this email would be appreciated. Should you wish to hold a
conference call with me and my co-counsels, please let us know.

Jeffrey A. Klafter
KLAFTER LESSER LLP

Two International Drive, Suite 350
Rye Brook, NY 10573

(914) 934-9200 x 301

Fax: (914) 934-9220

The information in this transmittal may be legally privileged, confidential, and/or otherwise protected
by law from disclosure, and is intended only for the recipient(s) listed above. If you are neither the
intended recipient(s) nor a person responsible for the delivery of this transmittal to the intended
recipient(s), you are hereby notified that any distribution or copying of this transmittal is prohibited. If
you have received this transmittal in error, please notify Klafter Lesser LLP immediately at (914) 934-
9200 or by return e-mail and take the steps necessary to delete it completely from your computer
system. Thank you.

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Case 1:21-md-02989-CMA Document 571-3 Entered on FLSD Docket 06/09/2023 Page 3 of 3

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gov.uscourts.flsd.590042.571.3.pdf

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05c43ac28dc5d00c61ec4579fa03dee161db911bfdb3ff14c04701f1cc0e68d5

Our copy

gov.uscourts.flsd.590042.571.3.pdf

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