Case 4:20-cv-09328-YGR Document 1 Filed 12/23/20 Page 1 of 30
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`Tina Wolfson (SBN 174806)
`Robert Ahdoot (SBN 172098)
`Bradley K. King (SBN 274399)
`AHDOOT & WOLFSON, PC
`2600 West Olive Avenue, Suite 500
`Burbank, California 91505
`Tel: (310) 474-9111
`Fax: (310) 474-8585
`twolfson@ahdootwolfson.com
`rahdoot@ahdootwolfson.com
`bking@ahdootwolfson.com
`
`LIDDLE & DUBIN, P.C.
`Nicholas A. Coulson (PHV forthcoming)
`Matthew Z. Robb (PHV forthcoming)
`975 E. Jefferson Ave.
`Detroit, Michigan 48207
`Tel: 313-392-0015
`Fax: 313-392-0025
`ncoulson@ldclassaction.com
`mrobb@ldclassaction.com
`
`Attorneys for Plaintiff and the Putative Class
`
`
`
`ROBINHOOD FINANCIAL LLC, a Delaware
`LLC, and ROBINHOOD SECURITIES, LLC, a
`Delaware LLC,
`
`
`Defendants.
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`CLASS ACTION COMPLAINT AND JURY DEMAND; CASE NO. 3:20-CV-9328
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`JUSTIN WILLIAM LEMON, individually and
`on behalf of all others similarly situated,
`
` Plaintiff,
`
`
`v.
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`
`) Case No. 3:20-cv-9328
`)
`) CLASS ACTION COMPLAINT
`)
`) JURY TRIAL DEMANDED
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`Case 4:20-cv-09328-YGR Document 1 Filed 12/23/20 Page 2 of 30
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`INTRODUCTION
`1.
`Plaintiff Justin William Lemon (“Plaintiff”), by and through his counsel, files this Class
`Action Complaint against Robinhood Financial LLC (“Robinhood Financial”) and Robinhood
`Securities, LLC (“Robinhood Securities”) (collectively, “Defendants” or “Robinhood”) on behalf of
`himself and on behalf of a class of similarly situated individuals, and alleges, upon personal knowledge
`as to his own actions, and upon investigation of counsel as to all other matters, as follows:
`NATURE OF THE ACTION
`2.
`Robinhood, a multi-billion dollar mobile application and website investment service, has
`capitalized on a surge of first-time market investors by misleading and luring unsuspecting consumers
`to execute inferior market trades on the platform under the guise of “commission free” trading.
`3.
`Through a process of deceit and omission, Defendants misled consumers and failed to
`disclose that Robinhood’s business operations relied extensively upon “payment for order flow,” in
`which Defendants received payment from market makers in exchange for executing the service’s trades.
`4.
`These payments often came at the expense of the consumer. While Defendants promoted
`and advertised an easy-to-use “commission free” trading platform, Defendants profited extensively from
`unsuspecting consumers who executed trades on Defendants’ platform at inferior execution prices
`compared to what consumers would have received from Robinhood’s competitors. For larger value
`orders, this price differential often exceeded the commission its competitors would have charged. These
`inferior prices were caused in large part by the unusually high charges Robinhood required from
`principal trading firms for the opportunity to obtain Robinhood’s customer order flow.
`5.
`The principal trading firms/electronic market makers in turn passed these costs along to
`Robinhood’s clients on each trade through inferior execution quality—the price at which the requested
`market orders were executed.
`6.
`Effectively, Robinhood charged backdoor commission fees to each of its clients’ orders,
`while concealing and denying the payment for order flow scheme.
`7.
`To effectuate this scheme, Defendants published misleading statements and omissions in
`customer communications relating to the execution of trades and Robinhood’s revenue sources. For
`years, Robinhood’s retail communications to consumers omitted receipt of payment for order flow, even
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`though it was Robinhood’s single largest source of revenue.
`8.
`Robinhood failed to disclose and omitted information regarding this process in numerous
`ways, including instructing customer service representatives not to mention payment for order flow in
`response to questions about Robinhood’s sources of revenue and omitting it from its website’s FAQ
`section.
`9.
`As a broker-dealer that routed customer orders for execution, Robinhood had a duty of
`best execution to its clients, a duty to seek and obtain the best reasonably available terms for customers’
`orders. Robinhood knowingly violated its duty of best execution by charging unusually high payment
`for order flow rates to its vendors and failing to conduct adequate regular and rigorous reviews of the
`execution quality it was providing on customer orders.
`10.
`Plaintiff brings this action on behalf of himself and a class of similarly situated individuals
`who were victims of Defendants’ materially deceptive acts and omissions, relying upon Robinhood’s
`warranties, advertisements, and representations, as well as Robinhood’s duty of best execution in
`executing trades on consumer’s behalf.
`11.
`Defendants have quietly sought to force its customers to execute trades on Defendants’
`platform at inferior prices compared to what consumers would have received from Robinhood’s
`competitors, while profiting on the back end of those trades.
`12.
`Defendants uniform conduct is equally applicable to the class. Plaintiff brings this class
`action against Defendants for: (1) Violation of Section 10(b) of the Securities Exchange Act of 1934 and
`Rule 10b-5; (2) Violations of California Consumers Legal Remedies Act (“CLRA”), Civil Code § 1750,
`et seq.; (3) Violations of California Unfair Competition Law (“UCL”), Bus. & Prof. Code § 17200, et
`seq.; (4) Violations of California False Advertising Law (“FAL”), Bus. & Prof. Code § 17500, et seq.;
`(5) Negligent Misrepresentation; (6) Breach of Implied Covenant of Good Faith and Fair Dealing; and
`(7) Breach of Fiduciary Duty.
`13.
`Plaintiff seeks an order for relief including but not limited to the following: (1) requiring
`Defendants to pay damages and restitution to Plaintiff and the Class; and (2) enjoining Defendants from
`further legal violations through Robinhood’s payment for order flow collection scheme and requiring
`Defendants to publicly correct the false and misleading statements and omissions alleged herein.
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`JURISDICTION AND VENUE
`14.
`This Court has original jurisdiction pursuant to the Securities Exchange Act of 1934, 15
`U.S.C. § 78a, et seq. This Court also has Class Action Fairness Act (CAFA) jurisdiction pursuant to 28
`U.S.C. § 1332(d)(2)(a). CAFA jurisdiction is appropriate as this action’s amount in controversy,
`exclusive of interest and costs, exceeds the sum or value of $5,000,000 and is a class action in which
`there are numerous class members who are citizens of states different from Defendants.
`15.
`This Court has personal jurisdiction over Defendants because Defendants are citizens of
`California, conduct significant, substantial, and not-isolated business activities in California and a
`substantial portion of the acts complained of took place in California.
`16.
`Venue is proper in the Northern District of California because Defendants conduct
`business in this District and many of the events that gave rise to Plaintiff’s claims occurred in this
`District.
`
`PARTIES
`17.
`Plaintiff Justin William Lemon is an individual and citizen of New Hampshire.
`18.
`Defendant Robinhood Financial LLC is a Delaware LLC with its principal place of
`business located at 85 Willow Road, City of Menlo Park, County of San Mateo, State of California.
`19.
` Defendant Robinhood Securities, LLC is a Delaware LLC with its principal place of
`business located at 85 Willow Road, City of Menlo Park, County of San Mateo, State of California.
`FACTUAL ALLEGATIONS
`
`A.
`Background
`20.
`Robinhood offers self-directed securities brokerage services to customers by means of its
`website and smartphone applications. Robinhood is a Commission-registered broker-dealer and a
`member of Financial Industry Regulatory Authority (“FINRA”). Robinhood Financial acts as an
`introducing broker and has a clearing arrangement with Robinhood Securities. When customers open
`accounts with Robinhood, they enter into a customer agreement with Robinhood Financial and
`Robinhood Securities.
`21.
`Robinhood was founded in 2013 and began offering retail brokerage accounts to the
`general public in March 2015. Robinhood distinguished itself from other retail-oriented broker-dealers
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`by, among other things, allowing customers to place orders to buy and sell securities without paying a
`trading commission. It was this price-value proposition that allowed Robinhood to rapidly grow.
`22.
`By June 2019, Robinhood had 9 million approved customer accounts.
`B.
`Principal Trading Firms and Payment for Order Flow
`23.
`Rather than sending customer orders to buy or sell equity securities directly to national
`exchanges, Robinhood, like other retail broker-dealers, routed its orders to other broker-dealers (often
`referred to as “principal trading firms” or “electronic market makers”) to either execute those orders or
`route them to other market centers.
`24.
`Principal trading firms attempt to profit from executing large volumes of retail buy and
`sell orders either by taking the other side of customer orders and exiting the positions at a profit, which
`is also known as “internalization,” or by routing the orders to other market centers.
`25.
`Historically, market makers paid fees to regional intermediaries for their services in
`executing trades with other local firms on behalf of the market maker. In order to grow a guaranteed
`supply of liquidity in their markets, market makers began offering payments to not only the
`intermediaries, but also retail firms, including brokers, in exchange for the retail firms routing their
`orders to the market makers. This practice, which expanded from off-exchange securities (over-the-
`counter or “OTC” securities) to exchange-traded securities, came to be known as “payment for order
`flow.” Over time, different types of venues, including Electronic Communication Networks (“ECNs”)
`and exchanges, also began making payments for order flow.
`26.
`Principal trading firms offer incentives to retail broker-dealers to send them order flow.
`One such incentive is “payment for order flow,” which is defined in Rule 10b-10(d)(8) of the Exchange
`Act to include any monetary payment, service, property, or other benefit that results in remuneration,
`compensation, or consideration to a broker-dealer in return for the routing of customer orders.
`27.
`Since it began operating as a broker-dealer, Robinhood, like other retail broker-dealers,
`has received payment for order flow in exchange for routing its customer orders to principal trading
`firms.
`
`28.
`SEC rules permit the receipt of payment for order flow by broker-dealers as long as it
`does not interfere with their efforts to obtain best execution, and as long as the routing of that order flow,
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`as well as a description of all terms of any such arrangements that may influence the broker-dealer’s
`order routing decision, are disclosed in quarterly reports filed pursuant to 17 CFR § 242.606 (Disclosure
`of order routing information, “SEC Rule 606”).
`29.
`Another incentive that principal trading firms may provide to retail broker-dealers is
`“price improvement” on customer executions. Price improvement occurs when a customer order
`receives an execution at a price that is superior to the best available quotation then appearing on the
`public quotation feed, that is, by executing a “buy” order at a price lower than the lowest prevailing
`offer or executing a “sell” order at a price higher than the highest prevailing bid.
`30.
`Price improvement creates a direct financial benefit for the customer, since the customer
`receives a better price than he or she would have received had the order been executed at the national
`best bid and offer (“NBBO”) on the public quotation feed.
`31.
`In practice, most retail broker-dealers obtain price improvement on the vast majority of
`customer orders that they send to principal trading firms.
`C.
`The Duty of Best Execution
`32.
`Broker-dealers such as Robinhood owe their customers a duty of “best execution.” Best
`execution requires that a broker-dealer endeavor to execute customer orders on the most favorable terms
`reasonably available in the market under the circumstances. This includes taking into account price,
`order size, trading characteristics of the security, as well as the potential for price improvement and other
`factors. See Newton v. Merrill, Lynch, Pierce, Fenner & Smith, 135 F.3d 266, 270 & n.2 (3d Cir. 1998);
`Marc N. Geman, Securities Exchange Act Release No. 43963 (Feb. 14, 2001) (Commission opinion).
`33.
`Although a broker-dealer is not required to examine every customer order individually
`for compliance with its duty of best execution, it must undertake regular and rigorous reviews of the
`quality of its customer order executions. See Payment for Order Flow, Securities and Exchange
`Commission Final Rule Release, Exchange Act Release No. 34902, 59 Fed. Reg. 55006, at 55009 (Oct.
`27, 1994) (“Payment for Order Flow Release”).
`34.
`The duty of best execution derives from, among other sources, the common law agency
`duty of loyalty, which obligates an agent to act exclusively in the principal’s best interest. Payment for
`order flow has the potential to create a conflict of interest between the broker-dealer and its customer
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`because payment for order flow is a benefit that goes to the broker-dealer itself, whereas other incentives
`that may be obtained for routing order flow, such as price improvement, benefit the broker-dealer’s
`customers. A broker-dealer must not allow payment for order flow to interfere with its efforts to obtain
`best execution. See Payment for Order Flow Release, at 55009 & n.28.
`35.
`In the context of transacting in securities, best execution requires that, when conducting
`a transaction on behalf of a client, a broker seek the terms most favorable to the client that can possibly
`be obtained given the present circumstances.
`36. When securities are traded in different venues, best execution requires that, absent
`instruction otherwise from the client, a broker-dealer ensure that the client’s order be routed to the best
`possible venue. A broker achieves best execution when it endeavors to obtain the best price available,
`execute the transaction in the shortest possible time frame, maximize the likelihood that the transaction
`is executed in its entirety, and, where possible, seek “price improvement”—the execution of a trade at a
`price better than the best current public quote.
`37.
`NASD Rule 2320 provided that Robinhood, as a broker-dealer, would “use reasonable
`diligence to ascertain the best market for the subject security and buy or sell in such market so that the
`resultant price to the customer is as favorable as possible under prevailing market conditions.”
`38.
`The factors to be considered in determining reasonable diligence were “(A) the character
`of the market for the security, e.g., price, volatility, relative liquidity, and pressure on available
`communications; (B) the size and type of transaction; (C) the number of markets checked; (D)
`accessibility of the quotation; and (E) the terms and conditions of the order which result in the
`transaction, as communicated to” Robinhood.
`39.
`Financial Industry Regulatory Authority (“FINRA”) Rule 5310, which superseded NASD
`Rule 2320 on May 31, 2012, incorporates all of that Rule’s provisions concerning a broker-dealer’s duty
`of best execution.
`D.
`Robinhood’s Initial Public Messaging Concerning Payment for Order Flow
`40.
`In 2014, prior to its public launch, Robinhood published an FAQ page on its website
`providing information about the company and its anticipated brokerage operations. The first version of
`the FAQ disclosed that Robinhood anticipated receiving payment for order flow in its answer to the
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`question “How does Robinhood make money?”
`41.
`Also in 2014, a best-selling author published a book that chronicled various aspects of
`the electronic securities trading industry and portrayed payment for order flow as a controversial
`practice.1
`42.
`Several news organizations also published articles discussing payment for order flow and
`other issues concerning electronic trading venues.2
`43.
`Senior Robinhood personnel were aware of these publications and the ensuing
`controversy regarding payment for order flow and its association with principal trading firms (which
`were also sometimes referred to as “high frequency trading firms”). They became concerned that if the
`public associated Robinhood with payment for order flow and high frequency trading firms, it could be
`viewed as controversial by Robinhood’s customers.
`44.
`In light of these concerns, in December 2014, Robinhood removed the reference to
`payment for order flow from its answer to the “How does Robinhood make money” FAQ and created a
`new FAQ page that specifically discussed payment for order flow.
`45.
`This new FAQ page stated that the payment for order flow revenue Robinhood received
`at the time was “indirect” and “negligible.” It also stated that if payment for order flow ever became a
`direct or significant source of revenue, Robinhood would inform customers of those facts on the “How
`does Robinhood make money” FAQ page.
`46.
`In the first quarter of 2015, Robinhood launched its trading platform to the public.
`Although the company’s overall revenue was modest in 2015 through mid-2016, during that time
`payment for order flow comprised more than 80% of the company’s revenue.
`47.
`These payments received for order flow were directly related to client orders and
`constituted a significant amount of the company’s revenue. Yet, Robinhood concealed these facts from
`its clients.
`
`
`1 https://www.pbs.org/newshour/show/flash-boys-investigates-high-frequency-traders-anticipate-wall-
`streets-next-move-faster (last visited December 21, 2020).
`2 https://www.ft.com/content/97810c5e-fd1c-11e3-8ca9-00144feab7de (last visited December 21,
`2020).
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`E.
`
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`Robinhood Received Unusually High Payment for Order Flow Rates and Failed to
`Conduct Rigorous Reviews of its Execution Quality
`
`48.
`Initially, Robinhood relied on another broker-dealer to provide both clearing and order
`execution services for Robinhood customer orders. That broker-dealer routed Robinhood customer
`orders to principal trading firms, received payment for order flow in return, and shared a portion of that
`payment for order flow with Robinhood.
`49.
`During the first half of 2016, Robinhood decided to start routing customer orders directly
`to principal trading firms and cease relying on the other broker-dealer for order execution routing
`services. By doing so, Robinhood could earn additional payment for order flow revenue.
`50.
`In or around May 2016, Robinhood began negotiations with a number of principal trading
`firms about potentially routing Robinhood customer orders to those entities.
`51.
`During those negotiations, certain principal trading firms told Robinhood that there was
`a trade-off between payment for order flow on the one hand and price improvement on the other: If
`Robinhood negotiated for higher payment for order flow revenue, according to the principal trading
`firms, there would be less money available for the principal trading firms to provide price improvement
`to Robinhood’s customers.
`52.
`At least one principal trading firm communicated to Robinhood that large retail broker-
`dealers that receive payment for order flow typically receive four times as much price improvement for
`customers as they do payment for order flow for themselves—an 80/20 split of the value between price
`improvement and payment for order flow.
`53.
`Robinhood negotiated a payment for order flow rate that was substantially and unusually
`higher than the rate the principal trading firms paid to other retail broker-dealers—which resulted in
`approximately a 20/80 split of the value between price improvement and payment for order flow.
`54.
`Robinhood explicitly agreed to accept less price improvement for its customers than what
`the principal trading firms were offering, in exchange for receiving a higher rate of payment for order
`flow for itself. However, Robinhood did not disclose this fact to its clients.
`55.
`In September 2016, Robinhood began routing customer orders directly and solely to
`principal trading firms. Around the same time, Robinhood formed a “Best Execution Committee” to
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`monitor the speed and the prices at which the principal trading firms were executing Robinhood customer
`orders. The Committee met at least once per month and included Robinhood’s General Counsel. From
`October 2016 through at least June 2019, the Committee observed that Robinhood was not obtaining
`much price improvement on its customer orders in equity securities, particularly on orders of 100 shares
`or more.
`56. Meanwhile, in 2017, Robinhood developed a proprietary routing algorithm, known as a
`smart order router, designed to make the principal trading firms with which Robinhood had payment for
`order flow arrangements compete for order flow by routing customer orders to the principal trading firm
`that had provided the most price improvement for that stock over the prior 30 days. However, the smart
`order router did not address Robinhood’s high payment for order flow rates or any potential execution
`prices that may be available at venues that did not agree to pay those rates. Even with its “smart” order
`router, Robinhood customer orders received poor execution quality.
`57.
`Although Robinhood was on notice that its high payment for order flow rates could lead
`to less price improvement, the Best Execution Committee did not conduct adequate, regular, and rigorous
`reviews to ensure that Robinhood was satisfying its best execution obligations.
`58.
`The Committee took no steps to determine whether Robinhood’s payment for order flow
`rates were having a negative impact on the execution prices that Robinhood’s customers received. Until
`October 2018, the Committee did not consider how Robinhood’s price improvement statistics compared
`to those of other retail broker-dealers, or to the retail order execution market generally.
`59.
`In mid-2017, when one of the principal trading firms to which Robinhood routed order
`flow told Robinhood it would no longer agree to pay Robinhood’s unusually high payment for order
`flow rates, but would pay a lower payment for order flow rate, Robinhood stopped routing customer
`orders to that principal trading firm.
`60. When certain Robinhood personnel began comparing the firm’s order execution quality
`to competitors in October 2018, they learned that for most execution quality metrics, including the
`percentage of orders receiving price improvement, Robinhood’s execution quality was worse.
`61.
`By March 2019, Robinhood had conducted a more extensive internal analysis, which
`showed that its execution quality and price improvement metrics were substantially worse than other
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`retail broker-dealers in many respects, including the percentage of orders that received price
`improvement and the amount of price improvement, measured on a per order, per share, and per dollar
`traded basis. Senior Robinhood personnel were aware of this analysis.
`62.
`However, Robinhood’s Best Execution Committee did not take appropriate steps to
`assess whether, in light of this information, Robinhood was complying with its duty to seek best
`execution of customer orders. Robinhood’s failure from October 2016 through June 2019 to conduct
`adequate regular and rigorous reviews that involved benchmarking its execution quality against
`competitor broker-dealers to determine whether it was obtaining the best terms reasonably available for
`customer orders, violated the firm’s duty of best execution.
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`F.
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`Robinhood Misleadingly Omitted Payment for Order Flow From Descriptions of
`Its Revenue Sources
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`63.
`By the end of 2016, Robinhood was generating a significant amount of revenue, the
`majority of which its controlling officers knew continued to come from payment for order flow.
`However, contrary to what the company had said in the payment for order flow FAQ, Robinhood did
`not disclose the new payment for order flow arrangements in its answer to the “How Robinhood Makes
`Money” FAQ on its website. Instead, at some point during 2016, Robinhood deleted the payment for
`order flow FAQ altogether.
`64.
`Robinhood kept no records showing when the payment for order flow FAQ was deleted,
`why it was deleted, or who was responsible for approving its removal.
`65.
`Between late 2016 and September 2018, Robinhood continued to grow rapidly. Although
`payment for order flow remained the company’s largest revenue source throughout this period,
`Robinhood did not include payment for order flow as a revenue source in its answer to the “How
`Robinhood Makes Money” FAQ on its website.
`66.
`The company failed to update the FAQ to include payment for order flow despite the fact
`that, in 2016 and 2017, the company did update the FAQ to include two other, smaller revenue sources:
`subscription-based memberships and interest on securities lending. The version of the “How Robinhood
`Makes Money” FAQ page that was posted on Robinhood’s website from approximately April 2017
`through September 2018 stated:
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`67.
`Robinhood kept incomplete records of its updates to the “How Robinhood Makes
`Money” FAQ page, including incomplete records of who was responsible for approving updates to that
`page.
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`68.
`The “How Robinhood Makes Money” FAQ was featured in certain of Robinhood’s
`customer communications. From at least February 22, 2016 to October 26, 2017 Robinhood displayed a
`link to the “How Robinhood Makes Money” FAQ on the home page of its website:
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`69. Moreover, Robinhood instructed customer service representatives to direct customers to
`the “How Robinhood Makes Money” FAQ page or use the language of the misleading FAQ answer
`when responding to general questions about how Robinhood made money. Thus, in response to inquiries
`from its customers between 2015 and August 2018 about how Robinhood made money—approximately
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`150 inquiries in total—Robinhood’s customer service representatives did not identify payment for order
`flow as one of the company’s revenue sources.
`70.
`Training documents for customer service representatives in early 2018 explicitly
`instructed them to “avoid” talking about payment for order flow and stated that it was “incorrect” to
`identify payment for order flow in response to the question how Robinhood makes money.
`71.
`Throughout this period, Robinhood disclosed some information about its receipt of
`payment for order flow as required in SEC-mandated reports pursuant to Rule 606. The company
`included these reports on the “Disclosure Library” page on its website that included a number of other
`legally-mandated disclosures. However, the company did not feature the “Disclosure Library” or the
`reports contained in that library prominently in its communication strategy, like it did with the “How
`Robinhood Makes Money” FAQ page.
`72.
`Robinhood’s customer agreements and trade confirmations stated only vaguely that
`Robinhood “may” receive payment for order flow.
`G.
`Robinhood Falsely Claimed That Its Execution Quality Matches or Beats That of
`Its Competitors
`73.
`In response to media reports in September and October 2018 about Robinhood’s payment
`for order flow rates, Robinhood added payment for order flow to the list of revenue sources appearing
`on the “How Robinhood Makes Money” FAQ page.
`74.
`But on October 12, 2018, it also published a new FAQ page that discussed payment for
`order flow and Robinhood’s order execution quality. The new FAQ page stated that Robinhood’s
`“execution quality and speed matches or beats what’s found at other major brokerages.” It also cited one
`statistic related to execution speed and one statistic related to the percentage of orders for S&P 500 stocks
`executed within the NBBO.
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`75.
`However, the internal analyses referenced in the paragraphs above that Robinhood
`conducted in October 2018 and March 2019 showed that Robinhood’s execution quality was worse than
`that of other large retail broker-dealers in many respects. In particular, in October 2018, when certain
`Robinhood employees began gathering data to compare Robinhood’s execution quality metrics to those
`of its competitors, other Robinhood personnel remarked that most of Robinhood’s metrics were worse
`and discussed the execution quality metrics with certain senior Robinhood personnel.
`76.
`A more extensive analysis Robinhood conducted in March 2019 stated that “[n]o matter
`how we cut the data, our % orders receiving price improvement lags behind that of other retail brokerages
`by a wide margin.”
`77.
`Robinhood further found that the amount of price improvement obtained for Robinhood
`customers was far lower than at competing broker-dealers, measured on a per order, per share, and per
`dollar traded basis. Senior Robinhood personnel were aware of this analysis.
`78.
`For most orders of more than 100 shares, the analysis concluded that Robinhood
`customers would be better off trading at another broker-dealer