Case 8:20-cv-00513-CEH-SPF Document 1 Filed 03/04/20 Page 1 of 9 PageID 1
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`UNITED STATES DISTRICT COURT
`UNITED STATES DISTRICT COURT
`MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION
`MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION
`Civil Action No. _______________
`Civil Action No.
`
`TRAVIS TAAFFE,
`TRAVIS TAAFFE,
`
`Plaintiff,
`Plaintiff,
`
`CLASS ACTION COMPLAINT
`CLASS ACTION COMPLAINT
`
`DEMAND FOR JURY TRIAL
`DEMAND FOR JURY TRIAL
`
`___________________________________ X
`X
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`ROBINHOOD MARKETS, INC.,
`ROBINHOOD MARKETS, INC.,
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`ROBINHOOD FINANCIAL LLC, and
`ROBINHOOD FINANCIAL LLC, and
`ROBINHOOD SECURITIES, LLC, :
`ROBINHOOD SECURITIES, LLC,
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`:
`:
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`___________________________________ X
`x
`
`vs.
`vs.
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`
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`Defendants.
`Defendants.
`
`
`
`COME NOW Plaintiff, TRAVIS TAAFFE on behalf of himself and the Class of others
`COME NOW Plaintiff, TRAVIS TAAFFE on behalf of himself and the Class of others
`
`similarly situated as defined herein, and hereby files this Class Action Complaint against
`similarly situated as defined herein, and hereby files this Class Action Complaint against
`
`Defendants Robinhood Markets, Inc., Robinhood Financial LLC and Robinhood Securities,
`Defendants Robinhood Markets, Inc., Robinhood Financial LLC and Robinhood Securities,
`
`LLC, (collectively “Robinhood”) and states as follows:
`LLC, (collectively "Robinhood") and states as follows:
`
`JURY DEMAND
`JURY DEMAND
`
`Plaintiff hereby demands a trial by jury.
`Plaintiff hereby demands a trial by jury.
`
`I. PARTIES
`I. PARTIES
`
`1.
`1.
`
`Plaintiff Travis Taaffe is an adult citizen of Florida and resides in Sarasota
`Plaintiff Travis Taaffe is an adult citizen of Florida and resides in Sarasota
`
`County, Florida.
`County, Florida.
`
`2.
`2.
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`At all times material hereto, Plaintiff Travis Taaffe acquired the Robinhood
`At all times material hereto, Plaintiff Travis Taaffe acquired the Robinhood
`
`mobile phone application and utilized the same to acquire, trade and hold securities in Florida.
`mobile phone application and utilized the same to acquire, trade and hold securities in Florida.
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`Case 8:20-cv-00513-CEH-SPF Document 1 Filed 03/04/20 Page 2 of 9 PageID 2
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`3.
`3.
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`Defendant Robinhood Markets, Inc. is a financial services holding company
`Defendant Robinhood Markets, Inc. is a financial services holding company
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`incorporated in Delaware, whose subsidiaries provide financial and investment services via an
`incorporated in Delaware, whose subsidiaries provide financial and investment services via an
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`internet/cloud-based platform that is also available on mobile phones. Its subsidiary, Defendant
`internet/cloud-based platform that is also available on mobile phones. Its subsidiary, Defendant
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`Robinhood Financial LLC, is a full service securities firm engaged in the retail sale of securities
`Robinhood Financial LLC, is a full service securities firm engaged in the retail sale of securities
`
`and various other financial products. Its subsidiary, Defendant Robinhood Securities, LLC, is a
`and various other financial products. Its subsidiary, Defendant Robinhood Securities, LLC, is a
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`full service securities firm engaged in the retail sale of securities and various other financial
`full service securities firm engaged in the retail sale of securities and various other financial
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`products. Defendants Robinhood Markets, Inc., Robinhood Financial LLC, and Defendant
`products. Defendants Robinhood Markets, Inc., Robinhood Financial LLC, and Defendant
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`Robinhood Securities, LLC, provide internet and mobile phone based securities sales and
`Robinhood Securities, LLC, provide internet and mobile phone based securities sales and
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`services to approximately 10 million customers and/or users.
`services to approximately 10 million customers and/or users.
`
`4.
`4.
`
`On Monday March 2, 2020, the Dow Jones Industrial Average rose over
`On Monday March 2, 2020, the Dow Jones Industrial Average rose over
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`1,294 points, the S&P 500 rose 136 points, and the Nasdaq rose 384 points in what was the
`1,294 points, the S&P 500 rose 136 points, and the Nasdaq rose 384 points in what was the
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`biggest ever point gain in a single day.
`biggest ever point gain in a single day.
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`5.
`5.
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`On this same day, Robinhood’s entire trading platform was completely
`On this same day, Robinhood's entire trading platform was completely
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`inaccessible and unavailable to all of its customers and/or users. Thus, customers and/or users
`inaccessible and unavailable to all of its customers and/or users. Thus, customers and/or users
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`were not even able to access their cash, securities and/or other property kept on the Robinhood
`were not even able to access their cash, securities and/or other property kept on the Robinhood
`
`platform, let alone use Robinhood’s services to buy, sell or trade securities.
`platform, let alone use Robinhood's services to buy, sell or trade securities.
`
`II. JURISDICTION AND VENUE
`II. JURISDICTION AND VENUE
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`6.
`6.
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`This Court has original jurisdiction over this matter under the Class Action
`This Court has original jurisdiction over this matter under the Class Action
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`Fairness Act and 28 U.S.C. §1332. This is a putative class action in which: (1) there are
`Fairness Act and 28 U.S.C. §1332. This is a putative class action in which: (1) there are
`
`1 million or more members in the Class; 2) at least some members of the proposed class have
`1 million or more members in the Class; 2) at least some members of the proposed class have
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`different citizenship from at least one Defendant and the claims of the proposed class members
`different citizenship from at least one Defendant and the claims of the proposed class members
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`exceed $5,000,000.00 in the aggregate.
`exceed $5,000,000.00 in the aggregate.
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`Case 8:20-cv-00513-CEH-SPF Document 1 Filed 03/04/20 Page 3 of 9 PageID 3
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`7.
`7.
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`Venue is appropriate as: Robinhood Securities, LLC, has a headquarters in this
`Venue is appropriate as: Robinhood Securities, LLC, has a headquarters in this
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`district; Defendants conduct business in this district; a substantial part of the events and
`district; Defendants conduct business in this district; a substantial part of the events and
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`omissions that give rise to the claims alleged herein occurred in this district; and brokerage
`omissions that give rise to the claims alleged herein occurred in this district; and brokerage
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`records related to sale of securities and its books and records are maintained and administered in
`records related to sale of securities and its books and records are maintained and administered in
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`this district.
`this district.
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`III. FACTUAL ALLEGATIONS
`III. FACTUAL ALLEGATIONS
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`A.
`A.
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`Robinhood’s Securities Brokerage Services Were Unavailable To
`Robinhood's Securities Brokerage Services Were Unavailable To
`All Customers And/Or Users On March 2, 2020
`All Customers And/Or Users On March 2, 2020
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`8.
`8.
`
`Robinhood provides “commission-free” trades in stocks, funds and options using
`Robinhood provides "commission-free" trades in stocks, funds and options using
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`an internet/cloud-based platform for individual customers and/or users.
`an internet/cloud-based platform for individual customers and/or users.
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`9.
`9.
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`It offers these services to its customers and/or users through its mobile phone
`It offers these services to its customers and/or users through its mobile phone
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`based application as an alternative to the traditional financial services provided in person, over
`based application as an alternative to the traditional financial services provided in person, over
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`the telephone or on the internet.
`the telephone or on the internet.
`
`10.
`10.
`
`On Monday March 2, 2020, the Dow Jones Industrial Average rose over
`On Monday March 2, 2020, the Dow Jones Industrial Average rose over
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`1,294 points, the S&P 500 rose 136 points, and the Nasdaq rose 384 points in what was the
`1,294 points, the S&P 500 rose 136 points, and the Nasdaq rose 384 points in what was the
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`biggest ever point gain in a single day for all three stock market indices.
`biggest ever point gain in a single day for all three stock market indices.
`
`11.
`11.
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`In a March 2, 2020 email to its customers and/or users Robinhood stated, “This
`In a March 2, 2020 email to its customers and/or users Robinhood stated, "This
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`morning, starting at 9:33 AM ET, we started experiencing downtime across our platform. These
`morning, starting at 9:33 AM ET, we started experiencing downtime across our platform. These
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`issues are affecting functionality on Robinhood, including your ability to trade.”
`issues are affecting functionality on Robinhood, including your ability to trade."
`
`12.
`12.
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`It was not until 2:19 am on March 3, 2020 that Robinhood announced publically
`It was not until 2:19 am on March 3, 2020 that Robinhood announced publically
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`on its Twitter account that, “Robinhood is currently back up and running. We’re testing through
`on its Twitter account that, "Robinhood is currently back up and running. We're testing through
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`the night, and you may observe some downtime as we prepare for tomorrow.”
`the night, and you may observe some downtime as we prepare for tomorrow."
`
`13.
`13.
`
`Robinhood’s customers and/or users were not able to access Robinhood’s
`Robinhood's customers and/or users were not able to access Robinhood's
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`platform to engage in any trading activity, to access their funds kept on the platform, to transfer
`platform to engage in any trading activity, to access their funds kept on the platform, to transfer
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`funds onto the system or to transfer funds off the system for all but 3 minutes of New York Stock
`funds onto the system or to transfer funds off the system for all but 3 minutes of New York Stock
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`Exchange trading hours, 9:30am until 4:00pm on March 2. There were additional outages of
`Exchange trading hours, 9:30am until 4:00pm on March 2. There were additional outages of
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`Robinhood’s platform on March 3, 2020.
`Robinhood's platform on March 3, 2020.
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`14.
`14.
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`On March 3, 2020, in a blog post on Robinhood’s website, Robinhood’s Co-
`On March 3, 2020, in a blog post on Robinhood's website, Robinhood's Co-
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`CEOs admitted liability and that it was Robinhood itself which was solely responsible for their
`CEOs admitted liability and that it was Robinhood itself which was solely responsible for their
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`complete failure; “We now understand the cause of the outage was stress on our infrastructure—
`complete failure; "We now understand the cause of the outage was stress on our infrastructure—
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`which struggled with unprecedented load. That in turn led to a “thundering herd” effect—
`which struggled with unprecedented load. That in turn led to a "thundering herd" effect—
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`triggering a failure of our DNS system.” As such, Robinhood admits that the platform outages
`triggering a failure of our DNS system." As such, Robinhood admits that the platform outages
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`were due to its own failures and expressly waive any defense related to failures of the platform
`were due to its own failures and expressly waive any defense related to failures of the platform
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`being out Robinhood’s control.
`being out Robinhood's control.
`
`IV. CLASS ACTION ALLEGATIONS
`IV. CLASS ACTION ALLEGATIONS
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`15.
`15.
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`Plaintiff brings this action pursuant to Rule 23 of the Federal Rules of Civil
`Plaintiff brings this action pursuant to Rule 23 of the Federal Rules of Civil
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`Procedure on behalf of the following Class:
`Procedure on behalf of the following Class:
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`Customers and/or users of Robinhood in the United States who lost the ability to
`Customers and/or users of Robinhood in the United States who lost the ability to
`access their Robinhood brokerage accounts to effectuate any transaction therein
`access their Robinhood brokerage accounts to effectuate any transaction therein
`on March 2, 2020.
`on March 2, 2020.
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`16.
`16.
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`Plaintiff is a member of the Class he seeks to represent. Plaintiff acquired the
`Plaintiff is a member of the Class he seeks to represent. Plaintiff acquired the
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`Robinhood mobile phone application and utilized the same to acquire, trade and hold securities.
`Robinhood mobile phone application and utilized the same to acquire, trade and hold securities.
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`Plaintiff was unable to access the mobile phone application to take any action, engage in any
`Plaintiff was unable to access the mobile phone application to take any action, engage in any
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`trading activity, to access his funds kept on the platform, to transfer funds onto the system or to
`trading activity, to access his funds kept on the platform, to transfer funds onto the system or to
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`transfer funds off the system for all but 3 minutes of New York Stock Exchange trading hours,
`transfer funds off the system for all but 3 minutes of New York Stock Exchange trading hours,
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`9:30am until 4:00pm on March 2.
`9:30am until 4:00pm on March 2.
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`17.
`17.
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`The proposed Class is so numerous that joinder of all members is impracticable.
`The proposed Class is so numerous that joinder of all members is impracticable.
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`There are approximately 10 million customers and/or users of Robinhood, all of which are
`There are approximately 10 million customers and/or users of Robinhood, all of which are
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`potential members of the Class.
`potential members of the Class.
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`18.
`18.
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`There are questions of law and fact common to the Class, and those questions
`There are questions of law and fact common to the Class, and those questions
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`predominate over individual questions. All customers and/or users of Robinhood were affected
`predominate over individual questions. All customers and/or users of Robinhood were affected
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`by the March 2, 2020 platform outage.
`by the March 2, 2020 platform outage.
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`19.
`19.
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`20.
`20.
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`21.
`21.
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`The claims alleged by Plaintiff are typical of the claims of the Class.
`The claims alleged by Plaintiff are typical of the claims of the Class.
`
`Plaintiff will fairly and adequately represent and protect the interests of the Class.
`Plaintiff will fairly and adequately represent and protect the interests of the Class.
`
`The questions of law and fact common to the members of the Class predominate
`The questions of law and fact common to the members of the Class predominate
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`over any questions affecting only individual members, and a class action is superior to other
`over any questions affecting only individual members, and a class action is superior to other
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`available methods for the fair and efficient adjudication of the controversy.
`available methods for the fair and efficient adjudication of the controversy.
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`V. CAUSES OF ACTION
`V. CAUSES OF ACTION
`
`COUNT I
`COUNT I
`BREACH OF CONTRACT
`BREACH OF CONTRACT
`
`22.
`22.
`
`23.
`23.
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`Plaintiff and class members adopt and incorporate paragraphs 1 through 21 in full.
`Plaintiff and class members adopt and incorporate paragraphs 1 through 21 in full.
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`Defendants forced Plaintiff and class members to consent to the Robinhood
`Defendants forced Plaintiff and class members to consent to the Robinhood
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`Financial LLC & Robinhood Securities, LLC Customer Agreement1 in order to gain access to
`Financial LLC & Robinhood Securities, LLC Customer Agreement) in order to gain access to
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`the Defendants’ trading platform. Attached as Exhibit A.
`the Defendants' trading platform. Attached as Exhibit A.
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`24.
`24.
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`Defendants breached their contractual duties to Plaintiff and class members by
`Defendants breached their contractual duties to Plaintiff and class members by
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`failing to provide a functioning platform for Plaintiff and class members to access their personal
`failing to provide a functioning platform for Plaintiff and class members to access their personal
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`funds, securities and/or other property.
`funds, securities and/or other property.
`
`1
` Plaintiff does not have access to an executed copy of same nor is he aware of the existence of one. Exhibit A is all
`1 Plaintiff does not have access to an executed copy of same nor is he aware of the existence of one. Exhibit A is all
`that is available and provided to Plaintiff.
`that is available and provided to Plaintiff.
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`25.
`Defendants’ breach also prevented Plaintiff and class members from executing
`25. Defendants' breach also prevented Plaintiff and class members from executing
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`market securities transactions on March 2 and March 3, 2020. This breach caused Plaintiff and
`market securities transactions on March 2 and March 3, 2020. This breach caused Plaintiff and
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`class members to miss out on some of the highest single-day market gains in recorded history.
`class members to miss out on some of the highest single-day market gains in recorded history.
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`26.
`26.
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`Plaintiff and class members have all been damaged in a similar manner due to
`Plaintiff and class members have all been damaged in a similar manner due to
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`Defendants breach of contract.
`Defendants breach of contract.
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`27.
`27.
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`Plaintiff requests relief as hereinafter described.
`Plaintiff requests relief as hereinafter described.
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`COUNT II
`COUNT II
`BREACH OF IMPLIED WARRANTY OF MERCHANTABILITY
`BREACH OF IMPLIED WARRANTY OF MERCHANTABILITY
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`28.
`28.
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`29.
`29.
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`Plaintiff and class members adopt and incorporate paragraphs 1 through 21 in full.
`Plaintiff and class members adopt and incorporate paragraphs 1 through 21 in full.
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`Defendants breached their implied warranty of merchantability by failing to
`Defendants breached their implied warranty of merchantability by failing to
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`provide a trading platform that is acceptable and reasonably fit for the ordinary purposes for
`provide a trading platform that is acceptable and reasonably fit for the ordinary purposes for
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`which it was being contracted, in this case, for including but not limited to: the purchase and sale
`which it was being contracted, in this case, for including but not limited to: the purchase and sale
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`of securities, transferring funds into Robinhood or transferring funds out of Robinhood.
`of securities, transferring funds into Robinhood or transferring funds out of Robinhood.
`
`30.
`30.
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` Defendants are merchants with respect to the kind of goods at issue, as
`Defendants are merchants with respect to the kind of goods at issue, as
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`Defendants are broker-dealers engaging in the securities markets.
`Defendants are broker-dealers engaging in the securities markets.
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`31.
`31.
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`Plaintiff and class members have all been damaged in a similar manner due to
`Plaintiff and class members have all been damaged in a similar manner due to
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`Defendants breach of implied warranty of merchantability.
`Defendants breach of implied warranty of merchantability.
`
`32.
`32.
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` Plaintiff requests relief as hereinafter described.
`Plaintiff requests relief as hereinafter described.
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`COUNT III
`COUNT III
`NEGLIGENCE
`NEGLIGENCE
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`33.
`33.
`
`34.
`34.
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`Plaintiff and class members adopt and incorporate paragraphs 1 through 21 in full.
`Plaintiff and class members adopt and incorporate paragraphs 1 through 21 in full.
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`Defendants owed a duty to Plaintiff and class members to exercise reasonable
`Defendants owed a duty to Plaintiff and class members to exercise reasonable
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`care in maintaining and supporting Defendants’ internet/cloud-based trading platform so that
`care in maintaining and supporting Defendants' internet/cloud-based trading platform so that
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`Plaintiff and class members would not be adversely affected by extended system
`Plaintiff and class members would not be adversely affected by extended system
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`failures/outages. This duty includes, inter alia, designing, maintaining, and testing Defendants’
`failures/outages. This duty includes, inter alia, designing, maintaining, and testing Defendants'
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`trading platform to ensure that the platform is adequately secured and protected from upticks in
`trading platform to ensure that the platform is adequately secured and protected from upticks in
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`customer trading volume and user engagement. Defendants had a duty to provide a system and
`customer trading volume and user engagement. Defendants had a duty to provide a system and
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`platform robust enough to handle all possible reasonable volumes of trading of securities by
`platform robust enough to handle all possible reasonable volumes of trading of securities by
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`customers and users and have a redundant/backup system to handle outages. Defendants’ duty
`customers and users and have a redundant/backup system to handle outages. Defendants' duty
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`further includes providing Plaintiff and class members with alternative forms of trading when
`further includes providing Plaintiff and class members with alternative forms of trading when
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`Defendants’ mobile trading application was inaccessible; for instance, providing its customers
`Defendants' mobile trading application was inaccessible; for instance, providing its customers
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`with a phone number to call in order to execute various trades or to have funds transferred.
`with a phone number to call in order to execute various trades or to have funds transferred.
`
`35.
`35.
`
`Defendants breached their duty to exercise reasonable care in safeguarding and
`Defendants breached their duty to exercise reasonable care in safeguarding and
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`protecting Plaintiff’s and other class members’ assets from the extended system failures
`protecting Plaintiffs and other class members' assets from the extended system failures
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`experienced on March 2, 2020 and March 3, 2020. Defendants further breached their duty by
`experienced on March 2, 2020 and March 3, 2020. Defendants further breached their duty by
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`failing to provide adequate support to the trading platform to ensure that it could continue to
`failing to provide adequate support to the trading platform to ensure that it could continue to
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`function during an uptick in trading volume and user engagement.
`function during an uptick in trading volume and user engagement.
`
`36.
`36.
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`Plaintiff and class members have all been damaged in a similar manner due to
`Plaintiff and class members have all been damaged in a similar manner due to
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`Defendants’ negligence.
`Defendants' negligence.
`
`37.
`Defendants’ negligence was the direct and proximate cause of the damages
`37. Defendants' negligence was the direct and proximate cause of the damages
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`suffered by Plaintiff and the other class members.
`suffered by Plaintiff and the other class members.
`
`PRAYER FOR RELIEF
`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiffs respectfully request that this Court find in favor of them and
`WHEREFORE, Plaintiffs respectfully request that this Court find in favor of them and
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`the Class of similarly situated individuals and against Defendants as follows:
`the Class of similarly situated individuals and against Defendants as follows:
`
`a.
`a.
`
`b.
`b.
`
`c.
`c.
`
`Certify this case as a class action;
`Certify this case as a class action;
`
`Designate Plaintiff as Class Representative;
`Designate Plaintiff as Class Representative;
`
`Designate Plaintiffs’ counsel of record as Class Counsel;
`Designate Plaintiffs' counsel of record as Class Counsel;
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`d.
`d.
`
`e.
`e.
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`Order appropriate equitable relief to remedy the inappropriate conduct;
`Order appropriate equitable relief to remedy the inappropriate conduct;
`
`Award Plaintiff and all others similarly situated the full value of all damages
`Award Plaintiff and all others similarly situated the full value of all damages
`
`sustained now or in the futures as a result of Defendants’ conduct;
`sustained now or in the futures as a result of Defendants' conduct;
`
`f.
`f.
`
`Award Plaintiff and all others similarly situated all damages, interest and
`Award Plaintiff and all others similarly situated all damages, interest and
`
`attorneys’ fees recoverable under applicable laws;
`attorneys' fees recoverable under applicable laws;
`
`g.
`g.
`
`Award Plaintiff and all others similarly situated punitive damages, compensatory
`Award Plaintiff and all others similarly situated punitive damages, compensatory
`
`and other damages;
`and other damages;
`
`h.
`h.
`
`Order injunctive relief including but not limited to an Order requiring that
`Order injunctive relief including but not limited to an Order requiring that
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`Defendants’ systems are capable of handling its customers’ and/or users’ securities transactions
`Defendants' systems are capable of handling its customers' and/or users' securities transactions
`
`even in a time of heavy trading volume, as well as requiring Defendants to implement adequate
`even in a time of heavy trading volume, as well as requiring Defendants to implement adequate
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`redundancy or backup processes to ensure that should a system outage occur there is another
`redundancy or backup processes to ensure that should a system outage occur there is another
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`avenue for customers and/or users to access, control and trade their cash, securities and/or other
`avenue for customers and/or users to access, control and trade their cash, securities and/or other
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`property.
`property.
`
`i.
`i.
`
`Award Plaintiff and all others similarly situated any and all other relief as this
`Award Plaintiff and all others similarly situated any and all other relief as this
`
`Court deems just and proper; and
`Court deems just and proper; and
`
`j.
`J.
`
`That this matter be tried by a jury.
`That this matter be tried by a jury.
`
`Dated: March 4, 2020
`Dated: March 4, 2020
`
`Respectfully submitted,
`Respectfully submitted,
`
`By: _/s/Michael S. Taaffe____
`By: /s/Michael S. Taaffe
`Michael S. Taaffe
`Michael S. Taaffe
`Florida State Bar No. 490318
`Florida State Bar No. 490318
`Michael D. Bressan
`Michael D. Bressan
`Florida State Bar No. 0011092
`Florida State Bar No. 0011092
`Jarrod J. Malone
`Jarrod J. Malone
`Florida State Bar No. 0010595
`Florida State Bar No. 0010595
`Shumaker, Loop & Kendrick, LLP
`Shumaker, Loop & Kendrick, LLP
`240 South Pineapple Ave., 10th Floor
`240 South Pineapple Ave., 10th Floor
`Sarasota, Florida 34236
`Sarasota, Florida 34236
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`Telephone: (941) 366-6660
`Telephone: (941) 366-6660
`Facsimile: (941) 366-3999
`Facsimile: (941) 366-3999
`E-Mail: mtaaffe@shumaker.com
`E-Mail: mtaaffe@shumaker.com
`E-Mail: mbressan@shumaker.com
`E-Mail: mbressan@shumaker.com
`E-Mail: jmalone@shumaker.com
`E-Mail: jmalone@shumaker.com
`Attorneys for Plaintiff
`Attorneys for Plaintiff
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