Case 1:21-cv-21294-CMA Document 1 Entered on FLSD Docket 01/29/2021 Page 1 of 13
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`'21
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`CV167
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`BLM
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`Case 1:21-cv-21294-CMA Document1 Entered on FLSD Docket 01/29/2021 Page 2 of 13
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`PARTIES
`
`Plaintiff Aaron Kolysko wasandis a citizen of the State of California.
`
`Timothy A. Nordeen was andis a citizen of the State of California and lives in the
`County of San Diego
`
`Defendant Robinhood Financial LLC is a Delaware corporation with its principal place of
`business at 85 Willow Road, Menlo Park, California 94025. It is a wholly-owned
`subsidiary of Robinhood Markets, Inc. Robinhood Financial LLCis registered as a
`broker-dealer with the U.S. Securities & Exchange Commission ("SEC"), Defendant
`Robinhood Financial LLC acts as an introducing broker and has a clearing arrangement
`with its affiliate, Defendant Robinhood Securities, LLC.
`
`10.
`
`Defendant Robinhood Securities, LLC is a Delaware corporation with its principal place
`of business at 500 Colonial Center Parkway, Suite 100, Lake Mary, Florida 32746.It is a
`wholly-owned subsidiary of Defendant Robinhood Markets, Inc. Defendant Robinhood
`Securities, LLC is registered as a broker-dealer with the SEC. Defendant Robinhood
`Financial LLC acts as a clearing broker and clears trades introducedbyits affiliate,
`Defendant Robinhood Financial.
`
`11.
`
`Defendant Robinhood Markets, Inc. is a Delaware corporation with its principal place of
`business at 85 Willow Road, Menlo Park, California 94025. Defendant Robinhood
`Markets, Inc. is the corporate parent of Defendants Robinhood Financial LLC and
`Robinhood Securities, LLC. 7. The above-named corporate defendants herein referred to
`collectively as "Robinhood."
`
`JURISDICTION AND VENUE
`
`12.
`
`13.
`
`This Court has subject-matter jurisdiction over this action pursuant to 28 U.S.C. §
`1332(d)(2). The aggregate claims of all members of the proposed class and subclass(es)
`are in excess of $5 million, exclusive of interest and costs, and there are more than 100
`putative class members. Many membersof the proposed class are citizens of a state
`different from Defendant.
`
`Pursuant to 28 U.S.C. § 1391, this Court is the proper venue for this action because a
`substantial part of the events, omissions, and acts giving rise to the claims herein
`occurred in this District where Robinhood,distributed, marketed, advertised, and sold the
`trading services which are the subject of the present complaint. Finally, venue is
`appropriate in this District pursuant to 28 USC § 1391(b)(2) because a substantial part of
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`the acts and omissions that gave rise to this Complaint occurred or emanated from this
`District.
`
`14.
`
`This Court has personal jurisdiction over Robinhood becauseit is authorized to do
`business and does conduct business in California, and becauseit has specifically
`marketed, advertised, and made substantial sales in California, and has sufficient
`minimum contacts with this state and/or sufficiently avails itself of the markets of this
`state through its promotion, sales, and marketing within this state to render the exercise of
`jurisdiction by this Court permissible.
`
`FACTUAL ALLEGATIONS
`
`15.
`
`Robinhoodis an online brokerage firm. Its customers place securities trades through the
`firm's website by using a web-based application (or "app"). Robinhood permits customers
`to purchase and sell securities, including futures contracts.
`
`16.
`
`Robinhood has experienced significant growth as a relatively new online brokerage firm.
`In 2019, Robinhood raised $323 million in funding at a $7.6 billion valuation. The firm
`markets itself primarily to younger investors and claims over 10 million users of its
`trading app.
`
`17.
`
`Onor about March 23, 2016, Robinhood's official Twitter account stated: "Let the
`people trade.” They have since disregarded their mantra and have blocked access for
`millions of its customers to trade particular securities.
`
`18.
`
`On or around January 11, 2021, stocks in GameStop Corp. ("GME") beganto rise.
`
`19.
`
`At that time, Robinhoodallowed retail investors to trade GME on the open market.
`
`20.
`
`On or around January 11, 2021, stocks in Black Berry, LTD., ("BB") began torise.
`
`21.
`
`At that time, Robinhood allowedretail investors to trade BB on the open market.
`
`22.
`
`On or around January 11, 2021, stocks in AMC Entertainment Holdings, Inc. ("AMC")
`beganto rise.
`
`23.
`
`Atthat time, Robinhood allowedretail investors to trade AMC on the open market.
`
`24,
`
`On or around January 11, 2021, stocks in Nokia Oyj ("NOK") began to rise.
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`25,
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`At that time, Robinhood allowedretail investors to trade NOK onthe open market.
`
`26.
`
`On or around January 11, 2021, stocks in Naked Brand Group, LTD.,("NAKD") began to
`rise.
`
`27.
`
`At that time, Robinhood allowedretail investors to trade NAKD on the open market.
`
`28,
`
`On or about January 27, 2021, Robinhood, in order to slow the growth of GME and
`deprived their customers ofthe ability to use their service, abruptly, purposefully,
`willfully, and knowingly pulled GME from their app. Meaning,retail investors could no
`longer buy or even search for GME on Robinhood's app.
`
`29.
`
`On or about January 27, 2021, Robinhood, in order to slow the growth of BB and
`deprived their customers of the ability to use their service, abruptly, purposefully,
`willfully, and knowingly pulled BB from their app. Meaning,retail investors could no
`longer buy or even search for BB on Robinhood's app.
`
`30.
`
`On or about January 27, 2021, Robinhood, in order to slow the growth of AMC and
`deprived their customers of the ability to use their service, abruptly, purposefully,
`willfully, and knowingly pulled AMC from their app. Meaning,retail investors could no
`longer buy or even search for AMC on Robinhood's app.
`
`31.
`
`On or about January 27, 2021, Robinhood,in order to slow the growth of NOK and
`deprived their customers of the ability to use their service, abruptly, purposefully,
`willfully, and knowingly pulled NOK from their app. Meaning, retail investors could no
`longer buy or even search for NOK on Robinhood's app.
`
`32.
`
`On or about January 27, 2021, Robinhood, in order to slow the growth of NAKD and
`deprived their customers of the ability to use their service, abruptly, purposefully,
`willfully, and knowingly pulled NAKD from their app. Meaning,retail investors could no
`longer buy or even search for NAKD on Robinhood's app.
`
`33.
`
`Uponinformation and belief, Robinhood's actions were done purposefully and knowingly
`to manipulate the market for the benefit of people and financial intuitions who were not
`Robinhood's customers.
`
`34.
`
`Since pulling the stock from their app, GME prices have gone up, depriving investors of
`potential gains.
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`35.
`
`Since pulling the stock from their app, BB prices have gone up, depriving investors of
`potential gains.
`
`36.
`
`Since pulling the stock from their app, AMCprices have gone up, depriving investors of
`potential gains.
`
`37.
`
`Since pulling the stock from their app, NOK prices have gone up, depriving investors of
`potential gains.
`
`38.
`
`Since pulling the stock from their app, NAKD prices have goneup, depriving investors of
`potential gains.
`
`39,
`
`Additionally, in the event GME goes down, Robinhood has deprived investors of
`"shorting" GMEin the hopesthe price drops.
`
`40.
`
`Additionally, in the event BB goes down, Robinhood has deprived investors of "shorting"
`BB in the hopesthe price drops.
`
`41.
`
`Additionally, in the event AMC goes down, Robinhood has deprived investors of
`"shorting" AMCin the hopesthe price drops.
`
`42.
`
`Additionally, in the event NOK goes down, Robinhood has deprived investors of
`"shorting" NOKin the hopesthe price drops.
`
`43,
`
`Additionally, in the event NAKD goes down, Robinhood has deprived investors of
`"shorting" NAKD in the hopes the price drops.
`
`44,
`
`Robinhood has completely blocked retailer investors from purchasing GME, BB, AMC,
`NOK, NAKDfor no legitimate reason, thereby depriving retailer investors of the benefits
`of Robinhood's services.
`
`45.
`
`The Financial Industry Regulatory Authority ("FINRA"), which governs brokers like
`Robinhood, espouses rule 5310 regarding "Best Execution and Interpositioning." Rule
`5310.01 requires that Robinhood "must makeevery effort to execute a marketable
`customer orderthat it receives promptly and fully." By failing to respondatall to
`customers' placing timely trades—-and outright blocking customers from trading
`security—Robinhoodhas breached these, among other, obligations and causedits
`customers substantial losses due solely to its own negligence and failure to maintain
`adequate infrastructure.
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`46.
`
`Robinhoodcontinues to randomly pull other securities from its app for no legitimate
`reason.
`
`47,
`
`Uponinformation and belief, Robinhoodis pulling securities from its platform to slow
`growth and help benefit individuals and institutions who are not Robinhood customers
`and are instead institutional investors or potential investors in Robinhood.
`
`48,
`
`On the morning of January 28, 2021, Plaintiff Timothy A. Nordeen used his Robinhood
`app, searched for stocks including but not limited to GME, BB, AMC, NOK,and/or
`NAKD on Robinhood's app, and found the stocks unavailable. Although the listed stocks
`are publicly-traded companies available on all other platforms, the stock did not even
`appear.
`
`49.
`
`On the morning of January 28, 2021, Plaintiff Aaron Kolysko used his Robinhood app,
`searched for stocks, including but not limited to GME, BB, AMC, NOK,and/or NAKD
`on Robinhood's app, and found the stocks unavailable. Although the listed stocks are
`publicly traded companies available on all other platforms, the stocks did not even
`
`appear.
`
`50.
`
`Thus, Plaintiffs, like so many others, lost out on all earning opportunities.
`
`CLASS ACTION ALLEGATIONS
`
`51.
`
`Plaintiff brings claims pursuant to Federal Rule of Civil Procedure 23 on behalf of the
`following Class, as defined below: All Robinhood customers within the United States.
`
`52.
`
`Additionally, or in the alternative, Plaintiff brings claims pursuant to Federal Rule of
`Civil Procedure 23 on behalf of the following Subclass, as defined below: All Robinhood
`customers within the United States who were not able to execute trades on stocks
`including but not limited to GME, BB, AMC, NOK, NAKD, after Robinhood knowingly,
`willfully, and purposefully removed it completely from their platform.
`
`53.
`
`Excluded from the Class are the Robinhood entities and their current employees, counsel
`for either party, as well as the Court and its personnel presiding over this action.
`
`54.
`
`This action has been brought and may properly be maintained as a class action against
`Robinhood pursuant to the provisions of Federal Rule of Civil Procedure 23
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`35.
`
`Numerosity: The precise number of membersof the proposed Class is unknownto
`Plaintiff at this time, but, based on information and belief, Class members are so
`numerous that their individual joinder herein is impracticable. Based on information and
`belief and publicly available reports, Class members numberin the hundreds of
`thousands and up to ten million. Subclass membersare likely in the thousands. All Class
`and Subclass members may be notified of the pendency ofthis action by reference to
`Robinhood's records or by other alternative means.
`
`56.
`
`Commonality: Numerous questions of law or fact are commonto the claims of Plaintiff
`and members of the proposed Class. These common questions of law and fact exist as to
`all Class members and predominate over questions affecting only individual Class
`members. These common legal and factual questions include, but are not limited to the
`following:
`
`a. Whether Robinhood knowingly failed to provide the financial services that were
`needed to handle reasonable consumer demand,including trading securities that
`are available on every other competitive trading platform;
`
`b. Whether Robinhood failed to provide the duty of care to their customers when
`they purposefully removed GME;
`
`c. Whether Robinhood failed to provide the duty of care to their customers when
`they purposefully removed BB;
`
`d. Whether Robinhoodfailed to provide the duty of care to their customers when
`they purposefully removed AMC;
`
`e. Whether Robinhood failed to provide the duty of care to their customers when
`they purposefully removed NOK;
`
`f. Whether Robinhood failed to provide the duty of care to their customers when
`they purposefully removed NAKD;
`
`g. Whether Robinhood removed GMEpurposefully to harm their customers’
`positions in GMEand benefit their own potential financial gains;
`
`h. Whether Robinhood removed BB purposefully to harm their customers’ positions
`in BB and benefit their own potential financial gains;
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`_ Whether Robinhood removed AMC purposefully to harm their customers’
`positions in AMCandbenefit their own potential financial gains;
`
`Whether Robinhood removed NOK purposefully to harm their customers’
`positions in NOKand benefit their own potential financial gains;
`
`Whether Robinhood removed NAKD purposefully to harm their customers’
`positions in NAKD and benefit their own potential financial gains;
`
`Whether Robinhood violated FINRA Rule 5310, among other FINRA rules,state
`rules, and federal regulations;
`
`. Whether Robinhood violated consumer protection laws in failing to disclose that
`its services would not include the ability to trade on stocks including but not
`limited to GME, BB, AMC, NOK, NAKD, and othersecurities, for substantial
`periods of time;
`
`Whether Robinhood wasin breach ofits legal, regulatory, and licensing
`requirements by failing to provide adequate access to financial services;
`
`Whether Robinhood wasin breach ofits contracts and/or the implied covenant of
`good faith and fair dealing in connection with its failure to provide financial
`services;
`
`Whether Robinhood was negligent or grossly negligent by failing to provide
`financial services in a timely manner dueto its possible nefarious desires;
`
`Whether Robinhood breachedits fiduciary duties to customers by failing to
`provide adequate accessto financial services;
`
`Whether Robinhood was unjustly enriched by its conduct;
`
`Whether Plaintiff and the other Class members were injured by Robinhood's
`conduct, and if so, the appropriate class-wide measure of damages,restitution,
`and other appropriate relief, including injunctive relief.
`
`Whether Plaintiff and the other Class membersare entitled to injunctive and
`declaratoryrelief.
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`37.
`
`Typicality: The claims of the named Plaintiff are typical of the claims of the proposed
`Class in that the named Plaintiff was a customer during the class period and was unable
`to trade stocks including but not limited to GME, BB, AMC, NOK, NAKD, and place
`time-sensitive trades thereby sustaining damages as a result of Robinhood's wrongful
`conduct.
`
`58,
`
`Adequate Representation: Plaintiff will fairly and adequately represent the Class's
`interests in that he has no conflicts with any other Class members. Plaintiff has retained
`competent counsel experienced in prosecuting complex class actions, including those
`involving financial services, and they will vigorously litigate this class action.
`
`59.
`
`Predominance and Superiority: There is no plain, speedy, or adequate remedy other
`than maintaining this class action. A class action is superior to other available means, if
`any, for the fair and efficient adjudication of this controversy. Prosecution of separate
`actions by individual Class members would create the risk of inconsistent or varying
`adjudications, establishing incompatible standards of conduct for the Defendant.
`Additionally, given the relatively modest damages sustained by most individual
`members, few, if any, proposed Class members could or would sustain the economic
`burden of pursuing individual remedies for Robinhood's wrongful conduct. Treatmentas
`a class action will achieve substantial economies of time, effort, and expense and provide
`comprehensive and uniform supervision by a single court. This class action presents no
`material difficulties inmanagement.
`
`60.
`
`Class action certification is warranted under Fed. R. Civ P. 23(b)(1)(A) because the
`prosecution of separate actions by individual members of the proposed Class would
`create a risk of inconsistent or varying adjudications with respect to individual Class
`members, which may produce incompatible standards of conduct for Defendants. 34.
`Class action certification is warranted under Fed. R. Civ P. 23(b)(1)(B) because the
`prosecution of separate actions by individual members of the proposed Class would
`create a risk of adjudications with respect to individual Class members, which may, as a
`practical matter, be dispositive of the interests of the other membersnotparties to the
`adjudications or substantially impair or impedetheir ability to protect their interests.
`
`61.
`
`The prerequisites to maintaining a class action for injunctive or equitable relief pursuant
`to Fed. R. Civ. P. 23(b)(2) are met as Robinhood hasacted or refused to act on grounds
`generally applicable to the Class, thereby makingfinal injunctive, declaratory, or
`equitable relief appropriate with respect to the Class as a whole. 36. Class action
`certification is also warranted under Fed. R. Civ P. 23(b)(3) because questions of law or
`fact common to the class members predominate over any questions affecting only
`individual members, and a Class action is superior to other available remedies for the fair
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`and efficient adjudication of this controversy. The amount of damagesavailable to the
`individual Plaintiff is insufficient to make litigation addressing Robinhood's conduct
`economically feasible for most in the absence of the class action procedure.
`Individualized litigation also presents a potential for inconsistent or contradictory
`judgments and increases the delay and expensetoall parties and the court system
`presented by the case's legal and factual issues. By contrast, the class action device
`presents far fewer managementdifficulties and provides the benefits of a single
`adjudication, economyof scale, and comprehensive supervision by a single court.
`
`62.
`
`Class action certification is also warranted under Fed. R. Civ P. 23(c)(4) because
`questions of law or fact common to the Class members may be certified and decided by
`this Court on a class-wide basis.
`
`CAUSE OF ACTION I
`For Breach of Contract
`
`63.
`
`Plaintiffs hereby incorporate by reference the factual allegations set forth above.
`
`64.
`
`In order to use the Robinhood trading platform, a potential customer must enter into the
`Customer Agreement with Robinhood.
`
`65.
`
`Plaintiff and all class members did enter into a Customer Agreement with Robinhood.
`
`66.
`
`Robinhood breached its Customer Agreement by, among other things, failing to disclose
`that its platform was going to pull profitable stocks from its platform randomly; that
`Robinhood failed to provide an adequate explanation to their customers; that Robinhood
`knowingly put their customers at a disadvantage compared to customers who used other
`trading apps; that Robinhoodfailed to provide access to its financial incentives to pull
`certain securities; that Robinhood's prohibited plaintiffs from performing in a timely
`manner(or at all) under the contract; that Robinhood failed to comply with all applicable
`legal, regulatory, and licensing requirements; and that Robinhood failed to exercise trades
`and actions requested by customers.
`
`67,
`
`Assuch, Robinhood breached its Customer Agreement with Plaintiff and Class
`members.
`
`68.
`
`Robinhood's failure to perform andits breaches of the Customer Agreement resulted in
`damages and losses to Plaintiff and Class members and continues to expose them to harm
`because Robinhoodfails to perform under the Customer Agreement. Theselossesreflect
`damages to Plaintiff and Class members in an amount to be determinedat trial or separate
`proceedings as necessary.
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`CAUSE OF ACTION II
`Breach of the Implied Covenant of Good Faith and Fair Dealing
`
`69.
`
`70.
`
`Plaintiffs hereby incorporate by reference the factual allegations set forth above.
`Plaintiffs and members of the Class and Subclass entered into the Customer Agreement
`with Defendant Robinhood to open a Robinhood trading account. They agreed to
`Robinhood's Terms and Conditions by using Robinhood's website and trading platform.
`
`71.
`
`Plaintiffs and members of the Class and Subclass fulfilled their obligations under these
`contracts by adhering to their terms and using Robinhood's trading services throughits
`website and trading platform.
`
`72.
`
`Robinhood was obligated to provide the trading services required under those contracts
`at all times, including but not limited to trades for GME, BB, AMC, OK, and NAKD.
`
`73.
`
`Wheninitially signing up for Robinhood, Plaintiff and all those similarly situated could
`and most actually did trade stocks, including but not limited to GME, BB, AMC, NOK,
`NAKD.
`
`74,
`
`Robinhood unfairly interfered with the rights of Plaintiffs and members of the Class and
`Subclass to receive the benefits of the Customer Agreement by, among other things, (1)
`failing to provide services necessary to carry out a trade;(ii) failing to provide certain
`trading services whatsoever; (iii) failing to inform individuals in a timely memberof the
`drastic changes in trading abilities; and (iv) prohibiting plaintiffs from buying GME, BB,
`AMC, NOK, NAKD,andothers, (v. for Robinhood's pecuniary interest and not
`disclosing those interest to Plaintiffs and all Class and Subclass members.
`
`75.
`
`Robinhood's conduct has caused Plaintiffs and members of the Class and Subclass harm,
`losses, and damages. These losses reflect damages to Plaintiffs and members of the Class
`and Subclass in an amount to be determined at trial or separate proceedings as necessary.
`
`CAUSE OF ACTIONIII
`
`Negligence
`
`76,
`
`Plaintiffs hereby incorporate by reference the factual allegations set forth above.
`Robinhood had a duty to exercise reasonable care in conducting and facilitating
`transactions for its customers.
`
`77,
`
`Robinhoodhad a duty to exercise reasonable care in providing trades on the free, open
`market for its customers.
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`78.
`
`Robinhood unlawfully breached its duties by, among other things, (1) removing multiple
`stocks to include but not limited to MGS, BB, AMC, NOK, NAKD, without notice from
`its trading app; (41) failed to provide financial services related to stocks including but not
`limited to GME, BB, AMC, NOK, NAKD,;(iii) failing to notify customers in a timely
`manner of the stock "blackouts,"
`
`79,
`
`Asoutlined in this Complaint, Robinhood's conduct lacked all care, and its acts and
`omissions were and continue to be an extreme departure from the ordinary standard of
`conduct. Their actions breach any duty of care to their customers and are inconsistent
`with the standard of care expected from similar firms in the open market.
`
`80.
`
`Uponinformation and belief, no institutions similar to Robinhood has ever outright
`banned customers from purchasing a specific share of a specific security.
`
`81.
`
`Robinhoodessentially abandoned its customers altogether by pulling stocks including
`but not limited to GME, BB, AMC, NOK, NAKD, a standard of care so far below whatis
`required for a business engaging in time-sensitive trading services that it amounts to a
`complete abandonmentofits duties.
`
`82.
`
`Robinhood's grossly negligent and wrongful breaches of its duties owed to Plaintiffs and
`members of the Class and Subclass proximately caused losses and damages that would
`not have occurred but for Robinhood's gross breach of its duty of due care. These losses
`reflect damages to Plaintiffs and members of the Class and Subclass in an amountto be
`determined at trial or separate proceedings as necessary.
`
`CAUSE OF ACTION IV
`Breach of Fiduciary Duty
`
`83.
`
`Plaintiff hereby incorporates by reference the factual allegations contained herein.
`
`84.
`
`As a licensed providerof financial services, Robinhood, at all times relevant herein was a
`fiduciary to Plaintiff and Class members and owed them the highest good faith and
`integrity in performing its financial services on their behalf. Robinhoodalso acted as a
`fiduciary to each and every customer who agreed to the Customer Agreement.
`
`85.
`
`Robinhood breachedits fiduciary duties to Plaintiff and Class members by, among other
`things, failing to disclose that its platform was going to remove stock purchases in a
`timely manner; actually removing stocks including but not limited to GME, BB, AMC,
`NOK, NAKD; removingstocks including but not limited to GME, BB, AMC, NOK,
`NAKD,for its own pecuniary benefits; that Robinhoodfailed to provide accessto its
`financial services in a timely manner; that Robinhood failed to comply with ail applicable
`
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`legal, regulatory, and licensing requirements; and that Robinhood failed to exercise trades
`and actions requested by customers in a complete and timely manner(also required by
`FINRA Rule 5310).
`
`86.
`
`Robinhood's conduct has caused Plaintiff and Class members' harm, losses, and damages
`and continues to expose them to harm because Robinhood continuesto breachits
`fiduciary duties. These losses reflect damages to Plaintiff and Class membersin an
`amount to be determinedat trial or separate proceedings as necessary.
`
`RELIEF REQUEST:
`
`Tis
`
`Enter an immediate injunction requiring Robinhood to reinstatement GMEontheir
`trading platform;
`
`Enter an immediate injunction requiring Robinhood to reinstatement BB ontheir trading
`platform;
`
`Enter an immediate injunction requiring Robinhood to reinstatement AMC on their
`trading platform;
`
`Enter an immediate injunction requiring Robinhood to reinstatement NOK ontheir
`trading platform;
`
`Enter an immediate injunction requiring Robinhood to reinstatement NAKDontheir
`trading platform;
`
`Enter an awardfor plaintiffs to be determined;
`
`Enter an award for attorneys fees and costs;
`
`Enter an award for punitive damagesfor the willful, wanton, and reckless behavior of
`Defendants; and,
`
`8.
`
`Any otherrelief this Court deemsjust andfit.
`
`Date: January 28, 2021
`
`Respectfully,
`
`| ee R. CARLIN, ESQ
`
`301 E. Ocean BLVD., Suite 1550
`Long Beach, California
`
`Page 13 of 13
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