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`Case 3:19-cv-02356-S Document 51 Filed 04/23/21 Page 1 of 164 PageID 1448Case 3:19-cv-02356-S Document 51 Filed 04/23/21 Page 1 of 164 PageID 1448
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`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF TEXAS
`DALLAS DIVISION
`
`
`PHILLIP R. CRUTCHFIELD,
`Individually and On Behalf of All Others
`Similarly Situated,
`
`Case No.: 3:19-cv-02356
`
`Plaintiff,
`
`v.
`
`SECOND AMENDED CLASS
`ACTION COMPLAINT FOR
`VIOLATIONS OF THE FEDERAL
`SECURITIES LAWS
`
`MATCH GROUP, INC., AMANDA W.
`GINSBERG, and GARY SWIDLER,
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`JURY TRIAL DEMANDED
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`Defendants.
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`Case 3:19-cv-02356-S Document 51 Filed 04/23/21 Page 2 of 164 PageID 1449Case 3:19-cv-02356-S Document 51 Filed 04/23/21 Page 2 of 164 PageID 1449
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`TABLE OF CONTENTS
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`I.
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`II.
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`III.
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`IV.
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`V.
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`NATURE OF THE ACTION ............................................................................................. 1
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`JURISDICTION AND VENUE ......................................................................................... 5
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`PARTIES ............................................................................................................................ 6
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`NON-PARTY CONFIDENTIAL WITNESSES ................................................................ 7
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`SUBSTANTIVE ALLEGATIONS .................................................................................. 12
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`A.
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`B.
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`Match’s Business & Operations............................................................................ 12
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`Match’s Strong and Growing Revenues Were Driven By Widespread Undisclosed
`Misconduct ............................................................................................................ 15
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`1.
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`Undisclosed Facts and Risks Concerning Fraudulent Accountholders .... 16
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`2.
`
`3.
`
`a.
`
`b.
`
`c.
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`Undisclosed Facts and Risks Due to Scammers ........................... 16
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`Undisclosed Facts and Risks Due to Bots..................................... 28
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`Undisclosed Facts and Risks Due to Sex Offenders and Felons .. 30
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`Undisclosed Facts and Risks Concerning Match’s Use of Communications
`from Fraudulent Accounts to Generate Deceptive Marketing, Sell
`Subscriptions, And Increase Its User Base ............................................... 35
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`Undisclosed Facts and Risks Concerning Match’s Use of Deceptive
`Guarantees and Confusing Billing and Cancellation Practices to Maintain
`Its Improperly Inflated User Base ............................................................. 37
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`a.
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`b.
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`Undisclosed Facts and Risks Concerning Match’s Use of Deceptive
`Guarantees .................................................................................... 38
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`Undisclosed Facts and Risks Concerning Match’s Improper Billing
`and Cancellation Practices ........................................................... 39
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`4.
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`Undisclosed Facts and Risks Concerning Match’s Retailiation Against Its
`Employees Who Tried To Protect Members ............................................ 45
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`C.
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`Materially False and Misleading Statements Issued During the Period ............... 46
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`1.
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`2.
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`The Membership Integrity Fraud .............................................................. 46
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`The Reported Results Fraud .................................................................... 120
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`D.
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`E.
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`PARTIAL CORRECTIVE DISCLOSURES INCREMENTALLY REVEALED
`THE FRAUDS .................................................................................................... 124
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`POST-CLASS PERIOD FACTS UNDERSCORE ONGOING RISKS FOR
`MATCH FROM THE UNDERLYING MISCONDUCT AT ISSUE ................ 129
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`F.
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`ADDITIONAL FACTS PROBATIVE OF SCIENTER..................................... 130
`
`1.
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`Defendants Ginsberg’s and Swidler’s Knowledge or Reckless Disregard of
`Red Flags Demonstrates Scienter ........................................................... 130
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`i
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`2.
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`3.
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`4.
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`5.
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`6.
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`7.
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`Defendants Ginsberg’s and Swidler’s Suspicious, Widespread Insider
`Trading During the Class Period Evidences Scienter ............................. 137
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`Defendants Ginsberg And Swidler Failed To Disclose One SEC
`Investigation And Two FTC Investigations While Insider Trading ....... 143
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`Suspicious Resignations, Including By Defendant Ginsberg, Evidence
`Scienter ................................................................................................... 144
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`The Fraud Implicated Core Operations ................................................... 146
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`Defendants Ginsberg and Swidler Signed, Were Quoted In, or Sox Certified
`the Alleged Misstatements ...................................................................... 147
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`The Fraud And Retaliation Against Employees Violated Match’s Corporate
`Code of Business Conduct and Ethics .................................................... 148
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`VI.
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`NO SAFE HARBOR ...................................................................................................... 150
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`VII. LOSS CAUSATION/ECONOMIC LOSS ..................................................................... 151
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`VIII. PRESUMPTION OF RELIANCE .................................................................................. 152
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`IX.
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`PLAINTIFFS’ CLASS ACTION ALLEGATIONS ....................................................... 153
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`X.
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`CLAIMS FOR RELIEF .................................................................................................. 155
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`COUNT I .................................................................................................................................... 155
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`COUNT II ................................................................................................................................... 159
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`XI.
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`PRAYER FOR RELIEF ................................................................................................. 160
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`XII. DEMAND FOR TRIAL BY JURY ................................................................................ 160
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`
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`
`ii
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`Co-Lead Plaintiffs, Phillip R. Crutchfield and Samir Ali Cherif Benouis (“Plaintiffs”),
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`individually and on behalf of all other persons similarly situated, by their undersigned attorneys,
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`for their complaint against Defendants, allege the following based upon personal knowledge as to
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`themselves and their own acts, and information and belief as to all other matters, based upon, inter
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`alia, the investigation conducted by and through their attorneys, which included a review of
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`Defendants’ public statements and publicly available documents, conference calls and
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`announcements, SEC filings, wire and press releases published by and regarding Match Group,
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`Inc. (“Match Group” or “Match”), analysts’ reports and advisories and other press coverage about
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`Match, Match’s stock chart, Match’s corporate website, data obtained through news services such
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`as Bloomberg and Yahoo! Finance, interviews with certain confidential witnesses (“CWs”) who
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`were former employees of Match and the brands it owns, information obtained through Freedom
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`of Information Act requests, and information readily obtainable through publicly available sources
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`and on the Internet. Plaintiffs believe that substantial evidentiary support will exist for the
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`allegations set forth herein after a reasonable opportunity for discovery.
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`I.
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`NATURE OF THE ACTION
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`1.
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`This is a federal securities class action brought on behalf of a class consisting of all
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`persons and entities who purchased or otherwise acquired the common stock of Match Group, Inc.
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`(NASDAQ: MTCH) between November 6, 2018 and January 31, 2020, both dates inclusive
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`(“Class Period”), seeking to pursue remedies against Match and certain of its officers and/or
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`directors named as Defendants herein for violations of the federal securities laws under the
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`Securities Exchange Act of 1934 (the “Exchange Act”).
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`2.
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`Match Group operates a suite of dating and matchmaking websites and applications
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`(“apps”) accessed through computers and devices, including popular brands like Match.com,
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`1
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`Tinder, PlentyofFish. It derives substantially all its revenues from payments by a portion of its
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`registered members, those it can convert from a free or trial membership to a premium or paid
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`membership, like Tinder Gold. To gauge its success, Match tracks financial and performance
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`metrics that are publicly reported to analysts and investors, including its “paid member count” or
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`“PMC”, the conversion rate from unpaid to paid memberships, and the average revenue per user
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`(or “ARPU”), in addition to more traditional reporting metrics like revenues and earnings.
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`3.
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`Unbeknownst to investors, Match’s websites and apps suffered from rampant levels
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`of scammers, “bots,” and other fraudulent accounts among its registered users, a “significant”
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`percentage of whom paid premiums for access to enhanced features, both to avoid detection and
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`as a prerequisite to accessing the features and functionalities necessary to carry out their scams.
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`These nefarious actors sought to extract money or things of value from Match’s legitimate
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`customers. Worse, most of Match’s brands also failed to screen for sex offenders and other
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`dangerous users, leading to a high number being on those sites. These underlying, negative,
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`undisclosed facts were described by numerous CWs, all former employees of Match Group or its
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`branded websites and apps like Tinder and Match.com. They describe a 15% to 20% rate of
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`fraudulent accounts on these Match websites/apps. They also describe how this percentage of
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`fraudulent accounts, if stable, was simply assumed, such that company forecasts were not adjusted
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`to exclude those accounts, even those that were paid subscriptions.
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`4.
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`Investors also did not know the extent to which Match understaffed and impeded
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`its own anti-fraud efforts. The CWs speak of small Fraud Department teams of just eight people
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`tasked with manually identifying and making removal decisions on millions of potentially
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`fraudulent accounts, in high volume and at high speed. The CWs described how the company
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`failed to implement touted technological anti-fraud measures and how cost concerns dictated that
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`2
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`anti-fraud personnel head counts were not increased. Certain CWs even describe retaliation by the
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`company when they took measures to protect consumers from fraudsters or dangerous users.
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`5.
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`The CWs also detail how these illegitimate and fraudulent accounts impacted and
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`inflated not only Match’s user statistics, metrics, and trends, but also its reported results, both
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`directly, as a “significant” percentage of scam accounts paid for extended length (3-month, 6-
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`month, or even 1-year) memberships, and indirectly, as Match and its branded websites and apps
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`used “aggressive” marketing based on the illegitimate and fraudulent accounts to target legitimate
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`non-paying users. Specifically, the CWs and an FTC complaint both assert that Match based email
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`solicitations and other marketing on the illegitimate and fraudulent accounts that were designed to
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`get non-paying users to upgrade to a premium or paid membership, like Tinder Gold, to see
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`purported “winks” or messages from other accounts – that, in reality, were set up by non-existent
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`“admirers” who sent only scam communications. The CWs said that Match and its branded
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`websites and apps also made it confusing and difficult – by design – for users to cancel paid
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`memberships once they were initiated.
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`6.
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`Contrary to these negative, undisclosed facts, Defendants Match, Ginsberg, and
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`Swidler made materially false and misleading misstatements and omissions to investors during the
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`Class Period that depicted Match as a strong company with solid website / app user base, high
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`customer satisfaction, and effective safety screening. For instance, in a December 20, 2018 video
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`interview published by the Wall Street Journal, Defendant Ginsberg said, “[W]e do everything we
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`can to provide safety and security for our users – everything from one strike you’re out to
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`making sure that we put in processes and best practices across the organization to keep bad
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`actors out.” A December 21, 2018 Wall Street Journal article published additional quotes by
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`Defendant Ginsberg, including, “It helps for us to have a portfolio [of matchmaking apps]
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`3
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`because if there’s bad behavior on one app, we can identify that user, we’ll kick him off all the
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`apps.” In a February 7, 2019 CNBC video interview, Defendant Ginsberg said, “[A]bout a year
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`and a half ago, we introduced [Tinder] Gold, which … gives you the ability to see who’s liked
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`you. [I]f someone says to you, do you want to see all the women who’ve liked you or all the men
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`who’ve liked you, it’s very hard to say no. … [T]he take rate on that Gold or that ‘likes you’
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`feature was really high and that was priced at an even higher premium, another subscription
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`tier. … [T]hat’s what’s really driven a lot of the growth.” In a May 8, 2019 Yahoo! Finance
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`interview, Defendant Swidler said, “We rolled out something called Tinder Gold about a year
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`and a half ago now. It’s been a huge success. [W]e’re continuing to find ways to make that
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`offering more compelling for users and have more people buy into Tinder Gold. We’re
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`merchandising it better. We’re getting it in front of users more effectively. And it’s really
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`working.” Defendant Ginsberg wrote in an article in the July/August 2019 issue of the Harvard
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`Business Review, “Most dating apps, including Tinder, have shifted to a “freemium” or paywall
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`strategy. Joining is free, and users get basic functionality. They can opt to pay for premium
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`features such as seeing who likes you and swiping in another city. Last year Tinder’s revenue
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`topped $800 million, demonstrating that many people are willing to pay for these features.”
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`Match’s September 25, 2019 press release, authorized for publication by Defendants Ginsberg and
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`Swidler, stated, “We catch and neutralize 85% of potentially improper accounts in the first four
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`hours, typically before they are even active on the site, and 96% of improper accounts within a
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`day” and “We’ve developed industry leading tools and AI that block 96% of bots and fake
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`accounts from our site within a day and are relentless in our pursuit to rid our site of these
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`malicious accounts.”
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`4
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`7.
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`The truth about these and the other alleged misstatements and omissions alleged
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`below was revealed through a series of partial corrective disclosures that over time revealed, inter
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`alia, that the FTC had filed a complaint against Match; that Match’s legal costs were soaring; that
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`an investigative report revealed that Match’s websites and apps, including Tinder, failed to screen
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`for sex offenders, leading to sexual assaults on legitimate site users; and that a Congressional
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`investigation was launched into the legitimacy and legality of Match’s user base. Each of these
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`partial corrective disclosures was accompanied by a correlating stock drop, sometimes muted by
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`Defendants’ contemporaneous explanations and additional misstatements, and each of them
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`damaged Plaintiffs and the Class Members. As a result of Defendants’ wrongful acts and
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`omissions as alleged herein, and the precipitous decline in the market value of Match’s securities,
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`Plaintiffs and the other Class members have suffered significant losses and damages.
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`II.
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`JURISDICTION AND VENUE
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`8.
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`The claims asserted herein arise under, and pursuant to, Sections 10(b) and 20(a)
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`of the Exchange Act, 15 U.S.C. §§78j(b) and 78t(a), and SEC Rule 10b-5 promulgated thereunder,
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`17 C.F.R. §240.10b-5.
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`9.
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`This Court has jurisdiction over the subject matter of this action under 28 U.S.C.
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`§1331 and §27 of the Exchange Act.
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`10.
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`Venue is proper in this Judicial District pursuant to §27 of the Exchange Act and
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`28 U.S.C. §1391(b). Many of the acts charged herein, including the dissemination of materially
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`false and/or misleading information, occurred in substantial part in this District.
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`11.
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`In connection with the acts, conduct and other wrongs alleged in this Complaint,
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`Defendants, directly or indirectly, used the means and instrumentalities of interstate commerce,
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`5
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`including, but not limited to, the mails, interstate telephone communications, and the facilities of
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`an electronic securities exchange in this District.
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`III.
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`PARTIES
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`12.
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`Plaintiff Phillip R. Crutchfield, as set forth in the previously-filed certification,
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`incorporated by reference herein, purchased Match securities during the Class Period, and suffered
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`damages as a result of the federal securities law violations and false and/or misleading statements
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`and/or material omissions alleged herein.
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`13.
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`Plaintiff Samir Ali Cherif Benouis, as set forth in the accompanying updated
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`certification filed herewith and in his previously-filed certification, incorporated by reference
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`herein, purchased Match securities during the Class Period, and suffered damages as a result of
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`the federal securities law violations and false and/or misleading statements and/or material
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`omissions alleged herein.
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`14.
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`Defendant Match (“Match”) is incorporated under the laws of Delaware with its
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`principal executive offices located in Dallas, Texas. Match’s common stock trades on the
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`NASDAQ exchange under the symbol “MTCH.” During the Class Period Match was a majority-
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`owned, publicly traded subsidiary of IAC/InterActiveCorp (“IAC”). At relevant times, the Match
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`corporate website has listed at least 20 different analysts who follow the company and its stock.
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`15.
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`Defendant Amanda W. Ginsberg (“Ginsberg”) was, at all relevant times, the Chief
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`Executive Officer (“CEO”) of Match.
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`16.
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`Defendant Gary Swidler (“Swidler”) was, at all relevant times, Chief Financial
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`Officer (“CFO”) of Match.
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`17.
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`Defendants Ginsberg and Swidler are collectively referred to herein as the
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`“Individual Defendants.”
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`6
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`18.
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`Defendants Ginsberg and Swidler, because of their positions with Match, possessed
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`the power and authority to control the contents of Match’s reports to the SEC, press releases and
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`presentations to securities analysts, money and portfolio managers and institutional investors, i.e.,
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`the market. Defendants Ginsberg and Swidler were provided with copies of Match’s reports and
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`press releases alleged herein to be misleading prior to, or shortly after, their issuance and had the
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`ability and opportunity to prevent their issuance or cause them to be corrected. Because of their
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`positions and access to material non-public information available to them, Defendants Ginsberg
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`and Swidler knew that the adverse facts specified herein had not been disclosed to, and were being
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`concealed from, the public, and that the positive representations that were being made were then
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`materially false and/or misleading. Defendants Ginsberg and Swidler are liable for the false
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`statements pleaded herein.
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`IV. NON-PARTY CONFIDENTIAL WITNESSES
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`19.
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`Lead Plaintiffs’ access to former employees of Match and its branded websites and
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`apps to solicit statements of truthful, relevant information has been hampered by the existence of
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`nondisclosure agreements and pending or potential personal litigation between these employees at
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`the company. Lead Plaintiffs believe that subpoena discovery would yield additional, material
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`information that would support the allegations and claims set forth herein.
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`20.
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`CW1 worked as the Senior Manager of Financial Planning and Analysis for Match
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`Group from January 2016 until May 2019 at Match Group’s headquarters in Dallas, on the 13th
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`floor where Defendant Ginsberg’s office was located. In this position, among other things, CW1
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`reviewed financial reports from each of Match’s website / app brands and consolidated them into
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`reports for monthly forecast meetings attended by executive leadership, including Defendants
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`Ginsberg and Swidler, worked on Match employee head-count reports, prepared information for
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`7
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`Match’s then-parent company IAC, prepared information for quarterly investor calls, and attended
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`monthly budget meetings. CW1 reported to Joaquin Martinez, the Vice President of Finance at
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`Match Group, who reported to Indrajit Ponnambalam, the Senior Vice President of Finance who
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`reported to Defendant Swidler. CW1 interacted closely with Defendant Swidler, whose office was
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`located in Match’s New York office, via approximately 2 video conference calls per week, in
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`addition to monthly forecast meetings and quarterly investor calls. CW1 also had regular
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`interactions with Defendant Ginsberg, meeting with her at least 2 times a month. CW1 interacted
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`with Match’s then-President and current CEO Sharmistha “Shar” Dubey during monthly forecast
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`meetings, quarterly investor calls, or when CW1 had to put together a report for IAC.
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`21.
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`CW2 worked as a Senior Finance Manager at Match.com in its Dallas headquarters
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`from February 2016 to February 2019. In this position, among other things, CW2 analyzed
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`Match.com’s financial data, developed earnings forecasts, prepared financial data for weekly and
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`monthly meetings where Defendants Ginsberg and Swidler were present, and worked with CW2’s
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`team to increase the conversion of non-paying members to paid member subscribers. CW2
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`reported to Senior Vice President Steve Bailey, who reported to Defendant Swidler.
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`22.
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`CW3 worked at Match.com from May 2010 as the Director of Training and Quality
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`Assurance in Match’s Dallas headquarters, where CW3’s work included developing training
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`modules for employees, reviewing employees to see that they were meeting guidelines, and
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`conducting customer service training for employees of Match.com and other Match brands. CW3
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`left the company in September 2019 when CW3’s position was eliminated. CW3 reported to the
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`Chief Operating Officer.
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`23.
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`CW4 worked at Match.com from July 2014 until November 2017 as a Product
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`Manager in the Operations Team at Match’s Dallas headquarters, and then as a Senior Project
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`8
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`Manager in charge of web applications until July 2018. CW4 reported to Senior Vice President of
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`Product, Beth Wilson. CW4 worked on various teams to improve Match.com’s products,
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`including photo recognition software and efforts to incorporate fraud detection on Match.com and
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`back-end systems for customer service representatives to work with customers on billing and
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`refunds.
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`24.
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`CW5 worked at Match.com in its Dallas headquarters starting in October 2010 for
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`a year as a customer service representative before moving into the Risk Operations Department
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`(commonly referred to as the Fraud Department), where CW5 worked as a Senior Fraud
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`Investigator until October 2019. Among other duties, CW5 investigated member profiles that had
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`been flagged automatically by the internal fraud detection system and attempted to block accounts
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`CW5 believed to be created by scammers. CW5 and the other Fraud Department members
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`monitored profiles on Match.com and People Media Group, the group of sites owned by
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`Match.com, that were internally referred to as Match’s affinity brands and that included niche sites
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`like ourtime.com and blackpeoplemeet.com. As a Senior Fraud Investigator, CW5 reported to the
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`Fraud Department heads, Mike Hanson and Gary Snider.
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`25.
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`CW6 worked at Match.com in its Dallas headquarters as a Senior Security Engineer
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`from February 2018 until April 2019. Among other duties, CW6 was responsible for setting up
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`security systems to detect security breaches, such as if a hacker was trying to access members’
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`personal information. CW6 reported to the Director of Security for Match Group, Joey Mitchell.
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`CW6 was one of six people on the Security Team.
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`26.
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`CW7 worked as the Director of Finance for Tinder from July 2014 until December
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`2018 at Tinder’s West Hollywood office. Among other things, CW7 conducted financial analysis
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`9
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`and prepared financial reports that detailed Tinder’s key metrics and financials. CW7 reported to
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`Senior Vice President James Kim.
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`27.
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`CW8 worked at Match.com in Match’s Dallas headquarters in a variety of
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`capacities from 2011 through May 2019, most recently as the Manager of Community
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`Operations/Relations (January 2018 through May 2019). In this position, among other duties,
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`CW8 supervised the work of the third-party call center that served as the first line of contact for
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`customers, which included a team of four escalation officers, a team of eight internal customer
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`care agents, and a pilot program offering a “white glove” interactive approach for members who
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`paid a premium price. CW8 reported to the Community Relations director, Crystal Roloff, who
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`reported to the Vice President of Community Relations.
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`28.
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`CW9 worked at Match.com in its Dallas headquarters from August 2018 until May
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`2019 as an Escalation Specialist, handling calls from customers who were not satisfied by the first
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`line of customer service representatives. CW9 reported to the Escalations Manager, Amanda
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`Harris. CW9 fielded calls regarding, among other things, subscribing customer complaints about
`
`Match.com’s billing practices, about their inability to access “winks” (a way for members to
`
`indicate interest in someone else on the site that many members use to make first contact before
`
`sending a message) and messages on the site sent by other members sent to them before they chose
`
`to subscribe (so as to access those messages and “winks”), and about their paid subscriptions
`
`continuing even after they tried to cancel. CW9 was fired for receiving low scores from the Quality
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`Assurance Department, in part, in retaliation for refunding customers’ money and advising
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`customers to hide their profiles when they told CW9 that they were afraid for their safety after
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`interactions with other Match customers.
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`
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`10
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`29.
`
`CW10 worked as a Senior Product Designer at Match.com in Match’s Dallas
`
`headquarters from July 2018 until August 2019. Among other duties, CW10 worked on the
`
`desktop website design and mobile application design, making items on the site visibly appealing,
`
`reviewing metrics, and testing that the site’s usability. CW10 reported to the Design Team Lead,
`
`Sean Lester. CW10 also suffered retaliation when CW10 was asked to leave, in part, because
`
`CW10 continuously questioned Match.com’s methods, which CW10 said were all about metrics
`
`and not about the customer.
`
`30.
`
`CW11 worked at Match’s Tinder brand (as discussed below) at its corporate
`
`headquarters in Los Angeles from December 2017 to May 2018 in the Trust and Safety Division,
`
`as one of six Team Members whose duties included responding to user-generated reports about
`
`other users (such as if the users were sex offenders, or were involved in harassment or other
`
`inappropriate behavior) and then from May 2018 until April 2019 in the Customer Service
`
`Division, providing various tech support assistance. During CW11’s tenure in the Trust and Safety
`
`Division, CW11 reported to Nicole Bloomfield, who reported to the VP of Global Community
`
`Operations, Victor Colomes, who in turn, reported directly to the Tinder CEO, Greg Blatt.
`
`31.
`
`CW12 worked for Match.com at its Dallas headquarters from October 2018 until
`
`November 2019. CW12 was initially hired as part of a pilot program that was commissioned to
`
`help Match.com determine if its overseas call center addressed customers’ needs and whether to
`
`continue to use it. In that position, CW12 responded to customer phone calls about their accounts.
`
`About halfway through CW12’s tenure, the pilot program ended and CW12 was kept on as a
`
`Customer Experience Advocate. In this position, CW12 responded to customers’ emails regarding
`
`problems with their accounts. CW12 reported to CW8.
`
`
`
`11
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`32.
`
`CW13 worked as a Community Operations Manager at Tinder from August 2018
`
`until June 2020, based in the West Hollywood office and reporting to Aaron Schlew. CW13
`
`managed the team of Tinder employees who reviewed individual accounts flagged as potentially
`
`fake, fraudulent, or bad actors.
`
`V.
`
`SUBSTANTIVE ALLEGATIONS
`
`A. Match’s Business & Operations
`
`33. Match is a provider of subscription dating products servicing North America,
`
`Western Europe, Asia, and many other regions around the world through websites and applications
`
`that Match owns and operates. Match operates a portfolio of brands, including not only
`
`Match.com, but also other branded websites and apps that are purportedly designed to increase the
`
`likelihood of users in finding a dating connection. Match Group revenue is primarily derived
`
`directly from users in the form of recurring subscriptions. Subscribers pay in advance, primarily
`
`by credit card or through mobile app stores. Revenue is also earned from online advertising, the
`
`purchase of à la carte features and offline events. Many of its brands employ a so-called
`
`“freemium” model, which permits basic registration and functionality for free, but charges a paid
`
`premium for advanced access and features.
`
`34. Match’s portfolio of website / app brands is collectively available in 42 languages
`
`and offered in over 190 countries. Its key brands include:
`
`Match.com. Match.com was launched in 1995. Match claims that among
`Match.com’s distinguishing features are the ability to search profiles, receive
`algorithmic matches and attend live events, promoted by Match.com, with other
`subscribers. Match.com is a brand that purportedly focuses on users with a higher
`level of intent to enter into a relationship, with a product and marketing that are
`purportedly designed to reinforce that approach. Match.com relies heavily on
`word-of-mouth traffic, repeat usage, and paid marketing. Match.com generates
`revenue in ways that include users converting to paid memberships and through
`online advertising.
`
`12
`
`•
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`Tinder. Tinder was launched in 2012, and Match claims that it has since risen to
`scale and popularit