Ghayoori v. Cobra Trading Inc

CourtDistrict Court, W.D. Washington
DecidedMay 28, 2025
Docket2:25-cv-00021
StatusUnknown

This text of Ghayoori v. Cobra Trading Inc (Ghayoori v. Cobra Trading Inc) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ghayoori v. Cobra Trading Inc, (W.D. Wash. 2025).

Opinion

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3 4 5 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 6 AT SEATTLE 7 ARASH GHAYOORI, 8 Petitioner, 9 v. 10 COBRA TRADING, INC., 11 Respondent. C25-0021 TSZ 12 ORDER 13 COBRA TRADING, INC., 14 Counter Claimant, 15 v. 16 ARASH GHAYOORI, Counter Defendant. 17

18 THIS MATTER comes before the Court on petitioner and counter-defendant 19 Arash Ghayoori’s Petition to vacate the arbitration award (the “Award”), docket no. 1, 20 respondent and counter-claimant Cobra Trading, Inc.’s counterclaim, see Answer and 21 Counterclaim, docket no. 6, Cobra’s opposition to the petition to vacate and motion to 22 confirm (“Motion to Confirm”) the Award, docket no. 8, Mr. Ghayoori’s cross motion to 1 vacate the Award (“Cross Motion to Vacate”), docket no. 13, and Mr. Ghayoori’s Motion 2 for a More Definite Statement, docket no 15. Having reviewed all papers filed in support

3 of, and in opposition to, the petition and motions, the Court enters the following order. 4 Background 5 Founded in 2004, Cobra operates as a retail broker providing customer service and 6 trading tools to active stock and option traders—both institutional and retail. See Ex. C to 7 Mot. to Confirm (docket no. 8-3).1 8 On or about July 6, 2021, Mr. Ghayoori created a margin trading account with

9 Cobra, which allowed him to trade on credit. See Ghayoori Decl. at ¶ 3 (docket no. 14); 10 see also Ex. C to Mot. to Confirm at 48–49 (docket no. 8-3). On his application for the 11 account, Mr. Ghayoori indicated that his investment objectives included “Trading, 12 Speculation, Growth” and “Income,” he wrote “Aggressive” as his risk tolerance, and he 13 provided several addresses, including his physical addresses in California and Vancouver,

14 British Columbia, and his brother’s physical address. See Ghayoori Decl. at ¶ 3 (docket 15 no. 14); see also Ex. E to Mot. to Confirm at 68 (docket no. 8-5). In connection with 16 establishing a margin account with Cobra, Mr. Ghayoori agreed to the following: 17 You can lose more funds than you deposit in the margin account – A decline in the value of securities that are purchased on margin may require you to 18 provide additional funds to the firm that has made the loan to avoid the forced sale of those securities or other securities in your account. The firm can force 19 the sale of securities in your account – If the equity in your account falls below the maintenance margin requirements under the law or the firm’s 20

21 1 The Court notes that exhibits filed by Cobra in support of its Motion to Confirm include declarations executed under penalty of perjury pursuant to 28 U.S.C. § 1746. Pursuant to this statute, these “unsworn 22 declarations” are admissible and entitled to evidentiary weight. 1 higher “house” requirements, the firm can sell the securities in your account to cover the margin deficiency. You also will be responsible for any shortfall 2 in the account after such a sale. The firm can sell your securities without contacting you – Some investors mistakenly believe that a firm must contact 3 them for a margin call to be valid, and that the firm cannot liquidate securities in their accounts to meet the call unless the firm has contacted them first. 4 This is not the case.

5 See Ex. B to Mot. to Confirm at 6 (docket no. 8-2). 6 On November 7, 2023, Mr. Ghayoori’s account reflected a negative balance of 7 $353,913.50 as a result of the trading activity and fund withdrawal the day prior.2 See 8 Ex. B to Mot. to Confirm at 5 (docket no. 8-2). The parties dispute, however, whether the 9 trading that occurred on November 6, 2023, was authorized by Mr. Ghayoori. Cobra 10 contends that on that date, Mr. Ghayoori “shorted” the stock of MSP Recovery, Inc. by 11 borrowing shares and selling them to buyers at market price, as he anticipated a decline in 12 value. See Ex. C to Mot. to Confirm at 54, 70 (docket no. 8-3). Instead, the stock price 13 rose, and Mr. Ghayoori’s positions incurred substantial losses. See Ex. B to Mot. to 14 Confirm at 69 (docket no. 8-2). Cobra asserts that it was required to cover the growing 15 debt by liquidating Mr. Ghayoori’s margin account. See Ex. C to Mot. to Confirm at 70 16 (docket no. 8-3). During the time the trades were being processed, Cobra contends that 17 Mr. Ghayoori represented he needed to immediately wire $313,000.00 for a real estate 18 transaction, and Cobra staff approved the transfer. See Ex. D to Mot. to Confirm (docket 19 no. 8-4). As a result of the trading losses and the withdrawal, Cobra states that 20

21 2 Mr. Ghayoori maintains that his account should reflect a balance of $30,000.00—the amount that would have remained following his request for a wire transfer—as he denies having traded on November 6, 22 2023. See Ghayoori Decl. at ¶ 9 (docket no. 14). 1 Mr. Ghayoori’s account balance reflected a negative $353,913.50. See Ex. E to Mot. to 2 Confirm at 86 (docket no. 8-5). On or about November 6, 2023, Mr. Ghayoori retained an

3 attorney who spoke with Cobra concerning this dispute. See Ex. B to Mot. to Confirm at 4 4 (docket no. 8-2). The attorney no longer represented Mr. Ghayoori as of November 9, 5 2023. See Ex. D to Mot. to Confirm at 4 (docket no. 8-4). 6 Mr. Ghayoori denies that he authorized any trades on November 6, 2023. See 7 Ghayoori Decl. at ¶¶ 5, 7 (docket no. 14). He maintains that, prior to learning of the 8 trades, he requested a wire transfer, which Cobra staff approved. See id. at ¶¶ 4, 6. Upon

9 discovering the trading activity, Mr. Ghayoori states that he “immediately contacted 10 Cobra to dispute them and assert that my account had been compromised.” Id. at ¶ 8; see 11 also Ex. F to Ghayoori Decl. (docket no. 14). 12 On November 16, 2023, Mr. Ghayoori sent an email to the Chief Operating 13 Officer of Cobra, Thomas Terry, stating the trades that occurred on November 6, 2023,

14 on his account were “unauthorized,” that he does “not have any responsibility for the 15 negative account balance” as “it is the direct result of the unauthorized trading,” that his 16 “phone number is no longer in service,” he has “moved to another part of the world,” and 17 “no longer live[s] in the U[nited] S[tates].” Ex. B to Mot. to Confirm at 4–5 (docket 18 no. 8-2).

19 On or about December 27, 2023, Cobra initiated arbitration proceedings against 20 Mr. Ghayoori through the Financial Industry Regulatory Authority (“FINRA”) pursuant 21 to the terms of the margin agreement. See Ex. C to Mot. to Confirm (docket no. 8-3). 22 Cobra initially requested Dallas, Texas, as the venue for the arbitration proceedings 1 because it is headquartered in the Dallas area and Mr. Ghayoori entered agreements 2 governed by Texas law with a Dallas forum selection provision. See id. Thereafter,

3 pursuant to FINRA Rule 12213, FINRA designated Seattle, Washington, as the 4 arbitration location, because the last known physical address of Mr. Ghayoori was in 5 Vancouver, British Columbia, and Seattle is the closest venue to that location. See Ex. C 6 to Mot. to Confirm at 24 (docket no. 8-3). 7 On January 3, 2024, FINRA mailed copies of the statement of the arbitration claim 8 (the “Statement of Claim”) and related arbitration documents to both physical addresses

9 Cobra maintained on file for Mr. Ghayoori, but the mailings were returned as 10 undelivered. See Exs. C & E to Mot. to Confirm (docket nos. 8-3 & 8-5). On January 24, 11 2024, Cobra’s counsel served the Statement of Claim and related documents on 12 Mr. Ghayoori via the FINRA Dispute Resolution (“DR”) Portal.3 See Ex. C to Mot. to 13 Confirm at 4 (docket no. 8-3). That same day, Cobra also emailed the materials to the

14 same address Mr. Ghayoori used to open his account and correspond with Cobra. See id. 15 at 8. Cobra copied Mr.

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