Golubowski v. Robinhood Markets, Inc.

CourtDistrict Court, N.D. California
DecidedFebruary 10, 2023
Docket3:21-cv-09767
StatusUnknown

This text of Golubowski v. Robinhood Markets, Inc. (Golubowski v. Robinhood Markets, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Golubowski v. Robinhood Markets, Inc., (N.D. Cal. 2023).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 PHILIP GOLUBOWSKI, Case No. 21-cv-09767-EMC

8 Plaintiff, ORDER GRANTING DEFENDANTS’ 9 v. MOTION TO DISMISS WITH LEAVE TO AMEND 10 ROBINHOOD MARKETS, INC., et al., Docket No. 78 11 Defendants.

12 13 14 Plaintiffs Aimee Sodha and Vinod Sodha (“Plaintiffs”) filed suit against Defendants 15 Robinhood Markets, Inc. (“Robinhood” or “the Company”), certain senior executives and 16 directors of Robinhood (Vladimir Tenev, Jason Warnick, Baiju Bhatt, Jan Hammer, Paula Loop, 17 Jonathan Rubinstein, Scott Sandell, and Robert Zoellick), and the underwriters (Goldman Sachs & 18 Co. LLC, J.P. Morgan Securities LLC, Barclays Capital Inc., Citigroup Global Markets Inc., 19 Wells Fargo Securities, LLC, Mizuho Securities USA LLC, JMP Securities LLC, KeyBanc 20 Capital Markets Inc., Piper Sandler & Co., Rosenblatt Securities Inc., BMO Capital Markets 21 Corp., BTIG, LLC, Santander Investment Securities Inc., Academy Securities, Inc., Loop Capital 22 Markets LLC, Samuel A. Ramirez & Company, Inc. and Siebert Williams Shank & Co., LLC). 23 Docket No. 75 (“FAC”). Plaintiffs assert claims under Sections 11, 12 and 15 of the Securities 24 Act of 1933 (“the Securities Act”) alleging that the registration statement and prospectus for 25 Robinhood’s July 30, 2021 initial public offering (“IPO”) contained false and misleading 26 statements and omissions. Now pending before the Court is Robinhood’s Motion to Dismiss 27 Plaintiffs’ First Amended Complaint. Docket No. 78 (“MTD”). 1 For the following reasons, the Court GRANTS Robinhood’s Motion to Dismiss WITH 2 LEAVE TO AMEND. 3 I. FACTUAL AND PROCEDURAL BACKGROUND 4 A. Factual Background 5 Robinhood is a financial services company headquartered in Menlo Park, California. FAC 6 ¶ 2. The company provides a trading platform on computers and mobile devices for retail 7 investors. FAC ¶¶ 558–61. Robinhood is a commission-free broker that earns revenue through a 8 “pay for order flow” practice, where it primarily earns revenue by routing customer transactions 9 on its app to market makers in exchange for payments. FAC ¶¶ 62–69. The “pay for order flow” 10 practice accounted for 75% of Robinhood’s revenue in 2020. FAC ¶ 69. 11 Plaintiffs assert that the “pay for order flow” practice has been extensively criticized by the 12 Securities and Exchange Commission, due to brokers’ incentives to route customers’ trades to 13 market makers who pay more, even if those market makers have worse spreads. FAC ¶¶ 69–70. 14 A “spread” is the difference between the bid prices (i.e., the price investors are willing to purchase 15 at) and ask prices (i.e., the price investors are willing to sell at) for the securities. FAC ¶ 65. In 16 December 2020, the SEC charged Robinhood for its misstatements that failed to disclose the 17 firm’s receipt of payments from trading firms for routing customer orders to them and for failing 18 to satisfy its duty to seek the best reasonably available terms to execute its customer orders. FAC 19 ¶ 71. Robinhood paid $65 million to settle. FAC ¶ 174. 20 Plaintiffs allege that Robinhood has experienced 70 outages or disruptions on its trading 21 platform between January 1, 2020, and November 30, 2020. FAC ¶ 75. For example, on March 2 22 and 3, 2020, when the Dow Jones Industrial Average experienced the then-largest point gain in its 23 history, the Robinhood platform collapsed when the market opened and was inoperable for over a 24 day. FAC ¶ 76. Plaintiffs allege that Robinhood’s help center was also inadequate in addressing 25 customer concerns. FAC ¶ 77. On July 30, 2021, Robinhood conducted an initial public offering 26 (“IPO”) and offered 55 million shares of common stock to the public at a price of $38 per share 27 for proceeds of over $2 billion. FAC ¶ 3. Prior to the IPO, Robinhood released the Registration 1 ¶ 1; Docket No. 78-2 Exh. 1 (Registration Statement); Exh. 2 (Prospectus). The Registration 2 Statement first describes Robinhood’s company mission, revenue model, and future goals:

3 Our mission is to democratize finance for all.

4 Robinhood was founded on the belief that everyone should be welcome to participate in our financial system. We are creating a 5 modern financial services platform for everyone, regardless of their wealth, income or background. 6 . . . We use technology to deliver a new way for people to interact 7 with the financial system. We believe investing should be familiar and welcoming, with a simple design and an intuitive interface, so 8 that customers are empowered to achieve their goals. We started with a revolutionary, bold brand and design, and the Robinhood app 9 now makes investing approachable for millions.

10 . . .

11 Built for People. Customer feedback is at the heart of product development at Robinhood. In the early days, our founders would 12 walk the campus of Stanford sharing product and design ideas and gathering real-time feedback. Today, we continue this tradition in a 13 programmatic way, seeking customer perspectives to inform our priorities and inspire our innovation. We want to understand our 14 customers and their expectations, ambitions, fears and challenges. Their insights help us focus on what is important and this approach 15 enables us to expand our offering centered on their needs. Many of our customers are new to investing, and we are encouraged to see 16 them taking their first steps toward wealth creation. We have replaced confusing jargon with simplicity and slang. Our tools are 17 delightful and engaging.

18 . . .

19 Future Vision. Our vision is for Robinhood to become the most trusted and most culturally relevant money app worldwide. We 20 innovate at the epicenter of finance, technology and access for all. As we look to the future, we want to help Robinhood customers 21 manage all aspects of their financial lives in one place. We envision them moving seamlessly between investing, saving and spending all 22 on the Robinhood platform. When we check our email, there is a go- to app. When we need a map, there is a go-to app. We envision a 23 world in which Robinhood is that go-to app for money. We believe people want to build financial independence and have the tools and 24 ability to own their financial well-being. We look forward to being our customers' single money app that enables them to achieve those 25 goals. 26 Registration Statement at 1–4. The document then describes “Trends in Our Favor” (including 27 “Technology is Transforming Customer Expectations” and “Increasing Participation in the 1 Registration Statement at 4-5. The Registration Statement also includes consolidated historical 2 || financial and operating data for the fiscal years ended December 31, 2019, and December 31, 3 2020, as well as the first and second quarters of 2021. See Registration Statement at 24. For these 4 || two years, Robinhood’s key performance indicators (“KPIs”) increased, as summarized in a series 5 of a charts (visuals generated by Plaintiffs) as follows: 6 MAU (IN MILLIONS) 7 25 21.3 8 20 17.7 SS 9 * 17 = = 10 to — == =—= . 43 ——— = SS 11 — — SS SS 5 = = □□ =—= 12 2019 (A) 2020 [A] 1021 (A} 2021 {E)

13 FAC 4 5 (monthly active users).

© TOTAL REVENUE (IN MILLIONS) 2 15 600 560.0 Sam . §22.2 = 16 son Be = 75 = = 18 mr »BBEEE 19 100 sei (717 77.50 722 = = = = = = 20 pBEBEBEBEEEEES 1019) 2019) 43019 #4019 1070 2020 30270 4020 1021 2021/(E) 21 (a) fA) A) ADs A) A ADA) A 22 || FAC {| 6 (revenue growth).

24 25 26 /// 27 28 ///

1 TOTAL AUC (IN BILLIONS) 120,000.0 2 102,035 100,000.06 _—— 3 80,932.4 0,000.0 —— 4 62,9785 —— 60,000.0 =——_—- — 5 40,000.0 = 6 20,000.0 14,135.6 ; = = = = 2019 (A) 2020 (A) 1021 (A) 2021 (E) 8 FAC 4 7 (total assets under custody). 9 10 AUC BY ASSET TYPE (IN MILLIONS) 1 1 BeEquities BOptions BCrypto 70,000.00 65,076.7 12 60,000.00 52.9831 = 50,000.00 > 13 = = 40,000.00 = =>

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Golubowski v. Robinhood Markets, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/golubowski-v-robinhood-markets-inc-cand-2023.