Lavale Burns v. UP Fintech Holding Limited

CourtDistrict Court, S.D. New York
DecidedMarch 27, 2025
Docket1:24-cv-01632
StatusUnknown

This text of Lavale Burns v. UP Fintech Holding Limited (Lavale Burns v. UP Fintech Holding Limited) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lavale Burns v. UP Fintech Holding Limited, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK LAVALE BURNS, individually and on behalf of all others similarly situated, Plaintiff, -against- 24-CV-1632 (JGLC) UP FINTECHUP FINTECH HOLDING OPINION AND ORDER LIMITED, TIANHUA WU, and JOHN FEI ZENG., Defendants.

JESSICA G. L. CLARKE, United States District Judge: Plaintiff Lavale Burns brings this action on behalf of all persons and entities who purchased or acquired shares of UP Fintech Holding Limited between April 29, 2020 and May 16, 2023. Each year, UP Fintech, an integrated financial technology platform that offers online brokerage services internationally, including in China, files annual reports with the Securities and Exchange Commission. From 2019 through 2022, the company’s annual reports stated that it was in compliance with securities laws and regulations in China, notwithstanding substantial uncertainties in the legal and regulatory landscape there. Beginning in 2021, a series of news articles were published suggesting that UP Fintech’s operation without a license may be in violation of Chinese laws and regulations. After the articles were published, UP Fintech’s share price decreased substantially. UP Fintech did not receive any formal notice of noncompliance until December 2022, and in January 2023, the law in China was changed to explicitly require companies like UP Fintech to operate with a license. On June 20, 2023, Plaintiff filed a complaint naming UP Fintech and two of its chief officers as Defendants, asserting that the company made numerous false and misleading representations and half-truths regarding the legality of UP Fintech’s operations in China and the risk it imposed on Plaintiff and all other similarly situated persons who held securities in the company. Plaintiff brings claims under the Securities Exchange Act Sections 10(b) and 20(a), and under Rule 10b-5. Defendants now seek dismissal of the complaint, arguing that none of their statements were false or misleading. The Court agrees. The disclosures adequately warned

investors of the risks and uncertainties in the legal landscape in China. Plaintiff fails to plausibly allege that the Company knew more than what it disclosed about the risks or that the disclosures were otherwise false or misleading. For these reasons and those stated below, the Court GRANTS Defendant UP Fintech’s motion to dismiss, but GRANTS Plaintiff leave to amend the complaint. BACKGROUND The facts are primarily set forth as alleged in the Amended Complaint, ECF No. 73,1 and are viewed in the light most favorable to Plaintiff. See Okoh v. Sullivan, 441 F. App’x 813 (2d Cir. 2011) (“Under Rule 12(b)(6), we construe the complaint liberally, accepting all factual allegations in the complaint as true, and drawing all reasonable inferences in the plaintiff’s

favor.”). The Court also considers documents incorporated into the Amended Complaint by reference. See Chambers v. Time Warner, Inc., 282 F.3d 147, 153 (2d Cir. 2002) (“[T]he complaint is deemed to include any written instrument attached to it as an exhibit or any statements or documents incorporated in it by reference.”) (internal citations and quotations omitted). “Even where a document is not incorporated by reference, the court may nevertheless consider it where the complaint relies heavily upon its terms and effect, which renders the document integral to the complaint.” Id.

1 All ¶ references herein refer to the Amended Complaint (“Am. Compl.”) unless otherwise noted. I. Facts A. UP Fintech’s Business UP Fintech Holding Limited (“UP Fintech” or the “Company”) is an integrated financial technology platform that provides cross-market, multi-product investment opportunities for

global investors. ¶¶ 2, 19. The Company’s revenue is derived from customer commission fees for securities trading, earned interest income, or financing services fees. ¶¶ 3, 20. Defendant Tianhua Wu (“Wu”) has been the Company’s Chief Executive Officer since January 2018, and Defendant John Fei Zeng (“Zeng,” together with Wu, the “Individual Defendants”) has been the Company’s Chief Financial Officer since October 2018. ¶¶ 10–12. Both Individual Defendants, as senior executives or directors of the Company, were privy to confidential and proprietary information during the Class Period. ¶ 14. Furthermore, the Individual Defendants “were able to, and did, directly or indirectly, control” UP Fintech’s business activities. ¶ 15. B. Disclosure Reports From 2019 to 2022, UP Fintech filed its Annual Reports on Form 20-F with the Securities

Exchange Commission (“SEC”). ¶¶ 21, 28, 35, 45. Each Annual Report was “signed by Defendants Wu and Zeng, attesting to the accuracy of financial reporting, the disclosure of any material changes to the Company’s internal controls over financial reporting, and the disclosure of all fraud.” Id. The Annual Reports from 2019 through 2021 contain nearly identical risk disclosure statements with respect to the Company’s operations in People’s Republic of China (“China” or “PRC”). ¶¶ 22, 29, 36. The statements began by articulating that the Company might not be able to obtain or maintain the necessary licenses for their activities in multiple jurisdictions, especially in PRC. Id. They then acknowledge that while the regulatory authorities in China might take the position that UP Fintech was required to obtain licenses, the Company’s legal counsel advised that the Company’s activities did not require a securities brokerage license or permit. Id. Then, the reports communicated the potential for new laws and regulations to impact the Company’s business and stressed that there may be substantial uncertainty regarding their

application to UP Fintech. Id. In a subsequent paragraph, the statements described an investor alert posted by the China Securities Regulation Commission (“CSRC”) on their website in July of 2016. Id. The post warned that, except for select investment channels that have been approved by the CSRS, all other institutions that provided services for Chinese investors to participate in oversees securities trading were not approved. Id. The statement continued to explain that in September 2016, UP Fintech received a rectification notice from the Beijing branch of the CSRC. Id. The Company’s statements indicate that it took action to comply with the CSRC’s requirements and provided the relevant information to the authorities. Id. The Company disclosed that it could not make assurances it would not be subject to further investigation and that additional rectifications might

adversely affect the business. Id. Finally, the statement explained that if the Company was required to and could not obtain necessary approvals, the Company might fail to develop new business, be fined, have gains confiscated, have activities suspended, or be subject to claims for compensation of any economic loss suffered by customers or other parties. Id. The 2019–2021 Annual Reports also contained a disclosure section regarding Chinese security laws. ¶¶ 24, 31, 41. The section acknowledged that if UP Fintech did not comply with the laws and regulations of the PRC, penalties, confiscation of illegal proceeds, fines, or termination of business may result. Id. Another section noted that the Company is subject to a myriad of regulatory bodies, though it did not specifically identify China or the CSRC as one of them. ¶¶ 26, 33, 43. Additionally, the Company expressed that compliance turned upon UP Fintech’s internal system of compliance but despite this, “violations could still occur.” Id. Both the 2021 and 2022 Annual Reports included additional paragraphs about potential intervention by the Chinese Government. ¶¶ 39, 50. The 2021 Annual Report noted that the PRC

government had recently indicated an “intent to exert more oversight and control over overseas securities offerings” that could adversely affect UP Fintech at any time. ¶ 39.

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