Securities And Exchange Commission v. Richman

District Court, N.D. California·Decided November 3, 2021·No. 3:21-cv-01911·Unknown

Opinion

1 2 3 4 5 IN THE UNITED STATES DISTRICT COURT 6 FOR THE NORTHERN DISTRICT OF CALIFORNIA 7 8 SECURITIES AND EXCHANGE Case No. 21-cv-01911-CRB COMMISSION, 9 Plaintiff, ORDER DENYING MOTION TO 10 DISMISS v. 11 JESSICA RICHMAN, et al., 12 Defendants. 13

14 The SEC alleges that Defendants Jessica Richman and Zachary Apte, co-founder’s 15 of uBiome, misled investors about fundamental aspects of uBiome’s business model 16 during the company’s Series C funding round. Complaint (“Compl.”) (dkt. 1). Defendants 17 move to dismiss the complaint, primarily arguing that the SEC fails to support its 18 allegations with the required specifics. Motion to Dismiss (“MTD”) (dkt. 38). After 19 carefully reviewing the parties’ briefs, the Court concludes that oral argument is not 20 necessary. For the reasons set forth below, the Court denies Defendants’ motion to 21 dismiss. 22 I. BACKGROUND 23 uBiome was a biotechnology company that focused on the human microbiome. 24 Compl. ¶¶ 14–15. The company developed tests that individual consumers could use to 25 receive diagnostics on the microorganisms present in their gut and genitals. Id. ¶ 15. The 26 test results could purportedly assist with the diagnosis and treatment of a range of medical 27 conditions, including inflammatory bowel disease and sexually transmitted infections. Id. 1 Richman and Apte co-founded uBiome in October 2012. Id. ¶¶ 12–14. During the 2 life of the company, Richman served as CEO and President, and Apte served as Chief 3 Scientific Officer and, at times, co-CEO.1 Id. Richman and Apte were hands-on managers 4 who “closely monitored and managed every aspect of uBiome’s operations together.” Id. ¶ 5 16. No “decision about a significant aspect of uBiome’s business was made without the 6 knowledge and approval of at least one of Richman or Apte.” Id. 7 The charges against Richman and Apte stem from events that began in 2015. Id. ¶¶ 8 17–18. Prior to 2015, uBiome developed and marketed tests for consumers, which 9 consumers paid for out of pocket. Id. ¶ 14. In 2015, uBiome shifted focus to developing 10 tests that could be billed to insurers because “uBiome would be able to charge insurers 11 significantly more money for the tests than it charged consumers.” Id. ¶¶ 17–18. Over the 12 next two years, uBiome developed and released SmartGut and SmartJane, both of which 13 the company described as covered by health insurance. Id. ¶ 19. 14 A. The Alleged Insurance Fraud 15 The thrust of the complaint is that Richman and Apte implemented and oversaw 16 certain improper practices to create the false appearance that SmartGut and SmartJane 17 qualified for insurance reimbursement and that, as a result, uBiome had strong prospects 18 for growth. The allegedly improper practices generally fall into two categories: (1) issues 19 related to uBiome’s doctor network and (2) misrepresentations to insurers. The complaint 20 alleges that Defendants knew or were reckless in not knowing that once these practices 21 came to light, insurers would “reject reimbursement claims for uBiome’s clinical tests,” 22 delivering a body blow to the company’s business model. Id. ¶ 21. 23 1. Doctor Network 24 The first set of allegedly improper practices centers around uBiome’s doctor 25 network. Id. ¶ 23. To qualify for reimbursement, insurers generally require that a 26 diagnostic test be ordered by a doctor. Id. ¶ 22. To meet this requirement, uBiome created 27 1 an online portal through which patients could connect with doctors to determine the 2 appropriateness of uBiome’s tests. Id. 3 The doctor network allegedly fell short of insurer standards in two ways. First, the 4 “default” set up was for doctors in the network to prescribe uBiome’s tests “based solely 5 on online questionnaire responses” without any live consultation. Id. ¶ 23. Prescribing 6 tests based solely on online questionnaires raised concerns about whether doctors were 7 prescribing tests without first establishing the requisite doctor-patient relationship. Id. 8 Shortly after the doctor network went live in July 2017, uBiome employees raised 9 this concern with Defendants. Id. ¶ 21. In summer of 2017, for example, the company’s 10 general counsel emailed defendants that “any tests prescribed based solely on consumers’ 11 questionnaires, versus a live consultation between consumer and doctor, would be a 12 reimbursement risk.” Id. ¶ 23. Not only did Defendants continue to use the doctor 13 network despite these concerns, they also allegedly “concealed” the network’s continued 14 use “from the general counsel and the uBiome board.” Id. 15 The second issue with the doctor network concerned tests of “dubious clinical 16 utility.” Id. ¶ 24. The tests of “dubious” utility involved re-testing of old samples that 17 consumers previously submitted. Id. Defendants allegedly orchestrated a scheme whereby 18 consumers were “broadly” advertised the option of retesting their samples. Id. When 19 consumers elected to retest an old sample, the consumer’s request was made to “appear to 20 be requests for tests on new samples” to network doctors. Id. As a result, “at Defendants’ 21 direction, uBiome resubmitted consumers’ originally reported symptoms to the doctors 22 reviewing retest requests as if they were newly reported symptoms.” Id. 23 The practice of presenting retests as requests for new tests also raised concerns 24 among employees. Id. ¶ 24. In 2017, for example, uBiome’s former lab director warned 25 that the “retests lacked ‘current clinical relevance’ and could be fraudulent.” Id. Again, 26 Defendants allegedly disregarded the concerns and continued the practice of retesting old 27 samples “from at least late 2017 through 2018.” Id. 2. Misrepresentations to Insurers 1 The second set of alleged improper practices involved misrepresentations to 2 insurers. The complaint includes specific and general examples of these alleged 3 misrepresentations. Specifically, Defendants learned in May 2018 that certain insurers 4 were requesting medical records “reflecting that doctors had contemporaneously consulted 5 with patients for the billed tests.” Id. ¶ 25. uBiome did not have such records, so 6 Defendants “directed company employees to create and backdate records to make it seem 7 as though doctor-patient consultations had occurred, and then to submit those fake records 8 to insurance companies.” Id. 9 More generally, the complaint alleges that Defendants engaged in various forms of 10 deceptive practices to obtain reimbursement from insurers. Id. ¶¶ 25–26. These practices 11 included billing for tests that had not been performed and “might never be performed 12 because the version of the test to be used had not been proved to work.” Id. ¶ 26. In 13 addition, Defendants oversaw the manipulation of billing codes, including directing 14 employees “to use incorrect insurance billing codes and/or vary the codes when billing for 15 the same type of test to avoid claims rejection, even though there was no legitimate basis 16 for doing so.” Id. 17 As with the doctor network and the practice of retesting old samples, employees 18 expressed worries about the legitimacy of the company’s practices with insurers, but 19 Defendants did not address the issues. Id. The concerns eventually began to extend 20 beyond employees, as multiple insurers began to challenge uBiome’s practices, including 21 one that alleged that the company was engaging in “fraud and abuse.” Id. ¶ 44. 22 B. The Series C Funding Round 23 The various forms of alleged insurance fraud were all underway when the company 24 began its Series C funding round in May 2018. Id. ¶ 34. And the complaint alleges that 25 Defendants’ false and misleading statements to investors during the Series C funding 26 round enabled the company to raise, and Defendants to make, millions of dollars. 27 Defendants’ alleged Series C misrepresentations generally fall into two buckets.

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