Case 2:21-cv-01079-SMB Document 1 Filed 06/21/21 Page 1 of 30 WOLF HALDENSTEIN ADLER 1 FREEMAN & HERZ LLP Matthew M. Guiney (pro hac vice to follow) 2 270 Madison Ave. New York, NY 10016 3 Tel.: (212) 545-4600 4
[email protected] 5 LYNCH DASKAL EMERY LLP 137 W. 25th St. 6 New York, NY 10001 7 Tel.: (212) 302-2400 8 Attorneys for Plaintiffs Rong Zhang, Xiaodan Wang, and 9 Chong Shen Raphanella and Proposed Lead Counsel for the Class 10 11 IN THE UNITED STATES DISTRICT COURT 12 FOR THE DISTRICT OF ARIZONA 13 Rong Zhang, Xiaodan Wang, and Chong No. CV-_______________ 14 Shen Raphanella, individually and on behalf of all others similarly situated, 15 CLASS ACTION COMPLAINT 16 Plaintiffs, v. 17 Voice of Guo Media, Inc., GTV Media 18 Group, Inc., Saraca Media Group Inc., Rule 19 of Law Foundation III, Inc., Rule of Law Society IV Inc., Sara Wei a/k/a Lihong Wei 20 Lafrenz, and Wengui Guo a/k/a Miles Guo 21 a/k/a Ho Wan Kwok a/k/a Miles Kwok a/k/a Nan Wu a/k/a Haoyun Guo. 22 Defendants. 23 24 25 26 27 28 Case 2:21-cv-01079-SMB Document 1 Filed 06/21/21 Page 2 of 30 1 Plaintiffs Rong Zhang, Xiaodan Wang, and Chong Shen Raphanella (“Plaintiffs”), 2 individually and on behalf of all other persons similarly situated, by the undersigned 3 attorneys, allege the following based upon personal knowledge as to themselves and their 4 own acts, and upon information and belief as to all other matters based upon, inter alia, 5 the investigation conducted by and through their attorneys, which included, among other 6 things, a review of the defendants’ public documents, announcements made by 7 defendants, wire and press releases, public filings on judicial dockets, and information 8 readily available on the Internet.