Case 5:20-cv-01769 Document 1 Filed 03/12/20 Page 1 of 72 1 THE RESTIS LAW FIRM, P.C. William R. Restis, Esq. (SBN 246823) 2
[email protected] 402 W. Broadway, Suite 1520 3 San Diego, California 92101 Telephone: +1.619.270.8383 4 Counsel for Plaintiff and the Putative Class 5 [Additional Counsel Listed On Signature Page] 6 7 8 9 10 UNITED STATES DISTRICT COURT 11 12 FOR THE NORTHERN DISTRICT OF CALIFORNIA 13 SAN JOSE DIVISION 14 ALEXANDER ADAME, individually and on Case No: 15 behalf of all others similarly situated, 16 Plaintiff, CLASS ACTION COMPLAINT 17 v. 18 DEMAND FOR JURY TRIAL ROBINHOOD FINANCIAL, LLC, a Delaware 19 limited liability company, ROBINHOOD SECURITIES, LLC, a Delaware limited liability 20 Company, and ROBINHOOD MARKETS, INC., a Delaware corporation, 21 22 23 Defendants. 24 25 26 27 28 CLASS ACTION COMPLAINT Case 5:20-cv-01769 Document 1 Filed 03/12/20 Page 2 of 72 1 Plaintiff Alexander Adame (“Plaintiff”), individually and on behalf of all others similarly 2 situated, brings this putative Class aCtion against Defendants Robinhood Financial, LLC 3 (“Robinhood Financial”), Robinhood SeCurities, LLC (“Robinhood SeCurities”), and Robinhood 4 Markets, Inc. (“Robinhood Markets”) (colleCtively, “Robinhood”), demanding a trial by jury. 5 Plaintiff makes the following allegations pursuant to the investigation of Counsel and based upon 6 information and belief, except as to the allegations speCifiCally pertaining to himself, whiCh are 7 based on personal knowledge. ACCordingly, Plaintiff alleges as follows: 8 NATURE OF THE ACTION 9 1. Robinhood is an online brokerage firm.