Stacey M. Kaplan

This securities fraud class action arises out of Defendants’ misrepresentations and omissions made in connection with Coinbase going public in April 2021 (the “Direct Listing”). The Direct Listing generated tremendous excitement because Coinbase was the first cryptocurrency exchange to become publicly-traded in the United States. As alleged, Coinbase’s financial success hinged almost entirely on its ability to increase and maintain its customer base, particularly its retail users, which in turn drove transaction fee revenue. Transaction fee revenue accounted for nearly all of the Company’s revenues.

Unbeknownst to investors, however, during the run up to the Direct Listing and all relevant times thereafter, Defendants failed to disclose numerous material facts and risks to investors, all of which imperiled Coinbase’s financial success. Defendants failed to disclose the material risks arising from Coinbase’s inability to safeguard custodial assets in the event of bankruptcy. That is, that in the event Coinbase went bankrupt, Coinbase customers could lose some or all of their assets stored with the Company. Indeed, Coinbase would later admit on May 10, 2022, that the Company’s inability to protect its customers’ crypto assets from loss in the event of bankruptcy made it likely that customers would find the Company’s custodial services more risky and less attractive, which could result in a discontinuation or reduction in use of the Coinbase platform.

Plaintiffs also allege that during this same period, Defendants continuously misled investors about the severe regulatory risks that threatened Coinbase’s U.S. business. Prior to the Direct Listing, the SEC was clear that many digital assets in the marketplace were securities under existing federal law. Given the substantial number of digital assets Coinbase made available on its trading platform, and its increased focus on offering “staking” and its “Coinbase Wallet” product, the Company’s susceptibility to adverse regulatory action grew exponentially throughout the Class Period. As alleged, despite Defendants’ knowledge of the critical consequences arising from an SEC enforcement action, Defendants nevertheless denied listing securities on Coinbase’s platform, and assured investors that Coinbase was in compliance with existing federal securities laws and positively engaged with regulators.

On July 25, 2022, Bloomberg reported that in May 2022, the SEC began investigating Coinbase for listing securities and for potential violations of the federal securities laws. Thereafter, on March 22, 2023, Coinbase disclosed that the SEC issued it a Wells Notice for potential securities fraud violations, which were formally alleged in a complaint filed by the SEC on June 6, 2023. In response to these disclosures, including the May 10 revelation, Coinbase’s stock price dropped, causing significant losses and damages to Coinbase’s investors.

On July 20, 2023, Plaintiffs filed a second amended complaint on behalf of a putative class of investors alleging that Defendants violated Sections 10(b) and 20(a) of the Securities Exchange Act of 1934, and Sections 11, 12(a)(2), and 15 of the Securities Act of 1933. After briefing the motion to dismiss the second amended complaint, on September 5, 2024, the Court denied in part and granted in part Coinbase’s motion to dismiss. Thereafter, Defendants moved for judgment on the pleadings and to certify for interlocutory review the Court’s September 5, 2024 motion to dismiss order. On September 30, 2025, the Court denied in part and granted in part the motion for judgment on the pleadings, and denied the interlocutory motion. On October 21, 2025, Plaintiffs filed the third amended complaint. The parties are currently engaged in motion to dismiss briefing on that complaint.

Read Amended Consolidated Class Action Complaint Here

Read Second Amended Consolidated Class Action Complaint Here 

Read Court’s September 4, 2024 Opinion Here

Read Court’s September 30, 2025 Opinion Here 

Read Plaintiffs’ Third Amended Complaint Here

This securities fraud class action arises out of misrepresentations and omissions made by former executives of First Republic Bank (“FRB” or the “Bank”) and FRB’s auditor, KPMG LLP, about significant risks faced by FRB that led to its dramatic collapse in May 2023, the second largest bank collapse in U.S. history.

FRB was a California-based bank that catered to high-net worth individuals and businesses in coastal U.S. cities. Leading into and during the Class Period, FRB rapidly grew in size: in 2021 alone, FRB grew total deposits by 36% and total assets by 27%. In 2022, FRB grew by another 17%, exceeding $200 billion in total assets.  During this period, Defendants assured investors that the Bank’s deposits were well-diversified and stable. Defendants also assured investors that they were actively and effectively mitigating the Bank’s liquidity and interest rate risks.

The Complaint alleges that Defendants failed to disclose material risks associated with the Bank’s deposit base and with respect to Defendants’ management of liquidity and interest rate risk. In contrast to Defendants’ representations regarding the safety and stability of FRB, the Complaint alleges that Defendants relied on undisclosed sales practices to inflate the Bank’s deposit and loan growth, including, for example, by offering abnormally low interest rates on long-duration, fixed-rate mortgages in exchange for clients making checking deposits. And contrary to Defendants’ representations that they actively and responsibly managed the Bank’s interest rate risk, the Complaint details how Defendants continually violated the Bank’s interest rate risk management policies by concentrating the Bank’s assets in long-duration, fixed rate mortgages. In 2022, when the Federal Reserve began rapidly raising interest rates, the Bank’s low-interest, long-duration loans began to decline in value, creating a mismatch between the Bank’s assets and liabilities. Internally, FRB’s interest rate models showed severe breaches of the Bank’s risk limits in higher rate scenarios, and Defendants discussed potential corrective actions at risk management meetings. However, Defendants took no corrective action, continued to mislead investors about the Bank’s interest rate risk, and only amplified the Bank’s risk profile by deepening the Bank’s concentration in long-duration loans.

On October 14, 2022, investors began to learn the truth when FRB announced financial results for the third quarter of 2022, which showed that rising interest rates had begun to impact the Bank’s key financial metrics and that the Bank had lost $8 billion in checking deposits. Despite these trends, Defendants continued to reassure investors that Bank’s deposits were well-diversified and stable, that FRB had ample liquidity, and that rising interest rates would not limit the growth in FRB’s residential mortgage loan business. In FRB’s 2022 annual report (released in February 2023, and audited by KPMG), Defendants further claimed that, despite the Bank’s increasing interest rate risks, the Bank possessed the ability to hold its concentrated portfolio of long-duration loans and securities to maturity. The undisclosed risks materialized further on March 10, 2023, when peer bank Silicon Valley Bank failed and FRB experienced massive deposit withdrawals of up to $65 billion over two business days, constituting over 40% of the Bank’s total deposits. Defendants did not reveal these catastrophic deposit outflows to the market and instead reassured investors regarding the Bank’s liquidity position. In the ensuing weeks, FRB’s financial position unraveled further, resulting in multiple downgrades by rating agencies, and additional disclosures regarding the magnitude of FRB’s deposit outflows and the Bank’s worsening liquidity position. On May 1, 2023, FRB was seized by regulators and placed into receivership. These disclosures virtually eliminated the value of FRB’s common stock and preferred stock.

On February 13, 2024, Plaintiffs filed a 203-page complaint on behalf of a putative class of investors who purchased FRB common stock and preferred stock, alleging violations of Sections 10(b), 20(a), and 20A of the Securities Exchange Act of 1934. Defendants moved to dismiss. Additionally, the U.S. Federal Deposit Insurance Corporation, acting as receiver for First Republic Bank, intervened as a non-party and filed a separate motion challenging the Court’s jurisdiction. Briefing on these motions was completed last year, and the Court held oral argument on April 17, 2025. On June 10, 2025, the Court granted the FDIC’s motion and dismissed the case with prejudice. The Court ruled that the Financial Institution Reform, Recovery and Enforcement Act of 1989 (FIRREA) stripped the Court of subject matter jurisdiction due to an administrative exhaustion requirement. The Court did not address Defendants’ motions to dismiss related to the sufficiency of the allegations under the Exchange Act. The matter is currently on appeal.

This securities fraud class action asserts claims against GlaxoSmithKline plc (“GSK”), a multinational pharmaceutical and biotechnology company, its current CEO, Emma Walmsley, and its former CFO, Iain Mackay. On July 7, 2025, Lead Plaintiff filed the Consolidated Class Action Complaint against GSK and these executives pursuant to Sections 10(b) and 20(a) of the Exchange Act.

The case arises out of public representations that Defendants made during the Class Period concerning Zantac, a medication to treat heartburn, reflux, and ulcers. From the early 1980s through late-2019, GSK sold this drug to millions of consumers while allegedly knowing that its active ingredient, ranitidine, formed a carcinogenic substance known as “NDMA” both within and outside the human body. Following the revelation of the presence of this carcinogen and the drug’s removal from the market in 2019-2020, GSK faced an onslaught of litigation. Defendants, however, claimed that GSK was still “investigating” the source of the NDMA found in Zantac and assured investors that GSK’s financial and business risk associated with litigation related to Zantac was minimal.

Plaintiffs allege that the foregoing representations were materially false or misleading. In this regard, the Complaint alleges that Defendants manufactured Zantac while aware that the drug’s active ingredient formed a carcinogen, NDMA, when interacting with elements normally found in the human digestive system. In 1982, prior to Zantac’s initial FDA approval and public sale the following year, Dr. Richard Tanner, a GSK scientist, documented the degradation of Zantac into NDMA in the “Tanner Study.” Consequently, Defendants were aware prior to the FDA approval of Zantac that the drug’s active ingredient would form a carcinogen. Despite the FDA’s concerns and questions regarding this issue during the drug approval process, GSK dismissed the “possibility of carcinogenesis,” and concealed its knowledge of this carcinogen for decades. The Complaint alleges that the truth contained in the Tanner Study was first revealed to investors and the public following a February 15, 2023 publication of a Bloomberg Businessweek article entitled “Zantac Cancer Risk Data Was Kept Quiet by Manufacturer Glaxo for 40 years.”

In early 2019, an independent laboratory, Valisure, discovered that OTC Zantac contained significantly more NDMA than the FDA’s daily limit. Based on this finding, Valisure submitted a Citizen’s Petition to the FDA, requesting it be removed from the market. That same year, following Valisure’s revelation to the public of the unsafe levels of NDMA in Zantac, the FDA recalled the drug. However, for years thereafter, GSK continued to conceal from investors and the public the connection between Zantac and NDMA. In particular, Defendants made misrepresentations concerning: (1) GSK’s awareness of carcinogenic issues with Zantac before the FDA reached out in 2019; (2) GSK’s “exposure” to patient safety and product quality risks, which Defendants misleadingly claimed remained “unchanged,” even after GSK belatedly revealed the Tanner Study showing the connection between the drug and NDMA; (3) the FDA’s purportedly thorough reviews of Zantac’s safety, when GSK failed to disclose critical data to the FDA, including the Tanner Study; and (4) the range of GSK’s Zantac-related liability.

The relevant truth about the connection between NDMA and Zantac, as well as the potential liability for GSK, was revealed through a series of corrective events. First, on August 10, 2022, analysts revealed that GSK’s potential Zantac litigation exposure could be “in the $5-10 billion range.” Additionally, on August 11, 2022, analysts revealed that GSK would bear approximately 80% percent of the Zantac litigation liability—far from GSK’s representations that its risk exposure was “unchanged.” Next, on August 16, 2022, Defendant Mackay confirmed GSK’s exposure was significant, quantifying it to be in the “mid $ billions.” Following these disclosures, GSK’s stock price fell precipitously. The Complaint alleges that GSK’s investors suffered substantial losses as a result of Defendants’ misstatements and omissions being revealed to the market.

On September 5, 2025, Defendants moved to dismiss the Amended Complaint. Briefing on the motion is complete and pending before the Court.

Defendant Lucid designs, produces, and sells luxury EVs. This securities fraud class action arises out of Defendants’ misrepresentations and omissions regarding Lucid’s production of its only commercially-available electronic vehicle (“EV”), the Lucid Air, and the factors impacting that production.

To start the Class Period, on November 15, 2021, Defendants told investors that Lucid would produce 20,000 Lucid Airs in 2022. This was false, and Defendants knew it. According to numerous former Lucid employees, Defendants already knew then that Lucid would produce less than 10,000 units in 2022, and admitted this fact during internal meetings preceding the Class Period.  They also knew why Lucid could not meet this production target—the Company was suffering from its own unique and severe problems that were stalling production of the Lucid Air, including internal logistics issues, design flaws, and the key drivers of parts shortages.  These problems had not only prevented, but continued to prevent Lucid from ramping up production of the Lucid Air.

Despite the actual state of affairs at Lucid, on November 15, 2021, and at all times thereafter during the Class Period, Defendants concealed these severe, internal, Company-specific problems. At every turn, when asked about the pace of production, or to explain the factors causing Lucid’s production delays, Defendants blamed the Company’s woes on the purported impact of external, industrywide supply chain problems and repeatedly assured investors that the Company was “mitigating” that global impact. These misrepresentations left investors with a materially false and misleading impression about Lucid’s actual production and internal ability and readiness to mass produce its vehicles. Against that backdrop, Defendants then lied, time and again, about the number of vehicles Lucid would produce. Even when, in February 2022, Defendants announced a reduced production target of 12,000 to 14,000 units, they continued to point to purported industry-wide supply chain problems and once more assured the market that the Company was thriving in spite of such issues. When the truth regarding Lucid’s false claims about its production and the factors impacting that production finally emerged, Lucid’s stock price cratered, causing massive losses for investors.

On December 13, 2022, the Plaintiff filed a 138-page consolidated complaint on behalf of a putative class of investors alleging that Defendants Lucid, Rawlinson, and House violated 10(b) and 20(a) of the Securities Exchange Act. On February 23, 2023, Defendants filed a motion to dismiss. In August, the Court denied in part and granted in part Defendants’ motion to dismiss. On September 20, 2024, the Plaintiff filed an amended complaint. Defendants’ motion to dismiss the amended complaint is fully briefed. In May, the Court denied in part and granted in part Defendants’ motion to dismiss. The case is now in fact discovery.

This securities fraud class action brings claims against NVIDIA, the world’s largest maker of graphic processing units (GPUs), and its Chief Executive Officer Jensen Huang. The case arises out of Defendants’ efforts to fraudulently conceal the extent of NVIDIA’s reliance on GPU sales to cryptocurrency miners. Led by Öhman Fonder, one of Sweden’s largest institutional investors, the suit alleges that in 2017 and 2018, NVIDIA’s revenues skyrocketed when it sold a record number of GPUs to crypto miners. Plaintiffs allege that during this period, NVIDIA’s sales to crypto miners outpaced its sales to the company’s traditional customer base of video gamers. Yet Defendants misrepresented the true extent of NVIDIA’s cryptocurrency-related sales, enabling the company to disguise the degree to which its growth was dependent on the notoriously volatile demand for crypto.

Following the price collapse of Etherium, a leading digital token, in late 2018, investors began to learn of NVIDIA’s true dependence on sales to crypto miners. This culminated on November 15, 2018, when NVIDIA announced it was only expecting $2.7 billion in fourth quarter revenues (a 7% decline year-over-year) which it attributed to a “sharp falloff in crypto demand.” Market commentators expressed shock at the company’s about-face, and NVIDIA’s stock price fell precipitously, damaging investors by billions of dollars in market losses.

The action was filed in June 2019 on behalf of a putative class of investors alleging that Defendants violated Sections 10(b) and 20(a) of the Securities Exchange Act of 1934. After the District Court dismissed the complaint, Plaintiffs successfully appealed the dismissal to the U.S. Court of Appeals for the Ninth Circuit. On August 25, 2023, in a published decision, the Ninth Circuit reversed, holding that Plaintiffs had sufficiently alleged that Defendants “made materially false or misleading statements about the company’s exposure to crypto, leading investors and analysts to believe that NVIDIA’s crypto-related revenues were much smaller than they actually were.” The Ninth Circuit further held that the complaint sufficiently alleged that Defendants knew or were at least deliberately reckless as to the falsity of their statements.

Defendants filed a petition for a writ of certiorari to the U.S. Supreme Court challenging the Ninth’s Circuit’s decision. The Supreme Court granted the petition on June 17, 2024. Following extensive briefing and oral argument, on December 11, 2024, the Supreme Court dismissed the writ of certiorari as improvidently granted, paving the way for Plaintiffs to enter discovery and prosecute their case against Defendants before the District Court.

Plaintiffs subsequently filed a motion for class certification, which is fully briefed and was argued before the Court in November.  Fact discovery is ongoing.

Read the Ninth Circuit Opinion Here

Read the Supreme Court Decision Here

Plaintiffs bring this securities fraud class action under the Securities Exchange Act of 1934 (“Exchange Act”) and Securities Act of 1933 (“Securities Act”) against former executives and Board members of Silicon Valley Bank (“SVB” or the “Bank”), underwriters of certain of SVB’s securities offerings, and the Bank’s auditor, KPMG LLP (collectively, “Defendants”). The action centers on Defendants’ misrepresentations and omissions concerning the Bank’s deficient risk management, including its management of liquidity and interest rate risks. A post mortem report from the Federal Reserve ultimately found that these deficiencies were directly linked to the Bank’s collapse in March 2023.

The Exchange Act claims are brought on behalf of all persons and entities who purchased or otherwise acquired the common stock of Silicon Valley Bank Financial Group, the parent company of SVB, between January 21, 2021 and March 10, 2023, inclusive (the “Class Period”), and were damaged thereby. Specifically, Plaintiffs allege that throughout the Class Period, SVB’s CEO Gregory W. Becker and CFO Daniel Beck (the “Exchange Act Defendants”) made false and misleading statements and omissions regarding SVB’s risk management practices, and its ability to hold tens of billions of dollars in “HTM” securities to maturity.

Contrary to the Exchange Act Defendants’ statements, and unbeknownst to SVB investors, SVB suffered from severe and significant deficiencies in its risk management framework and, accordingly, could not adequately assess, measure, and mitigate the many risks facing the Bank, nor properly assess its ability to hold its HTM securities to maturity. As the Federal Reserve has outlined, SVB had a grossly deficient risk management program that posed a “significant risk” to “the Firm’s prospects for remaining safe and sound”; had in place interest rate models that were unrealistic and “not reliable”; employed antiquated stress testing methodologies; and had a liquidity risk management program that threatened SVB’s “longer term financial resiliency” by failing to ensure that the Bank would have “enough easy-to-tap cash on hand in the event of trouble” or assess how its projected contingency funding would behave during a stress event. Plaintiffs further allege that the Exchange Act Defendants were well aware of these deficiencies because, among other things, the Federal Reserve repeatedly warned the Exchange Act Defendants about the deficiencies and the dangers they posed throughout the Class Period.

The Securities Act claims are brought on behalf of all persons and entities who purchased or acquired SVB securities in or traceable to SVB’s securities offerings completed on or about February 2, 2021, March 25, 2021, May 13, 2021, August 12, 2021, October 28, 2021, and April 29, 2022 (the “Offerings”). Plaintiffs allege that the offering documents accompanying these issuances also contained materially false statements regarding the effectiveness of the Bank’s interest rate and liquidity risk management, and its ability to hold its HTM securities to maturity. Through these Offerings, SVB raised $8 billion from investors.

Investors began to learn the relevant truth concealed by Defendants’ misrepresentations and omissions in 2022, when Defendants reported that, contrary to their prior representations, the rising interest rate environment had caused an immediate impact to the Bank’s financial results and future estimates. On March 8, 2023, the relevant truth was further revealed when SVB announced that, due to short-term liquidity needs, the Bank had been forced to sell all of its available for sale securities portfolio for a nearly $2 billion dollar loss, and would need to raise an additional $2.25 billion in funding. Two days later, on March 10, 2023, the California Department of Financial Protection & Innovation closed SVB and appointed the FDIC as the Bank’s receiver. SVB has filed for bankruptcy, and Congress, the DOJ, the SEC, and multiple other government regulators have commenced investigations into the Bank’s collapse and the Exchange Act Defendants’ insider trading.

On January 16, 2024, Plaintiffs filed an amended operative complaint detailing Defendants’ violations of the federal securities laws. Defendants filed three separate motions to dismiss the complaint, which Plaintiffs opposed in May 2024. On June 13, 2025, U.S. District Judge Noël Wise denied all motions to dismiss in a 29-page opinion. The case is now in fact discovery.

This securities fraud action alleges that Defendants violated Section 10(b) of the Securities Exchange Act by affirmatively misleading investors about the reckless and undisclosed bet that Zillow Group, Inc. (“Zillow” or the “Company”) was taking with its Zillow Offers iBuyer business.

iBuyers use algorithms to estimate home values, and then make instant cash offers to purchase homes based on those estimated values. If a homeowner accepts, the iBuyer makes repairs and flips the home. Zillow entered the iBuyer business in 2018, launching Zillow Offers.  By 2021, however, Zillow Offers’ growth was lagging.  In an attempt to jumpstart it, Plaintiff alleges that in Spring 2021, Defendants undertook a series of drastic and risky actions, including applying large “overlays” on top of the values generated by Zillow’s pricing algorithms, which significantly increased purchase offers.  Not surprisingly, many homeowners accepted Zillow’s inflated offers and soon the Company was touting the “strong demand” for Zillow Offers to investors while concealing the risky overlays that had actually driven growth.

Within months, Defendants’ reckless bets caught up to them. By November 2, 2021, Zillow announced that it was shuttering Zillow Offers, taking a $569 million impairment charge because it had overpaid for 18,000 homes, and axing 25% of its workforce. In response, Zillow’s stock prices plummeted, causing significant investor losses. Market commentators expressed outrage, calling the announcement a “financial disaster,” a “debacle” and declaring that “management should be accountable.”

On May 12, 2022, Plaintiff filed the operative complaint (“Complaint”) in the action on behalf of a class of investors who purchased Zillow’s stocks, including its Class C capital stock and Class A common stock, from August 5, 2021 to November 2, 2021, inclusive. Defendants moved to dismiss the Complaint in its entirety on July 11, 2022.  On December 7, 2022, U.S. District Judge Thomas S. Zilly of the Western District of Washington denied Defendants’ motion as to all but one statement. The case is now in discovery. On August 12, 2024, the Court granted Plaintiff’s request for leave to file an amended complaint, which Plaintiff subsequently filed on August 16, 2024. On August 23, 2024, the Court granted Plaintiff’s motion for class certification, which was filed on March 14, 2024.

Read Consolidated Class Action Complaint Here

Read Order Granting Class Certification Here