(Breach of Fiduciary Duty)   (Negligence)   40.  The proposed Class is defined as:  All former and current Customers of Robinhood in the United States and its  territories who were affected by Robinhood’s failure to prevent customers  from using its interface for stocks which were subject to a T1 Halt at any  time (a) within 4 years preceding the filing of this lawsuit (the “Class  Period”).   41.  Excluded from the Class are Robinhood, its parents, subsidiaries, affiliates, officers  and directors, any entity in which Robinhood has a controlling interest, all Customers who make  a timely selection to be excluded, governmental entities, all judges assigned to hear any aspect of  this litigation, as well as their immediate family members, and any of the foregoing’s legal heirs  and assigns.   42.  Plaintiff reserves the right to modify or amend the definition of the proposed Class  before the Court determines whether certification is appropriate.   43.  Plaintiff does not currently know the exact number of Class Members or their  identities because such information is in the exclusive control of Robinhood and can only be  ascertained by review of its records. However, Plaintiff believes that there are thousands of Class  Members, and that the Class Members are sufficiently numerous and geographically dispersed so  that joinder of all Class Members is impracticable. Plaintiff further believes that Robinhood failed  to prevent customers from using its interface for stocks subject to T1 holds during the Class Period.  Accordingly, it is believed that the amount in controversy easily exceeds $5,000,000.00.   45.  The factual basis of Robinhood’s misconduct is common to all Class Members and  resulted in injury to all Class Members.   46.  There are numerous questions of law and fact common to the Class and those  common questions predominate over any questions affecting only individual Class Members,  including whether Robinhood:  a.  Was negligent by not preventing its customers from using its  interface on stocks that were subject to a T1 halt; and  b.  the appropriate measure of damages sustained by Plaintiff and other  Class Members.   47.  A class action is superior to other methods for the fair and efficient adjudication of  this controversy. Treatment as a class action will permit a large number of similarly situated  persons to adjudicate their common claims in a single forum simultaneously, effectively, and  without the duplication of effort and expense, and risk of inconsistent rulings that numerous  individual actions would cause. Class treatment will also permit the adjudication of relatively small  claims by Class Members who otherwise might not be able to afford to litigate their claims  individually. This class action presents no difficulties in management that would preclude  maintenance as a class action.   48.  This forum is particularly desirable for the prosecution of this class action because  Robinhood maintains its regional headquarters in Lake Mary, Florida, and the lead Plaintiff is also  domiciled in Florida. As a result of the foregoing, litigating on a class action basis in this forum  will likely decrease the cost of discovery and prosecution, generally.   50.  Finally, the Class is readily definable and is one for which records likely exist in  the files of Robinhood.  51.  Plaintiff re-alleges paragraphs 1 through 50, above, as if fully set forth herein.   52.  Plaintiff brings this negligence claim on her own behalf, and on behalf of all Class  Members who were injured by Robinhood’s failure to prevent customers from using its interface  for stocks that are undergoing a trade halt within four (4) years preceding the filing of this lawsuit.   53.  As a securities broker-dealer, Robinhood owed its targeted customers a duty of care  in accordance with the standard of care used by similar professionals in the community under  similar circumstances using their deliberately engineered interface to facilitate specific  transactions and receipt of information for the “newcomer” to stocks. That includes, but is not  limited to, a duty to prevent customers from using its interface for stocks that are subject to a T1  Halt.   54.  Robinhood breached its duty, and the standard of care expected from similar  professionals in the community under similar circumstances by allowing customers to use its  interface for stocks that were subject to a T1 Halt.    56.  As a result of Robinhood’s failure to prevent its targeted customers from using its  interface for stocks that were subject to a T1 Halt, the Plaintiff (and all Class Members) used  Robinhood’s interface on stocks that were subject to high volatility.    57.  Once the T1 Halt was lifted, the result was a loss of money to the Plaintiff (and all  Class Members).    58.  As a direct and proximate result of the foregoing, Plaintiff (and all Class Members)  have suffered damages.  59.  Plaintiff re-alleges paragraphs 1 through 50, above, as if fully set forth herein.   60.  Robinhood owed a duty to Plaintiff and the Class Members as its fiduciary to inform  them of information surrounding certain stocks, as it advertised to, and provided this service for, its  customers. This is especially true since it advertised to the novice stockholder. This duty included  informing customers of T1 Halts.    61.  Robinhood breached this duty by not informing customers of the T1 Halts and by  not preventing them from using its interface for certain stocks not available because of the T1 Halts.   62.  Its breaches of fiduciary duties were committed directly against and directly  damaged Plaintiff and the Class Members, and they have suffered actual damages.    CASE NO.:   SHTERNA PINCHASOV, on her own behalf,   and on behalf of those similarly situated,  Plaintiff  Shterna Pinchasov Plaintiff Case #   Judge     vs. Robinhood Financial, LLC Defendant II.