Robinhood Markets, Inc. Jan. 2021 Short Squeeze (Securities)

Defendants violated 15 U.S.C § 78 by ways including:

a. effecting a series of transactions in the Subject Securities, creating actual or apparent active trading in such security, or raising or depressing the price of such security, for the purpose of inducing the purchase or sale of such security by others;

b. inducing the purchase or sale of the Subject Securities, by the circulation or dissemination in the ordinary course of business of information to the effect that the price of any such security will or is likely to rise or fall because of market operations of any one or more persons conducted for the purpose of raising or depressing the price of the Subject Securities;

c. making for the purpose of inducing the purchase or sale of the Subject Securities statements which were at the time and in the light of the circumstances under which it was made, false or misleading with respect to any material fact, and which Defendants knew or had reasonable ground to believe was so false or misleading,

d. including but not limited to that they presented an open market trading platform that
would continuously operate so that free market trading would occur;

e. effecting a series of transactions for the purchase and/or sale of the Subject Securities for the purpose of pegging, fixing, or stabilizing the price of the Subject Securities in contravention of such rules and regulations of the Securities and Exchange Commission;

f. effecting manipulative short sale of securities, including the Subject Securities;

g. violating the rules of the Commission to prevent manipulation of price levels of the equity securities market or a substantial segment thereof;

h. contributing significantly to extraordinary levels of volatility that have threatened
the maintenance of fair and orderly markets; and reasonably certain to engender such
levels of volatility;

i. effecting transactions in, or to induce or attempt to induce the purchase or sale of, any security-based swap, in connection with which such person engages in any fraudulent, deceptive, or manipulative act or practice, makes any fictitious quotation, or engages in any transaction, practice, or course of business which operates as a fraud or deceit upon any person. 15 U.S.C. § 78i;

j. effecting short sales, and using and employing stop-loss order in connection with the purchase or sale, of any security other than a government security, in contravention of such rules and regulations as the Commission may prescribe as necessary or appropriate in the public interest or for the protection of investors, 15 U.S.C. § 78j;

k. employing manipulative or deceptive device or contrivance in contravention of such rules and regulations as the Commission. 15 U.S.C. § 78j.