This case was last updated from PACER on 05/31/2021 at 08:36:51 (UTC).

Memic et al v. Markets, Inc. et al

Case Summary

On April 01, 2021, Carlos Ferreiro, Skyler Baird, Nermin Memic, and Bharat Thakkar (collectively, “Plaintiffs”), individually and on behalf of all others similarly situated, represented by Anuj Kapur of D. Miller & Associates, PLLC, filed a class action lawsuit against Robinhood Financial LLC, Robinhood Securities, LLC, Robinhood Markets, Inc., and DOES 1- 50, inclusive, (hereinafter collectively referred to as “Defendants” or “Robinhood”), seeking injunctive relief, punitive or exemplary damages with pre and post – judgement interest for restricting access to the open markets in publicly available securities. This case was filed in the U.S. District Court for the Southern District of Texas with Judge David Hittner presiding. 


“Plaintiffs seek relief on behalf of themselves and as a representative of all others who are similarly situated. Pursuant to Fed. R. Civ. P. Rules 23(a) and (b)(3), Plaintiffs seek certification of a Nationwide class defined. Plaintiffs hereby reserve the right to amend or modify the Class definitions with greater specificity or division after having had an opportunity to conduct discovery.”


In its complaint, the Plaintiffs alleged that, “Robinhood is an online brokerage firm that states its mission is to democratize finance for all. Upon information and belief, unbeknownst to Robinhood users and the market at large, Robinhood unilaterally removed tickers from its trading platform. This meant that retail investors could no longer purchase the rising tickers, or even search for them. Robinhood did this without providing notice to its users, or the market at large. These unilateral and unannounced acts did several things: (1) it locked Robinhood users into positions as the prices of these shares began to free fall; (2) It prevented Robinhood users for purchasing more shares at lower prices to average down their costs bases; (3) It prevented Robinhood users from shorting the stocks; and (4) It deprived the market for a large percentage of the retail market buying power causing all positions to free fall”.


The Plaintiffs further alleged that, “Defendants have completely blocked retailer investors from purchasing Restricted Tickers for no legitimate reason, thereby depriving retailer investors from the benefits of Robinhood’s services in giving access to the market. Additionally, for many users as their money was tied up with Robinhood they could not withdraw and simply trade positions on the day”.


There are five claims for relief laid down by the Plaintiffs. The first claim is for alleged breach of contract, because Robinhood allegedly breached the agreement by failing to provide advance notice of removal of heavily traded and highly profitable stock tickers and implementing the strictest restrictions on the same. The second claim is for alleged negligence, because Robinhood had a duty to exercise reasonable care to not manipulate the market. The third claim is for alleged breach of fiduciary duty. The fourth claim is for the alleged breach of duty of good faith and fair dealing. The fifth claim is for alleged breach of express and implied warranties. 


In its prayer for relief, the Plaintiffs have requested the court to issue immediate injunctive relief requiring Robinhood to reinstate all the retail tickers in question on their trading platform, an award for Plaintiffs and Class Members’ damages, an award for attorney’s fees and costs, punitive or exemplary damages according to proof, both prejudgment and post-judgment interest and such other relief as this Court may deem just and proper.


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Case Details Parties Documents Dockets


Case Details

  • Case Number:


  • Filing Date:


  • Case Status:

    Disposed - Other Disposed

  • Case Type:

    Finance - Security/Commodity/Exchange

Judge Details

Presiding Judge

David Hittner


Party Details


Carlos Ferreriro

Bharat Thakkar

Nermin Memic

Skylar Baird

Carlos Ferreiro

Skyler Baird


Robinhood Markets, Inc.

Robinhood Financial, LLC

Robinhood Securities, LLC

Does 1-50

Attorney/Law Firm Details

Plaintiff Attorney

Anuj Kapur

Attorney at D. Miller & Associates, PLLC

2610 W. Sam Houston Parkway South, Suite 200

Houston, TX 77042


Court Documents


1 #1

Civil Cover Sheet


2 #1


2 #2



3 #1


3 #2






Docket Entries

  • 04/16/2021
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  • Docket(#6) RECEIPT of Transfer Letter re: transfer of case to Southern District of Florida. New Case # assigned: 1:21cv21479 and received on 4/16/2021., filed. (mmapps, 4) (Entered: 04/16/2021)

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  • 04/15/2021
  • DocketInterdistrict transfer to Southern District of Florida. Case transferred electronically. (lgouadi, 4) (Entered: 04/15/2021)

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  • 04/15/2021
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  • Docket(#5) JPML CONDITIONAL TRANSFER ORDER (CTO-3) transferring case to Southern District of Florida to be included in MDL Docket No. 2989. (lgouadi, 4) (Entered: 04/15/2021)

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  • 04/02/2021
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  • Docket(#4) ORDER for Initial Pretrial and Scheduling Conference and Order to Disclose Interested Persons. Initial Conference set for 6/2/2021 at 10:30 AM in Courtroom 703 before Magistrate Judge Peter Bray. (Signed by Judge David Hittner) Parties notified.(JacquelineMataadi, 4) (Entered: 04/02/2021)

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  • 04/02/2021
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  • Docket(#3) Summons Issued as to All Defendants. Issued summons delivered to plaintiff by NEF, filed. (Attachments: #1 Summons, #2 Summons)(JosephWells, 4) (Entered: 04/02/2021)

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  • 04/01/2021
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  • Docket(#2) Request for Issuance of Summons as to All Defendants, filed. (Attachments: #1 Envelope, #2 Envelope)(Kapur, Anuj) (Entered: 04/01/2021)

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  • 04/01/2021
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  • Docket(#1) COMPLAINT against All Defendants (Filing fee $ 402 receipt number 0541-26207722) filed by Skylar Baird. (Attachments: #1 Civil Cover Sheet)(Kapur, Anuj) (Entered: 04/01/2021)

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