This case was last updated from PACER on 09/15/2021 at 08:34:17 (UTC).

Sandoz v. Waterdrop Inc. et al

Case Summary

On September 14, 2021, Sidney Sandoz (“Plaintiff”), individually and on behalf of all others similarly situated, represented by Samuel Howard Rudman of Robbins Geller Rudman & Dowd LLP, filed a civil action against Waterdrop Inc. (“Waterdrop” or the “Company”), Peng Shen (“Shen”), Kangping Shi, Nina Zhou, Kai Huang, & others, (collectively, the “Defendants”), seeking declaratory and compensatory relief, including interest thereon, as well as reasonable costs and expenses, for allegedly issuing Registration Statement, in connection with the IPO, which contained materially incorrect or misleading statements and/or omitted material information that was required to be disclosed. This case was filed in U.S. District Court in the Southern District of New York. 

 

In the complaint, Plaintiff alleged that, “On April 16, 2021, the Company filed with the SEC a registration statement on Form F-1 for the IPO, which, after an amendment, was declared effective on May 6, 2021 (the “Registration Statement”). On May 7, 2021, the Company filed with the SEC a prospectus for the IPO on Form 424B4, which incorporated and formed part of the Registration Statement. The Registration Statement was used to sell to the investing public 30 million Waterdrop ADSs at $12 per ADS. Defendants generated US$360 million in gross offering proceeds from their sale of Waterdrop ADSs in the IPO.”

 

Plaintiff further alleged that, “The Registration Statement was negligently prepared and, as a result, contained untrue statements of material fact, omitted material facts necessary to make the statements contained therein not misleading, and failed to make adequate disclosures required under the rules and regulations governing the preparation of such documents.”

 

Plaintiff also alleged that, “Specifically, the Registration Statement failed to disclose that Waterdrop was the subject of an intense regulatory investigation and pending crackdown by Chinese authorities because of a variety of market abuses perpetrated by the Company used to artificially inflate Waterdrop’s short-term financial results in the lead up to the IPO, including, inter alia: (i) operating insurance platforms without proper governmental authorizations; (ii) mispricing risks for consumers; and (iii) illicitly using client information. Indeed, unbeknownst to investors, the reason that Waterdrop had discontinued its mutual aid segment was because it had been ordered to do so by Chinese regulators. Furthermore, Waterdrop had suffered rapidly accelerating operating losses in the first quarter of 2021 – completed weeks before the IPO.”

 

Plaintiff lists out two claims for relief. The first claim is against all Defendants for violation of §11 of the 1933 Act, and the second claim is against all Defendants except the underwriter Defendants and Defendant De Vries for violation of §15 of the 1933 Act. 

 

In her prayer for relief, Plaintiff requested the court to determine that this action is a proper class action, and award compensatory damages in favor of Plaintiff and the other class members against all Defendants, jointly and severally, for all damages sustained as a result of Defendants’ wrongdoing, in an amount to be proven at trial, including interest thereon, and reasonable costs and expenses incurred in this action. Further, Plaintiff requested the court to  further award such equitable/injunctive or other relief as the court may deem just and proper including permitting any putative class members to exclude themselves by requesting exclusion through noticed procedures.

 

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Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    1:21-CV-07683

  • Filing Date:

    09/14/2021

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Finance - Security/Commodity/Exchange

 

Party Details

Plaintiff

Sidney Sandoz

Defendants

Waterdrop Inc.

Peng Shen

Kangping Shi

Nina Zhou

Kai Huang

Haiyang Yu

Yao Hu

Guang Yang

Colleen A. De Vries

Cogency Global Inc.

Goldman Sachs (Asia) L.L.C.

Morgan Stanley & Co. LLC

BofA Securities, Inc.

China Merchants Securities (HK) Co., Limited

CLSA Limited

Haitong International Securities Company Limited

Attorney/Law Firm Details

Plaintiff Attorney

Samuel Howard Rudman

Attorney at Robbins Geller Rudman & Dowd LLP (LI)

58 South Service Road, Suite 200

Melville, NY 11747

 

Court Documents

#3

(#3) REQUEST FOR ISSUANCE OF SUMMONS as to Waterdrop Inc., Peng Shen, Kangping Shi, Nina Zhou, Kai Huang, Haiyang Yu, Yao Hu, Guang Yang, Colleen A. De Vries, Cogency Global Inc., Goldman Sachs (Asia) L.L.C., Morgan Stanley & Co. LLC, BofA Securities, Inc., China Merchants Securities (HK) Co., Limited, CLSA Limited and Haitong International Securities Company Limited, re: #1 Complaint,. Document filed by Sidney Sandoz..(Rudman, Samuel) (Entered: 09/14/2021)

#2

(#2) CIVIL COVER SHEET filed..(Rudman, Samuel) (Entered: 09/14/2021)

#1

(#1) COMPLAINT against BofA Securities, Inc., CLSA Limited, China Merchants Securities (HK) Co., Limited, Cogency Global Inc., Colleen A. De Vries, Goldman Sachs (Asia) L.L.C., Haitong International Securities Company Limited, Yao Hu, Kai Huang, Morgan Stanley & Co. LLC, Peng Shen, Kangping Shi, Waterdrop Inc., Guang Yang, Haiyang Yu, Nina Zhou. (Filing Fee $ 402.00, Receipt Number ANYSDC-25061013)Document filed by Sidney Sandoz..(Rudman, Samuel) (Entered: 09/14/2021)

 

Docket Entries

  • 09/14/2021
  • View Court Documents
  • Docket(#3) REQUEST FOR ISSUANCE OF SUMMONS as to Waterdrop Inc., Peng Shen, Kangping Shi, Nina Zhou, Kai Huang, Haiyang Yu, Yao Hu, Guang Yang, Colleen A. De Vries, Cogency Global Inc., Goldman Sachs (Asia) L.L.C., Morgan Stanley & Co. LLC, BofA Securities, Inc., China Merchants Securities (HK) Co., Limited, CLSA Limited and Haitong International Securities Company Limited, re: #1 Complaint,. Document filed by Sidney Sandoz..(Rudman, Samuel) (Entered: 09/14/2021)

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  • 09/14/2021
  • View Court Documents
  • Docket(#2) CIVIL COVER SHEET filed..(Rudman, Samuel) (Entered: 09/14/2021)

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  • 09/14/2021
  • View Court Documents
  • Docket(#1) COMPLAINT against BofA Securities, Inc., CLSA Limited, China Merchants Securities (HK) Co., Limited, Cogency Global Inc., Colleen A. De Vries, Goldman Sachs (Asia) L.L.C., Haitong International Securities Company Limited, Yao Hu, Kai Huang, Morgan Stanley & Co. LLC, Peng Shen, Kangping Shi, Waterdrop Inc., Guang Yang, Haiyang Yu, Nina Zhou. (Filing Fee $ 402.00, Receipt Number ANYSDC-25061013)Document filed by Sidney Sandoz..(Rudman, Samuel) (Entered: 09/14/2021)

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