1 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA 

ORLANDO DIVISION 

STEVEN BAIRD, ON BEHALF OF 

HIMSELF AND ALL OTHERS SIMILARLY 

SITUATED, 

Plaintiff, 

v. 

ROBINHOOD MARKETS, INC.; 

ROBINHOOD FINANCIAL, LLC; AND

ROBINHOOD SECURITIES, LLC, 

Defendants. 

CASE NO. __________________ 

CLASS ACTION COMPLAINT 

Steven Baird, on behalf of himself and all others similarly situated, 

pursuant to Federal Rule of Procedure 23, sues Robinhood Markets, Inc., 

Robinhood Financial LLC, and Robinhood Securities, LLC, (collectively, 

“Robinhood”) and states: 

INTRODUCTION AND NATURE OF ACTION 

1. It is difficult to imagine a set of circumstances on which 

Representative Alexandra Ocasio-Cortez and Senator Ted Cruz could 

agree.

2. Robinhood’s decision to block market access to millions of its 

individual users in favor of billion-dollar institutional investors, like hedge 

Case 4:21-cv-00061-WS-MAF Document 1 Filed 01/29/21 Page 1 of 12
funds and banks, so shocked the public conscience that it united two of the 

most diametrically opposed members of Congress in condemnation:1

3. In this class action, Baird seeks, on behalf of himself and those 

similarly situated, damages under Florida’s Deceptive and Unfair Trade 

Practices Act (“FDUPTA”) caused by Robinhood’s unfair and deceptive 

practice of preventing individual investors from trading on their Robinhood 

accounts to their detriment, to protect institutional investors. Baird also 

seeks attorneys’ fees, for himself and the Class, under the Federal Class 

action Fairness Act and FDUTPA. 

1

 Ted Cruz (@tedcruz), Twitter (Jan. 29, 2021), https://twitter.com/tedcruz. 

Case 4:21-cv-00061-WS-MAF Document 1 Filed 01/29/21 Page 2 of 12
PARTIES, JURISDICTION, AND VENUE 

4. Baird is a citizen of Florida and is over the age of 18. 

5. Robinhood Markets, Inc. is a financial services holding company 

incorporated in Delaware, whose subsidiaries provide financial and 

investment services via an internet/cloud-based platform that is also 

available on mobile phones. 

6. Its subsidiary, Robinhood Financial LLC, is a Delaware 

corporation and full service securities firm engaged in the retail sale of 

securities and various other financial products. 

7. Its subsidiary, Robinhood Securities, LLC, is a Delaware 

corporation and full service securities firm engaged in the retail sale of 

securities and various other financial products. 

8. Collectively, Robinhood provides internet and mobile phone 

based securities sales and services to approximately 10 million customers 

and/or users. 

9. This Court has subject matter jurisdiction over this matter 

pursuant to 21 U.S.C. § 1332, because this putative class action consists of 

tens of thousands (or more) members, of whom at least one is a citizen of a 

state different from any Defendant, and the claims of the proposed class 

exceed $5,000,000. 

Case 4:21-cv-00061-WS-MAF Document 1 Filed 01/29/21 Page 3 of 12
10. This Court has general personal jurisdiction over each 

Robinhood entity because each is registered with the Florida Division of 

Corporations to conduct business in this state, and each conducts business 

in this state with tens of thousands of Florida residents. 

11. Venue is appropriate in this district because Robinhood conducts 

business in this district, a substantial portion of the misconduct giving rise to 

the claim occurred in this district, and a substantial portion of the harm 

caused by Robinhood occurred in this district. 

12. Tallahassee is the appropriate division under Local Rule 3.1, 

because the conduct outlined above in Paragraph 11 also occurred in this 

division. Baird is a Leon County resident. 

GENERAL FACTUAL ALLEGATIONS 

13. Robinhood is a registered broker-dealer with the Security and 

Exchange Commission. It holds itself out to the public and its customers on 

the landing page of its website as a platform that enables “Investing for 

Everyone.”2

14. Robinhood goes on to describe it services—directly over the link 

to sign up as a new customer—as “Commission-free investing, plus the tools 

2

 Robinhood, (Jan. 28, 2021), https://robinhood.com/us/en/. 

Case 4:21-cv-00061-WS-MAF Document 1 Filed 01/29/21 Page 4 of 12
you need to put your money in motion. Sign up and get your first stock for 

free. Certain limitations apply.”3

15. Robinhood’s very first Tweet on March 23, 2016, was: 4

16. Robinhood also holds itself out to the public and its customers as 

a good place for beginner, unexperienced investors to start investing, and 

publishes its Investing 101 teaching tools to, for example, teach fledgling 

investors about investments, stocks, and the stock market.5 Robinhood 

generally markets itself to young, inexperienced investors as an alternative 

to commission-based, traditional brokers. It claims over 10 million users. 

17. Robinhood provides its online brokerage services to its 

customers via a web-based application, in which it facilitates customers’ 

securities transactions. 

3

Id.

4

 Twitter, (Jan. 28, 2021), 

https://twitter.com/RobinhoodApp/status/712708069369782272

5

 Robinhood, (Jan. 28, 2021), https://learn.robinhood.com/.

Case 4:21-cv-00061-WS-MAF Document 1 Filed 01/29/21 Page 5 of 12
18. Early this year, a collective of individual investors, organizing 

through websites like reddit.com, caused massive disruptions in markets, in 

particular driving up otherwise unexceptional stocks (e.g. GameStop and 

AMC) to unprecedented values. 

19. In response to the disruptions, on January 28, 2021, Robinhood 

halted the trading of several publicly traded stocks such as GameStop, AMC, 

Nokia, and Blackberry, making it impossible for its individual investors to buy 

or sell the affected securities. 

20. As a result of Robinhood’s decision to restrict user trades, 

millions of its customers, including Baird, were unable to freely trade on the 

stock market. At the same time, institutional investors with whom Robinhood 

has beneficial relationships—but are not Robinhood customers—could 

continue to trade freely. 

21. This market manipulation created an unfair disadvantage for 

Baird and millions of other Robinhood investors like him to their detriment, 

for the benefit of institutional investors. 

Class Allegations 

22. Plaintiff brings this action pursuant to the Federal Class Action 

Fairness Act and Rule 23 of the Federal Rules of Civil Procedure on behalf 

of the following Class: any user of Robinhood within Florida that was unable 

Case 4:21-cv-00061-WS-MAF Document 1 Filed 01/29/21 Page 6 of 12
to trade on the market with their Robinhood account because of Robinhood’s 

restrictions on January 28, 2021. 

23. Baird is a member of the Class he seeks to represent. He was a 

Robinhood account holder and used his Robinhood account to acquire, 

trade, and hold securities. On January 28, 2021, Baird was unable to engage 

in any trading activity on his positions due to Robinhood’s halt. 

24. Additionally, or in the alternative, Baird brings claims this claim 

on behalf of all Robinhood customers within Florida who were not able to 

execute a trade of a restricted security after Robinhood purposefully 

removed the securities from its trading platform on January 28, 2021. 

25. Excluded from the Class are the Robinhood entities and their 

current employees, counsel for either party, as well as the Court and its 

personnel presiding over this action. 

26. Numerosity: The proposed Class is so numerous that joinder of 

all members is impracticable. Robinhood claims more than 10 million 

customers and/or users nationwide, tens of thousands of which are potential 

members of this proposed Class. 

27. Typicality: The claims alleged by Plaintiff are typical of the 

claims of the Class. All members of the proposed class were harmed by 

Robinhood’s unfair and deceptive business practices. 

Case 4:21-cv-00061-WS-MAF Document 1 Filed 01/29/21 Page 7 of 12
28. Adequacy: Plaintiff will fairly and adequately represent and 

protect the interests of the Class, and has no interests antagonistic or 

contrary to the Class, and has retained counsel experienced in complex 

class action litigation. 

29. Commonality: The questions of law and fact common to the 

members of the Class predominate over any questions affecting only Plaintiff 

or other individual members, and a class action is superior to other available 

methods for the fair and efficient adjudication of the controversy. 

30. Class members would not have an interest in pursuing separate 

individual actions against Robinhood, as the amounts of the individual claims 

are relatively small compared to the expense and burden of individual 

litigation. Class certification also will obviate the need for unduly duplicative 

litigation that might result in inconsistent judgments concerning Robinhood’s 

practices. 

31. Management of this lawsuit as a class action will not present any 

likely difficulties. In the interests of justice and judicial efficiency, it would be 

desirable to concentrate the litigation of all Class members’ claims in a single 

action. 

COUNT I – FDUTPA Violation 

32. Plaintiff reincorporates and realleges paragraphs 1 through 21. 

Case 4:21-cv-00061-WS-MAF Document 1 Filed 01/29/21 Page 8 of 12
33. Plaintiff is a consumer as defined in the FDUTPA. § 501.202(2), 

Fla. Stat. 

34. Robinhood is engaged in “trade or commerce” as defined in 

FDUTPA, by advertising, soliciting, providing, and offering trading services 

to the public. § 501.202(8), Fla. Stat. 

35. Section 501.204(a) provides: “Unfair methods of competition, 

unconscionable acts or practices, and unfair or deceptive acts or practices 

in the conduct of any trade or commerce are hereby declared unlawful.” 

§ 501.204, Fla. Stat. 

36. While the Florida Legislature has not defined what an “unfair and 

deceptive act” is, it has mandated that FDUTPA be liberally construed. 

§ 501.204, Fla. Stat. 

37. FDUTPA seeks to protect legitimate consumers, like Baird and 

the Class members, from those who engage in unfair methods of 

competition, or unconscionable, deceptive, and/or unfair acts or practices in 

the conduct of any trade or commerce. 

38. Furthermore, FDUTPA provides that great weight shall be given 

to federal cases interpreting the federal counterpart to FDUPTA. 

§ 501.204(2), Fla. Stat. Federal courts have defined a deceptive trade 

practice to be any act or practice that has the tendency or capacity to deceive 

Case 4:21-cv-00061-WS-MAF Document 1 Filed 01/29/21 Page 9 of 12
consumers and an unfair practice to be any act that offends public policy and 

is in general, unethical, oppressive, unscrupulous, or substantially injurious 

to consumers. 

39. An unfair practice under the federal statute has been defined as 

one that “offends established public policy” and one that is “immoral, 

unethical, oppressive, unscrupulous or substantially injurious to consumers.” 

Samuels v. King Motor Co of Fort Lauderdale, 782 So.2d 489 (Fla. 4th DCA 

2001) (citing Spiegel, Inc. v. Fed. Trade Comm'n, 540 F.2d 287, 293 (7th Cir. 

1976)). 

40. Robinhood engaged in unfair trade practices and/or unfair 

methods of competition when it knowingly restricted and limited their users’ 

ability to freely trade stocks at their fair market value for the purpose of 

protecting institutionalized banking companies and at the detriment to 

average individual investors, to whom it primarily markets. 

41. Robinhood’s actions offend public policy and are immoral, 

unethical, oppressive, unscrupulous, and substantially injurious to Baird and 

the Class members, who believed that Robinhood would provide the 

advertised access to the market. 

42. As a result of such ongoing deceptive and unfair trade practices, 

Plaintiff and the Class members have suffered and continue to suffer 

Case 4:21-cv-00061-WS-MAF Document 1 Filed 01/29/21 Page 10 of 12
damages, including actual damages to their investment account held in 

Robinhood’s business. 

WHEREFORE, Baird requests this Court: 

1. Certify the class pursuant to Federal Rule of Civil Procedure 23; 

2. Designate Baird as Class Representative; 

3. Designate undersigned counsel as Class Counsel; 

4. Award Baird, and all others similarly situated, actual damages caused 

by Robinhood’s FDUTPA violation; 

5. Award Baird, and all others similarly situated, reasonable attorneys’ 

fees pursuant to the Federal Class Action Fairness Act and FDUTPA; 

6. Award Baird, and all others similarly situated, costs and interest; and 

7. Award any other relief this Court deems just and proper. 

Baird, on behalf of himself and all others similarly situated, requests a 

trial by jury. 

Respectfully submitted this 29th day of January, 2021, 

GRAY|ROBINSON, P.A. 

301 East Pine Street, Suite 1400 

Orlando, Florida 32801 

Telephone: 407/843-8880 

Facsimile: 407/244-5690 

By: /s/ Jason Zimmerman 

Jason Zimmerman 

Florida Bar No. 104392 

jason.zimmerman@gray-robinson.com

Case 4:21-cv-00061-WS-MAF Document 1 Filed 01/29/21 Page 11 of 12
cindi.garner@gray-robinson.com

Counsel for Plaintiff, Steven Baird

Case 4:21-cv-00061-WS-MAF Document 1 Filed 01/29/21 Page 12 of 12