The Notice explains that the parties in the Lawsuit known as Moore v. Robinhood Financial LLC, No. 2:21‐cv‐01571‐BJR (W.D. Wash.) (the “Lawsuit”) have agreed to resolve the Lawsuit on a class action basis and that the Court has preliminarily approved the Settlement. If you are a member of the Settlement Class, you have legal rights and options that you may exercise, as explained in the Notice.  

The Lawsuit is about whether Robinhood violated Washington state laws, including Washington’s Commercial Electronic Mail Act (“CEMA”) and the Washington Consumer Protection Act (“CPA”), by substantially assisting Robinhood users in the transmission of unsolicited commercial text messages to prospective customers as a part of its refer-a-friend marketing program. Specifically, the Settlement Class Representatives allege that Robinhood’s trading app allowed users to generate and send pre-filled text messages to one or more of the user’s contacts, which contained a hyperlink for the contact(s) to sign up for a Robinhood account, without first obtaining the recipients’ clear and affirmative consent to receive commercial text messages. Under the CEMA, a person is entitled to $500 per unlawful text message and, under the CPA, a court may award an additional payment up to $1,500, as well as reasonable attorneys’ fees and costs.

Defendant denies any wrongdoing and believes it has fully complied with the law. Defendant has asserted many defenses it believes would be successful at trial. In agreeing to settle, Defendant maintains that it complied with the law and does not admit any wrongdoing. The Settlement is not an admission of wrongdoing. 

The Lawsuit is proceeding in the United States District for the Western District of Washington before the Honorable Judge Barbara J. Rothstein. 

In a class action lawsuit, one or more people called “Class Representatives” (in this case, Cooper Moore and Andrew Gillette), sue on behalf of themselves and other people who have similar claims. These people together are called a “Class” or “Class Members.” The Class Representatives and all the Class Members are called Plaintiffs. The company that the Plaintiffs sue, Robinhood Financial LLC, is called the Defendant. One court resolves the issues for all Class Members—except for those who chose to exclude themselves.

On August 9, 2021, Class Representative Moore started an action on behalf of a putative class by filing a complaint against Robinhood alleging that it violated CEMA and the CPA (“Complaint”). Class Representative Gillette was added to the Lawsuit on February 9, 2022 when the Class Representatives filed a First Amended Complaint. Defendant moved to dismiss the Lawsuit, claiming that the First Amended Complaint failed, as a matter of law, to state a viable claim for relief. On August 3, 2022, the Court denied Robinhood’s motion. The parties have since engaged in substantial discovery regarding the Class Representatives’ claims and Robinhood’s defenses.

The Court has not decided whether Robinhood did anything wrong. The Notice should not be interpreted as an expression of the Court’s opinion on the merits of the Lawsuit. 

The Court held a Final Approval Hearing on July 16, 2024 and granted Final Approval of the Settlement.

The Class Representatives and Robinhood agreed to a Settlement to resolve the Lawsuit, as described below. The Final Approval Hearing was held on July 16, 2024 and granted Final Approval of the Settlement.

You are a member of the Settlement Class if you (1) received a Robinhood referral program text message between August 9, 2017 and February 13, 2024; (2) were a Washington resident at the time you received the text message; and (3) you did not clearly and affirmatively consent in advance to receive the Robinhood referral program text message.

If you received a notice of this Settlement via email or mail, records indicate that you may have received a text message as part of Robinhood’s refer-a-friend marketing program on or after August 9, 2017. People who did not receive email or mail Notice may still be part of the Settlement Class if they meet the requirements described above.

The Settlement Class does not include Defendant, any entity that has a controlling interest in Defendant, and Defendant’s current or former directors, officers, counsel, and their immediate families. The Settlement Class also does not include any persons who validly requested exclusion from it.

If you are still not sure whether you are included in the Settlement Class, you can get free help from the Settlement Administrator or by writing to the lawyers appointed by the Court to represent the Settlement Class in this case (“Class Counsel”) at the addresses listed in response to Question 22. You can also contact them at 206-454-7308 or RobinhoodSettlement@TerrellMarshall.com.

The complete terms of the proposed Settlement are provided in the Settlement Agreement. The Notice provides only a summary of the terms of the Settlement.

The Final Approval Hearing was held on July 16, 2024 and granted Final Approval of the Settlement. If the Settlement becomes final, Robinhood will pay nine million dollars ($9,000,000) into a settlement fund. This money will be used to: (1) make Settlement payments to eligible Settlement Class Members; (2) pay the costs of distributing notice and Settlement payments to Settlement Class Members and other costs of administering the Settlement; and (3) pay court-awarded attorneys’ fees and litigation expenses of Class Counsel and any service awards granted to the Class Representatives. You must have decided whether to stay in the Class or opt out of it. The deadline to exclude yourself from the Class passed on May 13, 2024.

If you are a Settlement Class Member, you must have completed and submitted a Claim Form by May‎ ‎13‎, ‎2024 to receive a Settlement payment.

If you are a Settlement Class Member and did not exclude yourself from the Settlement, and the Settlement is approved and becomes final, the Settlement will be legally binding on you. In exchange for the opportunity to obtain settlement benefits, you will release any and all claims and rights, whether known or unknown, that arise out of or relate in any way to text messaging regarding the Robinhood referral program to any telephone number, that have been, or could have been, brought in the Lawsuit, as well as any claims arising out of the same facts as any of the claims asserted in the Lawsuit.

The Final Approval Hearing was held on July 16, 2024 and granted Final Approval of the Settlement. If the Settlement becomes final, Class Members who did not exclude themselves from the Settlement Class and who completed and submitted a timely and valid Claim Form will be issued a Settlement payment. The settlement fund will be distributed to all Settlement Class Members who submitted timely and valid Claim Forms, after the deduction of settlement costs, attorneys’ fees and expenses awarded by the Court, and any service awards granted to the Class Representatives. It is estimated by Class Counsel that Settlement payments will range between $45 and $90 per Settlement Class Member, although the actual amount could be higher or lower depending on how many valid Claim Forms are received.

If you are a Settlement Class Member, you must have completed and submitted a Claim Form by May‎ ‎13‎, ‎2024 to receive a Settlement payment. The Claim Form allowed Settlement Class Members to elect the method by which to receive payments including paper checks, Venmo, PayPal, etc.

For any Settlement payments that are uncashed or deemed undeliverable by the Settlement Administrator, the funds will be distributed by one or both of the following means: (1) a pro rata second distribution to those Settlement Class Members who cashed/received their initial Settlement payments (if there are sufficient residual funds to justify the administrative costs of such distribution); and/or (2) distribution to the Legal Foundation of Washington.

You must have decided whether to stay in the Class or exclude yourself from the Settlement. The deadline to exclude yourself from the Class passed on May 13, 2024.

If you chose to stay in the Settlement Class, you had the option to (1) do nothing; or (2) complete and submit a Claim Form by May‎ ‎13‎, ‎2024, in order to share in the payment of the settlement proceeds. Under either option, by choosing to stay in the Settlement Class and if the Settlement becomes final, you give up any rights to sue the Defendant separately about the same issues in this Lawsuit. See Question 11.

By staying in the Settlement Class, you could have objected to or commented on the Settlement and/or or to Class Counsel’s request for attorneys’ fees, litigation expenses, and service awards. You did not need to object or comment in order to receive a Settlement payment.

The deadline to file a Claim Form passed on May 13, 2024.

If you received an email notice of the Settlement, then your eight (8) digit claims code is located at the top of the email. If you received a postcard notice of the Settlement in the mail, then your eight (8) digit claims code is located on the front of the postcard above your name and address.

The deadline to file a Claim Form passed on May 13, 2024.

The deadline to object or comment passed on May 13, 2024.

If you excluded yourself from the Settlement, or “opted out,” you gave up the right to receive any benefits from the Settlement and you could not have commented or objected to the Settlement. However, you will keep any rights you may have to sue Robinhood regarding the issues in this Lawsuit. The deadline to exclude yourself from the Class passed on May 13, 2024.

The deadline to exclude yourself from the Class passed on May 13, 2024.

If you are in the Settlement Class and you do nothing, you will stay in the Settlement Class. The Final Approval Hearing was held on July 16, 2024 and granted Final Approval of the Settlement. If the Settlement becomes final, you will not be issued a Settlement payment and you will not be able to sue Robinhood about the issues in this Lawsuit. You will also be legally bound by all of the orders that the Court issues and judgments the Court makes as to the Settlement Class.

Yes. The Court has appointed the following attorneys and law firms to represent the Settlement Class Members. Together, these lawyers are called “Class Counsel”. You can contact them at 206-454-7308 or RobinhoodSettlement@TerrellMarshall.com.

Class Counsel filed a motion on April 12, 2024 asking the Court to award them attorneys’ fees up to one-fourth of the $9 million settlement fund and for reimbursement of reasonable litigation expenses and costs. The attorneys’ fees and expenses awarded by the Court will be the only payment to Class Counsel for their efforts in achieving the Settlement and for their risk in undertaking this representation on a wholly contingent basis during the more than two years this case was litigated. Class Counsel asked the Court on April 12, 2024 to compensate them for their efforts and commitment on behalf of the Settlement Class in this Lawsuit. They asked the Court to pay them attorneys’ fees not to exceed 25% of the $9 million settlement fund ($2,250,000), out of pocket costs currently estimated to be $142,407.76, and Class Representative Awards of $10,000 each to Plaintiffs Cooper Moore and Andrew Gillette ($20,000 total). The Court granted the motion on July 16, 2024.

You do not need to hire your own lawyer because Class Counsel is working for you. However, you are welcome to hire your own lawyer at your own expense. If you hire a lawyer to speak for you or to appear in Court, your lawyer must file a Notice of Appearance with the Court.

The Court held a Final Approval Hearing on July 16, 2024, via videoconference. 

At the Final Approval Hearing, the Court considered whether the Settlement was fair, reasonable, and adequate. The Court also considered Class Counsel’s application for attorneys’ fees, expenses, and service awards. If there were objections, the Court considered them. The Court granted Final Approval of the Settlement on July 16, 2024.

The Final Approval Hearing was held on July 16, 2024 and granted Final Approval of the Settlement.

The Final Approval Hearing was held on July 16, 2024 and granted Final Approval of the Settlement.

The Notice contains a summary of relevant court papers. Complete copies of public pleadings, Court rulings and other filings are available for review and copying at www.pacer.uscourts.gov. Information is also available at www.RobinhoodReferralSettlement.com, or by contacting the Settlement Administrator at (877) 231-0646, or Class Counsel at (206) 454-7308 or RobinhoodSettlement@TerrellMarshall.com. 

Please do not contact the Court or Judge Rothstein. They cannot answer any questions or discuss the Action.