Case: 1:21-cv-00490 Document #: 1 Filed: 01/28/21 Page 1 of 6 PageID #:1

Pro Se 2 (Rev. 12/16) Complaint and Request for Injunction

UNITED STATES DISTRICT COURT

for the
Northern District of Illinois

Eastern Division

) Case No. 1:21-cv-00490

) (to be filled in by the Clerk’s Office)
Richard Joseph Gatz, et. al.
)
Plaintiff(s) )
(Write the full name of each plaintiff who is filing this complaint.
If the names of all the plaintiffs cannot fit in the space above, )
please write “see attached” in the space and attach an additional )
page with the full list of names.) )
-v- )
)
)
)
Robinhood Financial, LLC )
Defendant(s) )
(Write the full name of each defendant who is being sued. If the )
names of all the defendants cannot fit in the space above, please )
write “see attached” in the space and attach an additional page
with the full list of names.)

COMPLAINT AND REQUEST FOR INJUNCTION

I. The Parties to This Complaint

A. The Plaintiff(s)

Provide the information below for each plaintiff named in the complaint. Attach additional pages if
needed.
Name Richard Joseph Gatz
Street Address 1104 N. Mill St
City and County Naperville, DuPage
State and Zip Code Illinois, 60563
Telephone Number 6304453187
E-mail Address richardgatz@gmail.com

B. The Defendant(s)

Provide the information below for each defendant named in the complaint, whether the defendant is an
individual, a government agency, an organization, or a corporation. For an individual defendant,
include the person's job or title (if known). Attach additional pages if needed.

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Pro Se 2 (Rev. 12/16) Complaint and Request for Injunction

Defendant No. 1
Name Robinhood Financial, LLC
Job or Title (if known)
Street Address 85 Willow Rd
City and County Menlo Park, San Mateo County
State and Zip Code California, 94025
Telephone Number 6509402700
E-mail Address (if known)

Defendant No. 2
Name
Job or Title (if known)
Street Address
City and County
State and Zip Code
Telephone Number
E-mail Address (if known)

Defendant No. 3
Name
Job or Title (if known)
Street Address
City and County
State and Zip Code
Telephone Number
E-mail Address (if known)

Defendant No. 4
Name
Job or Title (if known)
Street Address
City and County
State and Zip Code
Telephone Number
E-mail Address (if known)

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Pro Se 2 (Rev. 12/16) Complaint and Request for Injunction

II. Basis for Jurisdiction

Federal courts are courts of limited jurisdiction (limited power). Generally, only two types of cases can be
heard in federal court: cases involving a federal question and cases involving diversity of citizenship of the
parties. Under 28 U.S.C. § 1331, a case arising under the United States Constitution or federal laws or treaties
is a federal question case. Under 28 U.S.C. § 1332, a case in which a citizen of one State sues a citizen of
another State or nation and the amount at stake is more than $75,000 is a diversity of citizenship case. In a
diversity of citizenship case, no defendant may be a citizen of the same State as any plaintiff.

What is the basis for federal court jurisdiction? (check all that apply)
Federal question Diversity of citizenship

Fill out the paragraphs in this section that apply to this case.

A. If the Basis for Jurisdiction Is a Federal Question

List the specific federal statutes, federal treaties, and/or provisions of the United States Constitution that
are at issue in this case.
17 CFR § 240.10b-5

B. If the Basis for Jurisdiction Is Diversity of Citizenship

1. The Plaintiff(s)

a. If the plaintiff is an individual

The plaintiff, (name) , is a citizen of the
State of (name) .

b. If the plaintiff is a corporation

The plaintiff, (name) , is incorporated
under the laws of the State of (name) ,
and has its principal place of business in the State of (name)
.

(If more than one plaintiff is named in the complaint, attach an additional page providing the
same information for each additional plaintiff.)

2. The Defendant(s)

a. If the defendant is an individual

The defendant, (name) , is a citizen of
the State of (name) . Or is a citizen of
(foreign nation) .

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Pro Se 2 (Rev. 12/16) Complaint and Request for Injunction

b. If the defendant is a corporation

The defendant, (name) , is incorporated under
the laws of the State of (name) , and has its
principal place of business in the State of (name) .
Or is incorporated under the laws of (foreign nation) ,
and has its principal place of business in (name) .

(If more than one defendant is named in the complaint, attach an additional page providing the
same information for each additional defendant.)

3. The Amount in Controversy

The amount in controversy−the amount the plaintiff claims the defendant owes or the amount at
stake−is more than $75,000, not counting interest and costs of court, because (explain):

III. Statement of Claim

Write a short and plain statement of the claim. Do not make legal arguments. State as briefly as possible the
facts showing that each plaintiff is entitled to the injunction or other relief sought. State how each defendant
was involved and what each defendant did that caused the plaintiff harm or violated the plaintiff's rights,
including the dates and places of that involvement or conduct. If more than one claim is asserted, number each
claim and write a short and plain statement of each claim in a separate paragraph. Attach additional pages if
needed.

A. Where did the events giving rise to your claim(s) occur?

Robinhood Financial, LLC (hereinafter referred to as the "Defendant") has a securities and options
tradings platform and mobile application. The events occurred nationally.

B. What date and approximate time did the events giving rise to your claim(s) occur?
January 27th, 2021, January 28, 2021, and the events are ongoing.

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Pro Se 2 (Rev. 12/16) Complaint and Request for Injunction

C. What are the facts underlying your claim(s)? (For example: What happened to you? Who did what?
Was anyone else involved? Who else saw what happened?)

The Defendant halted trading on its securities exchange platform of Blackberry (BB), Nokia (NOK),
and AMC Theatres (AMC) for retail investors. On information and belief, they have continued to allow
trading for institutional investors. Richard Joseph Gatz (hereinafter referred to as the "Plaintiff") owned
two (2) options contracts for BB at the time of the trading halt. The value of these options decreased by
almost two-hundred percent and the BB stock price fell over ten dollars ($10) from the prior days close.
On information and belief, the halting of trading of these stocks was to protect institutional investment
at the detriment of retail customers. Furthermore, this appears to be in lock-step with other securities
trading platforms, such as Ally Financial, TD Ameritrade and potentially others.

IV. Irreparable Injury

Explain why monetary damages at a later time would not adequately compensate you for the injuries you
sustained, are sustaining, or will sustain as a result of the events described above, or why such compensation
could not be measured.
The halt of retail trading for these stocks has caused irreparable harm and will continue to do so. Plaintiff is
unable to get fair market value for his options contracts and the manipulation has caused the price of the BB to
fall. If the stocks are not allowed to be trading it is likely that Plaintiff will take a financial loss solely due to the
Defendant's behavior and manipulation of their trading platform. The Defendant has on information and belief
continued to allow investment in these securities by instititutional investors who have benefited from the
stoppage of retail investment.

V. Relief

State briefly and precisely what damages or other relief the plaintiff asks the court to order. Do not make legal
arguments. Include any basis for claiming that the wrongs alleged are continuing at the present time. Include
the amounts of any actual damages claimed for the acts alleged and the basis for these amounts. Include any
punitive or exemplary damages claimed, the amounts, and the reasons you claim you are entitled to actual or
punitive money damages.
Plaintiff respectfully requests that this honorable court require Robinhood to continue to allow trading of these
securities for retail investors so that they can trade at their actual market value based upon retail and institutional
investment. Plaintiffs' monetary damages continue to accrue and likely will be substantial.

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Pro Se 2 (Rev. 12/16) Complaint and Request for Injunction

VI. Certification and Closing

Under Federal Rule of Civil Procedure 11, by signing below, I certify to the best of my knowledge, information,
and belief that this complaint: (1) is not being presented for an improper purpose, such as to harass, cause
unnecessary delay, or needlessly increase the cost of litigation; (2) is supported by existing law or by a
nonfrivolous argument for extending, modifying, or reversing existing law; (3) the factual contentions have
evidentiary support or, if specifically so identified, will likely have evidentiary support after a reasonable
opportunity for further investigation or discovery; and (4) the complaint otherwise complies with the
requirements of Rule 11.

A. For Parties Without an Attorney

I agree to provide the Clerk’s Office with any changes to my address where case−related papers may be
served. I understand that my failure to keep a current address on file with the Clerk’s Office may result
in the dismissal of my case.

Date of signing: 01/28/2021

Signature of Plaintiff /s/ Richard Joseph Gatz

Printed Name of Plaintiff Richard Joseph Gatz

B. For Attorneys

Date of signing: 01/28/2021

Signature of Attorney /s/ Richard Joseph Gatz

Printed Name of Attorney Richard Joseph Gatz
Bar Number 6291165
Name of Law Firm Richard Gatz, Attorney at Law
Street Address 1104 N. Mill St. Unit 212
State and Zip Code Illinois, 60563
Telephone Number 6304453187
E-mail Address richardgatz@gmail.com

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