Reynolds v. Citadel Securities LLC — Entry #39: MOTION to Appoint Lead Plaintiff Jordan Dario Primo by Jordan Dario Primo

Case 1:26-cv-24485-RKA Document 39-4 Entered on FLSD Docket 08/28/2026 Page 1 of 7


                  EXHIBIT C


Case 1:26-cv-24485-RKA Document 39-4 Entered on FLSD Docket 08/28/2026 Page 2 of 7


    Jun 29, 2026 5:19 PM Eastern Daylight Time


    Grant & Eisenhofer Files Class Action Lawsuit
    Against Citadel Securities LLC and Virtu
    Americas LLC
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    NEW YORK--(BUSINESS WIRE)--On June 29, 2026, Grant & Eisenhofer P.A. filed a
    class action lawsuit on behalf of Aron Reynolds (“Plaintiff”) against Citadel
    Securities LLC (“Citadel”) and Virtu Americas LLC (“Virtu”) (together, the
    “Defendants”). The action alleges that Defendants defrauded investors by placing
    and executing manipulative trades designed to artificially deflate the price of
    Genius stock and also resulted in increased transaction costs for investors.


       The lawsuit alleges that throughout the Class Period, Defendants
       Citadel Securities and Virtu Americas engaged in a manipulative and
       illegal trading practice known as “spoofing.”
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    The action is brought on behalf of all persons who purchased or otherwise acquired,
    or sold or otherwise disposed of, securities of Genius between April 12, 2022 and
    May 30, 2025, inclusive (the “Class Period”). The action, brought in the United
    States District Court for the Southern District of Florida, is captioned Aron Reynolds
    v. Citadel Securities LLC and Virtu Americas LLC, No. 1:26-cv-24485 (S.D. Fla.).

    Citadel and Virtu are broker-dealers registered with the Securities and Exchange
    Commission and operate as major market makers, routinely placing and executing
    securities trades for investors as well as for their own trading accounts.

    The complaint alleges violations of Sections 9(a) and 10(b) of the Securities
    Exchange Act of 1934. Specifically, the lawsuit alleges that throughout the Class


Case 1:26-cv-24485-RKA Document 39-4 Entered on FLSD Docket 08/28/2026 Page 3 of 7
    Period, Defendants engaged in a manipulative and illegal trading practice known
    as “spoofing,” which involves submitting and then cancelling buy or sell orders
    without any genuine intent to execute them. The purpose of these “baiting orders”
    was to mislead other market participants about the true level of supply and
    demand for Genius securities, or about the stock’s price volatility, thereby
    influencing the market price of Genius to benefit Defendants’ own trading
    positions. The alleged manipulation also increased investors’ transaction costs by
    inflating the bid-ask spread for Genius stock. Defendants entered thousands of
    these baiting orders on U.S. stock exchanges to create the false impression that
    Genius’ stock price reflected genuine supply-and-demand and volatility dynamics,
    while simultaneously profiting by absorbing and reselling their customers’ order
    flow at prices favorable to Defendants.

    Throughout the Class Period, sharp declines in Genius’ stock price consistently
    coincided with substantial spikes in Defendants’ spoofing activity. For example,
    during the week of February 10, 2025, Defendants built significant short positions in
    Genius stock and reaped substantial trading profits: Citadel traded more than 23
    million shares of Genius off-exchange, accounting for nearly half of all off-exchange
    trading in the stock, while Virtu traded nearly 11 million shares, accounting for more
    than 20% of all off-exchange trading. Together, Defendants comprised nearly 70%
    of all off-exchange trading in Genius stock that week, as short volume surged from
    a low of 53% to more than 61%. As a result, Genius’ stock price decline by 22%
    despite the absence of any new material, company-specific news.


    Investors who purchased or sold Genius securities during the Class Period are
    members of this proposed Class and may be able to seek appointment as lead
    plaintiff, which is a court-appointed representative of the Class, by complying with
    the relevant provisions of the Private Securities Litigation Reform Act of 1995 (the
    “PSLRA”). See 15 U.S.C. Section 78u-4(a)(2)(A)(i)-(vi).

    If you wish to serve as lead plaintiff, you must move the Court by no later than
    August 28, 2026. You do not need to seek to become a lead plaintiff in order to
    share in any possible recovery. You may also retain counsel of your choice to
    represent you in this action.

    If you wish to discuss this action or have any questions concerning this notice or
    your rights, please contact Abe Alexander at Grant & Eisenhofer P.A. at 646-722-
    8500, or via email at [email protected].


Case 1:26-cv-24485-RKA Document 39-4 Entered on FLSD Docket 08/28/2026 Page 4 of 7
    Contacts
    Abe Alexander
    Grant & Eisenhofer P.A.
    Tel.: (646) 722-8500
    [email protected]


    Industry:         Class Action Lawsuit   Professional Services   Legal


    GRANT & EISENHOFER P.A.


    RELEASE VERSIONS


     English


    CONTACTS
    Abe Alexander
    Grant & Eisenhofer P.A.
    Tel.: (646) 722-8500
    [email protected]


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