Reynolds v. Citadel Securities LLC — Entry #40: MOTION to Appoint Lead Plaintiff Duc To ( Responses due by 9/11/2026.), MOTION to Appoint Lead Counsel The Rosen Law Firm, P.A
Case: Reynolds v. Citadel Securities LLC flsd · 1:26-cv-24485
filed June 29, 2026
What this document is
Docket entry #40 · filed August 28, 2026
MOTION to Appoint Lead Plaintiff Duc To ( Responses due by 9/11/2026.), MOTION to Appoint Lead Counsel The Rosen Law Firm, P.A. by Duc To. Attorney Laurence Matthew Rosen added to party Duc To(pty:mov). (Attachments: # 1 Text of Proposed Order, # 2 Decl. of Laurence Rosen, # 3 Exhibit 1 - Early Notice, # 4 Exhibit 2 - PSLRA Cert, # 5 Exhibit 3 - Loss Chart, # 6 Exhibit 4 - RLF Firm Resume)(Rosen, Laurence) (Entered: 08/28/2026)
Who is involved
- Aron Reynolds
- Citadel Securities LLC
- Virtu Americas LLC
Why we have it
We follow this case because it names a company we track, although that company is not a party:
- Applied Digital: its former name “FLIGHT SAFETY TECHNOLOGIES INC” appears in a filing in this case.
…Counsel. $1.2 million. • Flight Safety Technologies, Inc., (D. Conn.). Rosen Lead Counsel. $1…
- Core Scientific: its name “Core Scientific, Inc.” appears in a filing in this case.
…Lead Counsel. Pang v. Levitt (Core Scientific, Inc.), No. 22-CV-1191-LY (W.D. Tex.). Rosen…
A free copy from the RECAP archive of federal court filings (mirrored at the Internet Archive), retrieved October 07, 2026. Federal court filings are public records.
Document text
4 page(s), 8,161 characters, converted from the PDF's text layer · plain text.
Full text
Case 1:26-cv-24485-RKA Document 40-3 Entered on FLSD Docket 08/28/2026 Page 1 of 4
Exhibit 1
Case
7/1/26, 10:22 AM1:26-cv-24485-RKA
Grant &Document
Eisenhofer Files40-3 Entered
Class Action on FLSD
Lawsuit Against CitadelDocket
Securities 08/28/2026 Page
LLC and Virtu Americas LLC2 of 4
Jun 29, 2026 5:19 PM Eastern Daylight Time
Grant & Eisenhofer Files Class Action Lawsuit
Against Citadel Securities LLC and Virtu
Americas LLC
Share
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.”
Share
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
https://www.businesswire.com/news/home/20260629282533/en/Grant-Eisenhofer-Files-Class-Action-Lawsuit-Against-Citadel-Securities-LLC-and-Virtu… 1/6
Case
7/1/26, 10:22 AM1:26-cv-24485-RKA
Grant &Document
Eisenhofer Files40-3 Entered
Class Action on FLSD
Lawsuit Against CitadelDocket
Securities 08/28/2026 Page
LLC and Virtu Americas LLC3 of 4
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].
https://www.businesswire.com/news/home/20260629282533/en/Grant-Eisenhofer-Files-Class-Action-Lawsuit-Against-Citadel-Securities-LLC-and-Virtu… 2/6
Case
7/1/26, 10:22 AM1:26-cv-24485-RKA
Grant &Document
Eisenhofer Files40-3 Entered
Class Action on FLSD
Lawsuit Against CitadelDocket
Securities 08/28/2026 Page
LLC and Virtu Americas LLC4 of 4
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]
More News From Grant &
Eisenhofer P.A.
Get RSS Feed
https://www.businesswire.com/news/home/20260629282533/en/Grant-Eisenhofer-Files-Class-Action-Lawsuit-Against-Citadel-Securities-LLC-and-Virtu… 3/6