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SECURITIES\n    LITIGATION                                       DECISION AND ORDER\n\n\n\n\n    THIS DOCUMENT RELATES TO ALL ACTIONS\n\n\nVICTOR MARRERO, United States District Judge.\n\n        Lead   Plaintiff     James   Pappas1   (\u201cPlaintiff\u201d      or   \u201cLead\n\nPlaintiff\u201d) brought this consolidated class action against\n\nQutoutiao, Inc. (\u201cQTT\u201d or the \u201cCompany\u201d), its officers and\n\ndirectors2 (the \u201cIndividual Defendants,\u201d and together with\n\nQTT, the \u201cCompany Defendants\u201d), and its underwriters3 (the\n\n\n1 The Court notes that on July 8, 2025, Lead Counsel for the Class filed\n\na suggestion of death providing notice that Lead Plaintiff James Pappas\nhad died. (See Dkt. No. 129.). Following this notice, the Parties\nexchanged pre-motion letters regarding Lead Counsel\u2019s anticipated motion\nto substitute Rosemary Korines pursuant to Federal Rule of Civil Procedure\n25(a) (Dkt. Nos. 130-134). On August 18, 2025, the Court issued a Joint\nStipulation and Order pursuant to which the Parties stipulated that\nDefendants would withdraw their letter opposition to the pre-motion letter\nseeking the substitution of Rosemary Korines, the executor of James\nPappas\u2019 estate, as Lead Plaintiff. (Dkt. No. 142.) Courts in this Circuit\nhave allowed the \u201csubstitution of a deceased shareholder-plaintiff by the\nexecutors of his estate in a derivative action, holding that the executors\nwould possess \u2018shareholder\u2019 standing as long as the decedent did because\nany shares owned by the decedent \u2018passed into [his] estate by operation\nof law.\u2019\u201d Roe v. City of New York, No. 00-CV-9062, 2003 WL 22715832, at\n*3 (S.D.N.Y. Nov. 19, 2003) (quoting Saylor v. Bastedo, 623 F.2d 230,\n237-38 (2d Cir. 1980)).\n2 The Individual Defendants are Eric Tan (\u201cTan\u201d), Lei Li (\u201cL. Li\u201d), Jingbo\n\nWang (\u201cWang\u201d), Shaoqing Jiang (\u201cJiang\u201d), Jianfei Dong (\u201cDong\u201d), Oliver\nYucheng Chen (\u201cChen\u201d), Yongbo Dai (\u201cDai\u201d), James Jun Peng (\u201cPeng\u201d), and\nFeng Li (\u201cF. Li\u201d).\n3  The Underwriter Defendants are Citigroup Global Markets Inc.\n(\u201cCitigroup\u201d), Deutsche Bank Securities Inc. (\u201cDeutsche Bank\u201d), China\nMerchants Securities (HK) Co., Ltd. (\u201cChina Merchants\u201d), UBS Securities\n\n\n                                     1\n\fCase 1:20-cv-06707-VM     Document 144     Filed 02/05/26   Page 2 of 51\n\n\n\n\u201cUnderwriter    Defendants,\u201d         and   together    with      the   Company\n\nDefendants, the \u201cDefendants\u201d). Plaintiff, an investor in QTT,\n\nasserts    claims   under      the    Securities      Act   of    1933     (the\n\n\u201cSecurities Act\u201d) for alleged misstatements and omissions in\n\nconnection with QTT\u2019s initial public offering (\u201cIPO\u201d) in\n\nSeptember 2018 and its secondary public offering (\u201cSPO,\u201d and\n\ntogether with the IPO the \u201cOfferings\u201d) in April 2019. (See\n\nDkt.   No.   118    [hereafter       \u201cSecond    Amended     Complaint\u201d      or\n\n\u201cSAC\u201d].)\n\n       Defendants       QTT,   the     Individual       Defendants,         and\n\nCitigroup, Deutsche Bank, China Merchants, UBS, Keybanc, and\n\nJefferies now move to dismiss the Second Amended Complaint in\n\nits entirety for failure to state a claim pursuant to Federal\n\nRule of Civil Procedure 12(b)(6) (\u201cRule 12(b)(6)\u201d). (See Dkt.\n\nNo. 122 [hereafter the \u201cMotion\u201d or \u201cMot.\u201d].)4 For the reasons\n\ndiscussed below, Defendants\u2019 Motion is GRANTED.\n\n\n\n\nLLC (\u201cUBS\u201d), Keybanc Capital Markets, Inc. (\u201cKeybanc\u201d), CLSA Limited\n(\u201cCLSA\u201d), Haitong International Securities Company Limited (\u201cHaitong\u201d),\nJefferies Group LLC (\u201cJefferies\u201d), and Lighthouse Capital International\nInc. (\u201cLighthouse\u201d).\n4 Three of the Underwriter Defendants, specifically, CLSA, Haitong, and\nLighthouse, entered into stipulations with Plaintiff preserving their\nright to move to dismiss on other grounds if the Court denies this Motion\nin whole or in part. (See Dkt. No. 121.) They did not join this Motion.\n\n\n\n                                      2\n\fCase 1:20-cv-06707-VM      Document 144         Filed 02/05/26        Page 3 of 51\n\n\n\n                             I.     BACKGROUND5\n\n       A.   FACTUAL BACKGROUND\n\n       QTT operates mobile content platforms that distribute\n\nand share entertainment content in China. The QTT smartphone\n\napplication (\u201cQTT App\u201d) aggregates articles and short videos\n\nfrom professional media and freelancers and presents this\n\ncontent in a customized feed for users. QTT generates the\n\nmajority of its revenue by selling advertisements on its\n\nmobile platforms. QTT\u2019s business model targeted consumers who\n\nlived in smaller, provincial cities in China \u2013 known as lower\n\ntier    cities   \u2013   purportedly          because      this      underserved         but\n\ngrowing market had increasing disposable income and spent\n\nmore time on the internet.\n\n        Initially, QTT\u2019s advertising business relied primarily\n\non     third-party        advertising          platforms         to      sell     QTT\u2019s\n\nadvertising      spaces.     For    example,        Baidu,       another        Chinese\n\ninternet    company,       helped        QTT    sell     a    large       volume      of\n\nadvertisements       in    2016    and    2017.     In   February          2018,     QTT\n\nacquired Dianguan, an advertising agent, for approximately\n\n\n\n\n5The following facts are taken from Plaintiff\u2019s Second Amended Complaint,\nwhich the Court must take as true for the purpose of resolving Defendants\u2019\nmotion to dismiss. See Safka Holdings LLC v. iPlay, Inc., 42 F. Supp. 3d\n488, 491 (S.D.N.Y. 2013). Where indicated, the Complaint\u2019s factual\nallegations are supplemented by facts and information drawn from documents\nappended to the Complaint, which are properly before the Court. See\nTannerite Sports, LLC v. NBCUniversal Media LLC, 135 F. Supp. 3d 219, 225\nn.1 (S.D.N.Y. 2015).\n\n\n\n                                          3\n\fCase 1:20-cv-06707-VM   Document 144      Filed 02/05/26   Page 4 of 51\n\n\n\n$2.3 million. QTT subsequently combined Dianguan\u2019s existing\n\ntechnology and its own resources into an in-house advertising\n\nplatform and reduced its reliance on third-party platforms\n\nlike Baidu.\n\n      On September 14, 2018, QTT announced its IPO of 12\n\nmillion American Depository Shares (\u201cADS\u201d) at a price of $7.00\n\nper   share.   On    September    11,   2018,    QTT   filed      its    final\n\namendment to the IPO Registration Statement with the SEC on\n\nForm F-1/A, which was declared effective on September 13,\n\n2018. On September 14, 2018, QTT filed its prospectus on Form\n\n424B (\u201cIPO Prospectus\u201d and together with IPO Registration\n\nStatement, the \u201cIPO Offering Documents\u201d). QTT closed its IPO\n\nin September 2018.\n\n      On March 29, 2019, QTT announced an SPO of 10 million\n\nQTT ADSs at a price of $10.00 per share. On April 1, 2019,\n\nQTT   filed    its   first   and    final     amendment      to    its    SPO\n\nRegistration    Statement    on    Form    F-1/A    (\u201cSPO    Registration\n\nStatement\u201d), which was declared effective shortly thereafter.\n\nOn April 3, 2019, QTT filed its SPO Prospectus on Form 424B4\n\nwith the SEC. The SPO closed in April 2019 (\u201cSPO Prospectus,\u201d\n\nand together with the SPO Registration Statement, the \u201cSPO\n\nOffering Documents\u201d).\n\n      On July 15, 2020, China Central Television (\u201cCCTV\u201d),\n\nChina\u2019s state-controlled broadcaster, reported that certain\n\n\n                                    4\n\fCase 1:20-cv-06707-VM   Document 144    Filed 02/05/26    Page 5 of 51\n\n\n\nadvertisements placed by third-party advertising agents on\n\nQTT\u2019s platform were improper (the \u201cCCTV Report\u201d). As a result\n\nof the CCTV Report, the price of the QTT\u2019s ADSs fell by more\n\nthan 24 percent and the QTT App was temporarily removed from\n\nseveral major app stores in China for two weeks, although the\n\nQTT App was still available to existing users. In response,\n\nQTT enacted several remedial measures to identify and remove\n\nproblematic     advertisements.    On    December        16,   2020,     QTT\n\nreported a revenue decline for the third quarter of 2020,\n\nwith a 19.7 percent decline in year-over-year revenue and a\n\n23.1 percent decline in advertising revenue. These third\n\nquarter 2020 financials allegedly triggered a significant\n\nshare price decline.\n\n      B.    THE PARTIES\n\n      Plaintiff purchased ADSs in September 2018 pursuant or\n\ntraceable to QTT\u2019s IPO and alleges he suffered damages arising\n\nfrom federal securities law violations.\n\n      The SAC names three types of defendants. The first is\n\nthe company QTT. The second are the Individual Defendants,\n\nwho are current or former employees of QTT. The third are the\n\nUnderwriter Defendants who underwrote either QTT\u2019s IPO or\n\nSPO, or both.\n\n      The SAC names nine Individual Defendants, each of whom\n\nallegedly participated in the preparation of, signed and/or\n\n\n                                  5\n\fCase 1:20-cv-06707-VM    Document 144     Filed 02/05/26   Page 6 of 51\n\n\n\nauthorized the signing of QTT\u2019s IPO and/or SPO documents.\n\nSpecifically, the SAC names: (1) Tan, QTT\u2019s co-founder and\n\nits Chief Executive Officer (\u201cCEO\u201d) since May 20, 2019; (2)\n\nL. Li, QTT\u2019s co-founder and CEO until May 2019 when he\n\nresigned from the Company; (3) Wang, a director at QTT and\n\nthe Company\u2019s Chief Financial Officer (\u201cCFO\u201d) until January\n\n22, 2020; (4) Jiang, a director of QTT and a member of its\n\nAudit Committee and Compensation Committee until September\n\n13, 2019; (5) Dong, a director of QTT and Co-President of\n\nQTT; (6) Chen, a director of QTT and QTT\u2019s Chief Strategy\n\nOfficer from August 2018 to February 2020; (7) Dai, a director\n\nof QTT beginning in November 2018; (8) Peng, a director of\n\nQTT, a member of its Audit Committee and Nominating and\n\nCorporate Governance Committee, and Chair of the Compensation\n\nCommittee; and (9) F. Li, a director of QTT.\n\n      Lastly,   the     SAC   names   nine    Underwriter     Defendants,\n\nspecifically: (1) Citigroup, a multinational investment bank\n\nand financial services corporation who served as underwriter\n\nfor QTT\u2019s IPO and SPO; (2) Deutsche Bank, a financial services\n\ninstitution that served as underwriter to QTT\u2019s IPO and SPO;\n\n(3) China Merchants, a China-based financial services company\n\nthat served as underwriter for QTT\u2019s IPO; (4) UBS, which\n\nprovides   investment     banking     and    financial     services,      and\n\nserved as an underwriter for QTT\u2019s IPO; (5) Keybanc, which\n\n\n                                      6\n\fCase 1:20-cv-06707-VM   Document 144      Filed 02/05/26   Page 7 of 51\n\n\n\nprovides   investment    advisory       services,    and     served   as   an\n\nunderwriter for QTT\u2019s IPO; (6) CLSA, a capital markets and\n\ninvestment group that served as an underwriter for QTT\u2019s SPO;\n\n(7) Haitong, an international financial institution that\n\nserved as an underwriter for QTT\u2019s SPO; (8) Jefferies, an\n\ninvestment banking firm that served as underwriter for QTT\u2019s\n\nSPO; and (9) Lighthouse, a boutique investment bank that\n\nserved as underwriter for QTT\u2019s SPO.\n\n      C.    PROCEDURAL HISTORY\n\n      On August 20, 2020, Plaintiff initiated this action\n\nagainst    QTT   and    multiple        individual     and     underwriter\n\ndefendants, bringing claims alleging violations of Sections\n\n11 (\u201cSection 11\u201d) and 15 (\u201cSection 15\u201d) of the Securities\n\nAct, and Sections 10(b) and (20)(a) of the Securities Exchange\n\nAct of 1934 (the \u201cExchange Act\u201d).6 (See Dkt. No. 1.) On\n\nNovember 4, 2020, Judge Sidney Stein, who originally presided\n\nover this action, consolidated this case with action No. 20-\n\nCV-7717 and named James Pappas as lead plaintiff. (See Dkt.\n\nNo. 22.) On January 15, 2021, Plaintiff filed an Amended\n\nComplaint, which added claims alleging violations of Section\n\n\n\n\n6 Specifically, the individual defendants were Tan, L. Li, Wang, Jiang,\nDong, and Chen. The underwriter defendants were China Merchants,\nCitigroup, Deutsche, KeyBanc, and UBS.\n\n\n\n                                    7\n\fCase 1:20-cv-06707-VM        Document 144      Filed 02/05/26   Page 8 of 51\n\n\n\n12(a)(2) (\u201cSection 12(a)(2)\u201d) of the Securities Act. (See\n\nDkt. No. 41.)\n\n        On March 16, 2021, Defendants moved to dismiss the\n\nAmended Complaint under Rule 12(b)(6) for failure to state a\n\nclaim. (See Dkt. Nos. 49, 53.) On August 3, 2023, Judge Stein\n\nruled    in    favor    of    Defendants      and    dismissed       the   Amended\n\nComplaint in its entirety. (See Dkt. No. 108.) Judge Stein\n\nconcluded that Plaintiff had not adequately pleaded that\n\nDefendants had made misstatements or omissions of material\n\nfact in violation of the Exchange Act. (See id.) Judge Stein\n\nalso found that Plaintiff\u2019s Securities Act claims sounded in\n\nfraud and thus were subject to a heightened pleading standard\n\nunder Federal Rule of Civil Procedure Rule 9(b) (\u201cRule 9(b)\u201d).\n\n(See    id.)   Applying       the    Rule     9(b)   standard,       Judge   Stein\n\ndismissed      the     Securities     Act     claims    because      Plaintiff\u2019s\n\nallegations were not pleaded with sufficient particularity as\n\nto each Defendant. (See id.)\n\n        Plaintiff appealed only the dismissal of the Securities\n\nAct claims, arguing that Judge Stein erred in applying the\n\nRule 9(b) pleading standard. The Second Circuit agreed and\n\nvacated the district court\u2019s dismissal of the Securities Act\n\nclaims. (See Dkt. No. 113.) The Second Circuit explained that\n\nPlaintiff\u2019s      Securities         Act   claims     sounded    in    negligence\n\nrather than fraud and thus were subject to review under the\n\n\n                                          8\n\fCase 1:20-cv-06707-VM   Document 144     Filed 02/05/26    Page 9 of 51\n\n\n\nRule    8(a)   notice    pleading       standard,    not     Rule    9(b)\u2019s\n\nheightened pleading standard. (See id.) The Second Circuit\n\ndeclined to address whether Plaintiff\u2019s Securities Act claims\n\nwere sufficiently pleaded under Rule 8(a) and stated that the\n\nparties\u2019   other    arguments    remained     available      to     them   on\n\nremand. (See id.)\n\n       On remand, this action was reassigned to this Court.\n\nPlaintiff subsequently filed the Second Amended Complaint,\n\nbringing claims under Sections 11, 12(a)(2), and 15 of the\n\nSecurities Act, and no longer asserting claims under the\n\nExchange Act. Defendants filed their motion to dismiss7 with\n\nan accompanying memorandum of law, (\u201cDefs.\u2019 Mem.,\u201d Dkt. No.\n\n123), to which Plaintiff filed an opposition, (\u201cPl.\u2019s Opp\u2019n,\u201d\n\nDkt. No. 131) and Defendants filed a reply (\u201cDefs.\u2019 Reply,\u201d\n\nDkt. No. 143).\n\n\n\n\n7 In support of their motion to dismiss, Defendants filed a declaration\nwith multiple documents included as exhibits, including excerpts of SEC\nfilings and a Wolfpack Research Report. (See Dkt. No. 124.) The Court\ntakes judicial notice of these documents as matters properly considered\nat the pleading stage. See ATSI Commc\u2019ns, Inc. v. Shaar Fund, Ltd., 493\nF.3d 87, 98 (2d Cir. 2007) (\u201c[W]e may consider any written instrument\nattached to the complaint, statements or documents incorporated into the\ncomplaint by reference, legally required public disclosure documents\nfiled with the SEC, and documents possessed by or known to the plaintiff\nand upon which it relied in bringing the suit.\u201d); Staehr v. Hartford Fin.\nServs. Grp., Inc., 547 F.3d 406, 425 (2d Cir. 2008) (\u201c[I]t is proper to\ntake judicial notice of the fact that press coverage, prior lawsuits, or\nregulatory filings contained certain information, without regard to the\ntruth of their contents.\u201d).\n\n\n\n                                    9\n\fCase 1:20-cv-06707-VM     Document 144      Filed 02/05/26   Page 10 of 51\n\n\n\n                         II.   STANDARD OF REVIEW\n\n         \u201cTo survive a motion to dismiss, a complaint must contain\n\n sufficient factual matter, accepted as true, to \u2018state a claim\n\n to relief that is plausible on its face.\u2019\u201d Ashcroft v. Iqbal,\n\n 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly,\n\n 550 U.S. 544, 570 (2007)). A claim is plausible if the\n\n complaint     states    \u201c\u2018enough    fact      to    raise    a   reasonable\n\n expectation that discovery will reveal evidence of illegal\u2019\n\n conduct\u201d \u2014 there is not \u201ca probability requirement at the\n\n pleading stage.\u201d Lynch v. City of New York, 952 F.3d 67, 75\n\n (2d Cir. 2020) (quoting Twombly, 550 U.S. at 556); see Iqbal,\n\n 556 U.S. at 678 (\u201cA claim has facial plausibility when the\n\n plaintiff pleads factual content that allows the court to\n\n draw the reasonable inference that the defendant is liable\n\n for the misconduct alleged.\u201d). \u201cIn other words, a complaint\n\n should     not   be    dismissed    when     the    factual      allegations\n\n sufficiently \u2018raise a right to relief above the speculative\n\n level.\u2019\u201d Liboy v. Russ, No. 22-CV-10334, 2023 WL 6386889, at\n\n *4 (S.D.N.Y. Sept. 29, 2023) (quoting Twombly, 550 U.S. at\n\n 555).\n\n         In reviewing a motion to dismiss under Rule 12(b)(6),\n\n the Court must \u201cconstru[e] the complaint liberally, accepting\n\n all factual allegations in the complaint as true, and drawing\n\n all     reasonable     inferences    in      the    plaintiff\u2019s      favor.\u201d\n\n\n                                     10\n\fCase 1:20-cv-06707-VM    Document 144     Filed 02/05/26   Page 11 of 51\n\n\n\n Goldstein v. Pataki, 516 F.3d 50, 56 (2d Cir. 2008) (citation\n\n omitted). The Court may also \u201cconsider documents attached to\n\n the pleadings, documents referenced in the pleadings, or\n\n documents that are integral to the pleadings in order to\n\n determine if a complaint should survive a [Rule] 12(b)(6)\n\n motion.\u201d Garcia v. Lewis, No. 05-CV-1153, 2005 WL 1423253, *3\n\n (S.D.N.Y. June 16, 2005); see also ATSI Commc\u2019ns, Inc. v.\n\n Shaar Fund, Ltd., 493 F.3d 87, 98 (2d Cir. 2007) (\u201c[W]e may\n\n consider any written instrument attached to the complaint,\n\n statements or documents incorporated into the complaint by\n\n reference, legally required public disclosure documents filed\n\n with the SEC, and documents possessed by or known to the\n\n plaintiff and upon which it relied in bringing the suit.\u201d).\n\n                            III. DISCUSSION\n\n      Plaintiff brings Counts I, II, and III under Sections\n\n 11, 12(a)(2), and 15 of the Securities Act, respectively.\n\n (See SAC \u00b6\u00b6 137-65.) Plaintiff argues that QTT\u2019s IPO Offering\n\n Documents   and   SPO    Offering      Documents     (collectively        the\n\n \u201cOffering Documents\u201d) contained material misstatements and\n\n omissions of fact that caused financial losses to Plaintiff\n\n and other investors. Plaintiff\u2019s allegations regarding such\n\n misstatements and omissions of material fact generally fall\n\n into the following categories: (1) QTT misrepresented that it\n\n had an effective screening program to prevent the placement\n\n\n                                     11\n\fCase 1:20-cv-06707-VM      Document 144     Filed 02/05/26     Page 12 of 51\n\n\n\n of illegal advertisements on the QTT app, including the use\n\n of artificial intelligence to screen advertisements (id. \u00b6\u00b6\n\n 107-08, 122); (2) QTT omitted from the Offering Documents\n\n that it was actively placing a material amount of illegal\n\n advertisements on the QTT app at the time of the IPO and SPO\n\n (id. \u00b6\u00b6 109-11, 125-27); (3) a material amount of QTT\u2019s\n\n revenue      growth   came    from    placing     illegal     advertisements\n\n rather than from a strategy of targeting underserved users in\n\n lower tier cities (id. \u00b6\u00b6 8, 99-101, 116-17); and (4) QTT\n\n failed to disclose certain related party transactions (id. \u00b6\u00b6\n\n 48-66).\n\n        In response, Defendants argue that: (1) Plaintiff does\n\n not have statutory standing to bring a claim under Section 11\n\n as to the SPO and Section 12(a)(2); and (2) Plaintiff has\n\n failed to state a claim under the Securities Act because none\n\n of     the   challenged      statements     are       materially    false     or\n\n misleading. (See Defs.\u2019 Mem. at 1-4.)\n\n        Regarding standing, the Court finds that while Plaintiff\n\n does have standing to bring his claims against the Defendants\n\n involved in the IPO, he does not have Article III standing to\n\n bring his claims against the Defendants involved only in the\n\n SPO. Additionally, the Court finds that Plaintiff does not\n\n have    statutory     standing   to    bring      a   claim   under    Section\n\n 12(a)(2). Addressing the substance of Plaintiff\u2019s claims, the\n\n\n                                       12\n\fCase 1:20-cv-06707-VM   Document 144    Filed 02/05/26   Page 13 of 51\n\n\n\n Court finds that Plaintiff has failed to state a claim under\n\n the Securities Act because none of the challenged statements\n\n are materially false or misleading. Accordingly, for the\n\n reasons discussed below, the Court will grant Defendants\u2019\n\n Motion.\n\n      A.    STANDING\n\n      Defendants argue that Plaintiff does not have statutory\n\n standing to bring a claim under Section 11 as to the SPO and\n\n Section   12(a)(2).    (See   Defs.\u2019   Mem.   at   25-27.)    Plaintiff\n\n argues that he has standing to bring all the claims asserted\n\n in this action and that the law of the case doctrine prevents\n\n this Court from reconsidering Judge Stein\u2019s prior holding\n\n that Plaintiff had standing. (See Pl.\u2019s Opp\u2019n at 24-25.)\n\n      As an initial matter, the \u201c[l]aw of the case doctrine is\n\n prudential and discretionary in character, and courts \u2018always\n\n [have] the power to change a ruling\u201d in light of \u2018further\n\n reflection[.]\u2019\u201d Laurent v. PricewaterhouseCoopers LLP, 963 F.\n\n Supp. 2d 310, 314 (S.D.N.Y. 2013) (quoting Corporacion de\n\n Mercadeo Agricola v. Mellon Bank Int\u2019l, 608 F.2d 43, 48 (2d\n\n Cir.1979) (internal citations omitted); see also American\n\n Hotel Int\u2019l Grp., Inc. v. OneBeacon Ins. Co., 611 F. Supp. 2d\n\n 373, 379 (S.D.N.Y. 2009), aff\u2019d, 374 F. App\u2019x 71 (2d Cir.\n\n 2010) (\u201c[W]hen an appellate court does not address an issue\n\n that a trial court decided, the trial court on remand has the\n\n\n                                  13\n\fCase 1:20-cv-06707-VM       Document 144        Filed 02/05/26    Page 14 of 51\n\n\n\n discretion to determine whether its prior determination on an\n\n issue should be disturbed.\u201d).\n\n        In this matter, the Second Circuit explicitly stated\n\n that    it    did   \u201cnot    reach       the    parties\u2019    other     arguments,\u201d\n\n including arguments as to standing, \u201call of which remain\n\n available to them on remand.\u201d (Dkt. No. 113 at 8.) Given the\n\n discretionary nature of the law of the case doctrine and the\n\n Second Circuit\u2019s implication that the standing argument would\n\n remain       available     on     remand,       the    Court      will     address\n\n Defendants\u2019         arguments      regarding          Plaintiff\u2019s        standing,\n\n beginning with whether Plaintiff has standing to bring the\n\n Section 11 claim as to the SPO.\n\n               1.     Standing for the Section 11 Claim\n\n        Regarding standing to assert the Section 11 claim as to\n\n the    SPO,    Defendants       argue    the    Plaintiff       lacks    statutory\n\n standing because he cannot trace his shares to the SPO. (See\n\n Defs.\u2019 Mem. at 25-27.) Specifically, Defendants contend that\n\n because Plaintiff purchased his QTT shares in September 2018,\n\n six months before the April 2019 SPO, his shares are not\n\n traceable to that SPO, as is required to claim statutory\n\n standing under Section 11. (See id.) Plaintiff argues that\n\n under Federal Rule of Civil Procedure 23 (\u201cRule 23\u201d), a\n\n plaintiff can litigate injuries on behalf of putative class\n\n members. (See Pl.\u2019s Opp\u2019n at 24-25.)\n\n\n                                          14\n\fCase 1:20-cv-06707-VM   Document 144    Filed 02/05/26    Page 15 of 51\n\n\n\n       In making these arguments, Plaintiff and Defendants\n\n appear to be speaking past one another. Defendants\u2019 argument\n\n concerns whether Plaintiff has statutory standing, while\n\n Plaintiff\u2019s     argument   that   Rule      23   gives    him    standing\n\n implicates the distinct concept of class action standing. To\n\n properly address the standing issue, and before turning to\n\n statutory standing, the Court will first analyze whether\n\n Plaintiff has sufficiently established Article III standing\n\n and the related concept of class standing.\n\n                  a. Article III Standing\n\n       \u201cThe   \u2018threshold    question    in   every   federal     case\u2019     is\n\n \u2018whether the plaintiff has made out a case or controversy\n\n between [themselves] and the defendant within the meaning of\n\n [Article] III.\u201d Won v. Amazon.com Servs. LLC, No. 21-CV-2867,\n\n 2025 WL 2962616, at *5 (E.D.N.Y. Oct. 21, 2025) (quoting\n\n Denney v. Deutsche Bank AG, 443 F.3d 253, 263 (2d Cir. 2006)).\n\n Article III \u201c[s]tanding in the class action context requires\n\n a bifurcated inquiry.\u201d Petrosino v. Stearn\u2019s Prod., Inc., No.\n\n 16-CV-7735, 2018 WL 1614349, at *5 (S.D.N.Y. Mar. 30, 2018).\n\n As part of this bifurcated inquiry, courts in this Circuit\n\n first examine whether the individual plaintiff has satisfied\n\n the   minimum    requirements     of   \u201ctraditional\u201d       Article       III\n\n standing before determining whether the plaintiff has class\n\n\n\n\n                                   15\n\fCase 1:20-cv-06707-VM    Document 144    Filed 02/05/26   Page 16 of 51\n\n\n\n standing.   See   id.   (\u201cFirst,   Plaintiff      must   establish       the\n\n minimum requirements of Article III standing[.]\u201d).\n\n      To establish \u201ctraditional\u201d Article III standing, an\n\n individual plaintiff must have \u201c(1) suffered an injury in\n\n fact, (2) that is fairly traceable to the challenged conduct\n\n of the defendant, and (3) that is likely to be redressed by\n\n a favorable judicial decision.\u201d Spokeo, Inc. v. Robins, 578\n\n U.S. 330, 338 (2016), as revised (May 24, 2016) (citing Lujan\n\n v. Defenders of Wildlife, 504 U.S. 555, 560\u201361 (1992)). \u201cIn\n\n the context of class actions, Article III standing requires\n\n that \u2018for every named defendant there must be at least one\n\n named plaintiff who can assert a claim directly against that\n\n defendant.\u2019\u201d Youngers v. Virtus Inv. Partners Inc., 195 F.\n\n Supp. 3d 499, 510 (S.D.N.Y. 2016) (quoting NECA-IBEW Health\n\n & Welfare Fund v. Goldman Sachs & Co., 693 F.3d 145, 159 (2d\n\n Cir. 2012)). If that requirement is satisfied, the inquiry\n\n shifts to a class standing analysis. See Point12 Diversified\n\n Fund, LP v. TMC The Metals Co., No. 21-CV-5991, 2025 WL\n\n 1920340, at *9 (E.D.N.Y. July 11, 2025) (\u201cIn putative class\n\n actions, the standing analysis does not stop there. After\n\n \u2018traditional\u2019 Article III standing has been established,\n\n [courts] consider \u2018class standing\u2019 \u2014 that is, the named\n\n plaintiff[\u2018s]\n\n\n\n\n                                    16\n\fCase 1:20-cv-06707-VM         Document 144       Filed 02/05/26        Page 17 of 51\n\n\n\n ability (and incentive) to press the claims of absent class\n\n members.\u201d)\n\n       Here, the Plaintiff can satisfy \u201ctraditional\u201d Article\n\n III standing for the Section 11 claim for some, but not all\n\n Defendants.       Plaintiff        plausibly      alleges        a    monetary        loss\n\n caused by his investment in QTT securities that could be\n\n redressed through rights of action for damages under Section\n\n 11. However, for causation, his injury is fairly traceable\n\n only to the alleged misstatements and omissions by Defendants\n\n involved     in   the    IPO.      Plaintiff      purchased           QTT   securities\n\n related to the IPO only in September 2018. Therefore, his\n\n injury   can      be    \u201cfairly     traceable\u201d        only       to     the   material\n\n misstatements and omissions made by the Defendants involved\n\n in the IPO. Spokeo, 578 U.S. at 338. Since Plaintiff did not\n\n purchase shares of the SPO, which took place months later in\n\n April 2019, his injury could not have been caused by the\n\n material misstatements and omissions made only by Defendants\n\n involved in the SPO.\n\n       Therefore, while Plaintiff has Article III standing to\n\n pursue claims against Defendants involved in the IPO, he does\n\n not   have   Article         III   standing      to   pursue         claims    against\n\n Defendants who were involved only in the SPO. Because \u201cfor\n\n every named defendant there must be at least one named\n\n plaintiff     who      can   assert    a    claim     directly          against       that\n\n\n                                            17\n\fCase 1:20-cv-06707-VM   Document 144   Filed 02/05/26   Page 18 of 51\n\n\n\n defendant,\u201d the Section 11 claims must be dismissed as to the\n\n Defendants who were involved only in the SPO. See NECA, 693\n\n F.3d at 159 (quoting Cent. States Se. & Sw. Areas Health &\n\n Welfare Fund v. Merck\u2013Medco Managed Care, L.L.C., 504 F.3d\n\n 229, 241 (2d Cir. 2007)). Specifically, Plaintiff does not\n\n have standing against the individuals Dai, Peng, and F. Li,\n\n and underwriters Haitong, Jefferies, CLSA, and Lighthouse\n\n since these defendants were alleged to be involved only in\n\n the SPO and had no involvement in the IPO in which Plaintiff\n\n actually purchased shares. (See SAC \u00b6\u00b6 23-47.) The remaining\n\n Defendants are those who had involvement in the IPO, which\n\n includes some Defendants who were involved in both the IPO\n\n and SPO Offerings. Because this litigation entails a class\n\n action, the next step in the bifurcated Article III standing\n\n inquiry is to address class standing as to the remaining\n\n Defendants.\n\n                  b. Class Standing\n\n      \u201cAfter   \u2018traditional\u2019     Article    III   standing     has      been\n\n established, [courts] consider \u2018class standing\u2019 \u2014 that is,\n\n the named plaintiff[\u2018s] ability (and incentive) to press the\n\n claims of absent class members.\u201d Point12 Diversified Fund,\n\n 2025 WL 1920340, at *9. Through class standing a \u201cnamed\n\n plaintiff may bring claims on behalf of unnamed class members\n\n for a different violation of the same statute upon which the\n\n\n                                  18\n\fCase 1:20-cv-06707-VM         Document 144   Filed 02/05/26    Page 19 of 51\n\n\n\n named plaintiff rests his claims if that plaintiff \u2018plausibly\n\n alleges (1) that he personally has suffered some actual injury\n\n as   a    result      of    the   putatively    illegal      conduct   of      the\n\n defendant, and (2) that such conduct implicates the same set\n\n of concerns as the conduct alleged to have caused injury to\n\n other members of the putative class by the same defendants.\u2019\u201d\n\n Lozada v. TaskUs, Inc., 710 F. Supp. 3d 283, 312\u201313 (S.D.N.Y.\n\n 2024) (quoting NECA, 693 F.3d at 162). \u201cConduct \u2018implicates\n\n the same set of concerns\u2019 when the conduct that injured the\n\n named plaintiff and the conduct that injured the absent class\n\n members can be proven in a similar way\u201d against the same\n\n defendants. In re Bibox Grp. Holdings Ltd. Sec. Litig., 534\n\n F. Supp. 3d 326, 335 (S.D.N.Y. 2021) (quoting NECA, 693 F.3d\n\n at 163).\n\n          Here,   as        discussed   above,    it    has     already        been\n\n established that Plaintiff has Article III standing as to a\n\n Section 11 claim for the defendants involved in the IPO, but\n\n not for those involved in the SPO. However, some of these\n\n Defendants involved in the IPO were also involved in the SPO.\n\n Specifically, Defendants QTT, L. Li, Wang, Jaing, Dong, Chen,\n\n Citigroup, and Deutsche Bank were involved in both the IPO\n\n and SPO Offerings. The question then is whether Plaintiff,\n\n having the necessary individual standing to bring a Section\n\n 11 claim as to the Defendants involved in the IPO, can bring\n\n\n                                        19\n\fCase 1:20-cv-06707-VM   Document 144     Filed 02/05/26   Page 20 of 51\n\n\n\n claims   on   behalf   of   the   unnamed    putative    class    members\n\n relating to the SPO against the Defendants involved in both\n\n Offerings.\n\n      The misstatements and omissions made in the IPO and SPO\n\n are sufficiently similar to plead class standing for the\n\n Section 11 claim as to the SPO for Defendants involved in\n\n both Offerings. While there are slight differences in wording\n\n between the alleged misstatements in the IPO and SPO Offering\n\n Documents, they raise the \u201csame set of concerns[.]\u201d NECA, 693\n\n F.3d at 162; see also Langan v. Johnson & Johnson Consumer\n\n Companies, Inc., 897 F.3d 88, 94 (2d Cir. 2018)(\u201c[N]on-\n\n identical injuries of the same general character can support\n\n standing.\u201d). Plaintiff would need to rely on substantially\n\n similar evidence to show that the misstatements and omissions\n\n contained in both the IPO and SPO relating to QTT\u2019s corporate\n\n strategy and business decisions, financial results, and its\n\n alleged failure to disclose related party transactions were\n\n materially    misleading.     Because     Plaintiff      has   plausibly\n\n alleged that he \u201c(1) personally has suffered some actual\n\n injury as a result of the putatively illegal conduct of the\n\n defendant,\u201d and (2) the conduct \u201cimplicates the same set of\n\n concerns as the conduct alleged to have caused injury to other\n\n members of the putative class by the same defendants,\u201d class\n\n standing as to the Section 11 SPO claims relating to the\n\n\n                                    20\n\fCase 1:20-cv-06707-VM     Document 144      Filed 02/05/26    Page 21 of 51\n\n\n\n Defendants involved both Offerings is proper. NECA, 693 F.3d\n\n at 162 (internal citations and ellipsis omitted).\n\n                   c. Statutory Standing\n\n       Distinct from \u201ctraditional\u201d Article III standing and the\n\n related \u201cclass standing\u201d inquiry is statutory standing, which\n\n asks whether the plaintiff\u2019s claims fall within the scope of\n\n a   statute.    See    Lexmark   Intern.,      Inc.   v.    Static    Control\n\n Components, Inc., 572 U.S. 118, 128 n.4 (2014). Statutory\n\n standing arguments are more \u201cabout the scope of the cause of\n\n action because they do not, as standing does, go to [the]\n\n Court\u2019s subject matter jurisdiction.\u201d Lozada, 710 F. Supp. 3d\n\n at 311 n.19.\n\n       Here, the Defendants challenge Plaintiff\u2019s statutory\n\n standing to bring certain claims under the Securities Act.\n\n Specifically,     the     Defendants         allege   that     because       the\n\n Plaintiff did not purchase shares from the SPO, his claims\n\n are not traceable to that offering as is required under\n\n Section   11.    \u201cTo    bring    a   claim    under   [Section]      11,     the\n\n securities held by the plaintiff must be traceable to the\n\n particular registration statement alleged to be false or\n\n misleading.\u201d Slack Techs., LLC v. Pirani, 598 U.S. 759, 768\n\n (2023). While Defendants\u2019 analysis is correct in the context\n\n of individual standing, the Plaintiff here has class standing\n\n as to certain Defendants.\n\n\n                                       21\n\fCase 1:20-cv-06707-VM   Document 144    Filed 02/05/26   Page 22 of 51\n\n\n\n      As discussed above, Plaintiff has class standing to\n\n bring a Section 11 claim as to the SPO on behalf of the\n\n unnamed putative class members against Defendants QTT, L. Li,\n\n Wang, Jaing, Dong, Chen, Citigroup, and Deutsche Bank, who\n\n were all involved in both the IPO and SPO offerings. While\n\n Plaintiff does not have individual statutory standing against\n\n these defendants to make a Section 11 claim as to the SPO,\n\n this circumstance does not constitute a material issue, as\n\n class standing allows him to pursue claims on behalf of the\n\n unnamed putative class members who can satisfy Section 11\n\n statutory   standing    by   tracing    their     securities     to     the\n\n statements in the SPO Offering Documents. Thus, the fact that\n\n Plaintiff does not individually have statutory standing for\n\n the SPO claim is remedied by class standing, which allows the\n\n Plaintiff to pursue the Section claim on behalf of unnamed\n\n putative class members as to the SPO. See NECA 693 F.3d at\n\n 158 (finding class standing applied even where plaintiff did\n\n not individually have statutory standing to pursue certain\n\n claims).\n\n             2.   Section 12(a)(2) Statutory Standing\n\n      Section 12(a)(2) of the Securities Act grants purchasers\n\n of securities an express cause of action against sellers who\n\n make material misstatements or omissions \u201cby means of a\n\n prospectus.\u201d 15 U.S.C. \u00a7 77l(a)(2). In the context of Section\n\n\n                                  22\n\fCase 1:20-cv-06707-VM     Document 144      Filed 02/05/26    Page 23 of 51\n\n\n\n 12(a)(2), the word \u201c\u2018prospectus\u2019 is a term of art referring\n\n to a document that describes a public offering of securities\n\n by an issuer or controlling shareholder.\u201d Gustafson v. Alloyd\n\n Co., 513 U.S. 561, 584 (1995). Thus, to have statutory\n\n standing    under    Section     12(a)(2),        \u201cplaintiffs     must       have\n\n purchased   securities        directly     from     the    defendants\u201d   in    a\n\n \u201cpublic offering[].\u201d Freidus v. Barclays Bank PLC, 734 F.3d\n\n 132, 141 (2d Cir. 2013); see In re Smart Techs. Inc. S\u2019holder\n\n Litig., 295 F.R.D. 50, 57 (S.D.N.Y. 2013) (\u201cIt is well-settled\n\n that a plaintiff may maintain a section 12(a)(2) claim only\n\n where the plaintiff purchased securities directly in the\n\n initial public offering.\u201d).\n\n        Moreover, courts in this Circuit routinely find that\n\n \u201c[p]laintiffs who purchased securities in a secondary market\n\n or aftermarket lack standing\u201d to bring a Section 12(a)(2)\n\n claim. Garnett v. RLX Tech. Inc., 632 F. Supp. 3d 574, 614\n\n (S.D.N.Y. 2022); see also In re Sterling Foster & Co., Inc.,\n\n Sec.   Litig.,     222   F.   Supp.   2d     216,    244    (E.D.N.Y.    2002)\n\n (collecting cases finding that \u201cpurchasers in private or\n\n secondary   market       offerings    are     precluded       from   bringing\n\n actions under Section 12(a)(2)\u201d). Here, Plaintiff concedes\n\n that he did not purchase QTT shares in the IPO or the SPO\n\n directly    from    Defendants.       (See    SAC     n.47.)    Accordingly,\n\n Plaintiff lacks statutory standing to bring a claim under\n\n\n                                       23\n\fCase 1:20-cv-06707-VM     Document 144         Filed 02/05/26   Page 24 of 51\n\n\n\n Section 12(a)(2). See In re HEXO Corp. Sec. Litig., 524 F.\n\n Supp.     3d    283,   305    (S.D.N.Y.       2021)       (dismissing     Section\n\n 12(a)(2)       claim   for    lack    of     standing      because    the   named\n\n plaintiffs did not purchase the company\u2019s shares during the\n\n IPO); In re Cosi, Inc. Sec. Litig., 379 F. Supp. 2d 580, 589\n\n (S.D.N.Y. 2005) (\u201c[B]ecause the plaintiffs have not alleged\n\n that they have purchased their shares in the IPO, they have\n\n failed to allege that they have standing to bring a claim\n\n under [Section] 12(a)(2).\u201d).\n\n         Plaintiff relies on Langan v. Johnson & Johnson Consumer\n\n Companies, Inc., 897 F.3d 88 (2d Cir. 2018), to establish he\n\n has class standing for his Section 12(a)(2) claims because he\n\n has   standing     for   his       Section     11    claims    as    to   certain\n\n defendants.       To   that    extent      his      reliance   on    Langan    is\n\n misplaced. In Langan, the Second Circuit discussed how NECA\n\n stood for the proposition that \u201cnon-identical injuries of the\n\n same general character can support standing.\u201d 897 F.3d at 94.\n\n It also reaffirmed, as NECA did, that \u201c\u2018with respect to each\n\n asserted claim\u2019 against each defendant, \u2018a plaintiff must\n\n always    have    suffered     a     distinct       and   palpable    injury   to\n\n herself.\u2019\u201d Id. at 92. Class standing, as described in Langan\n\n and NECA, \u201cdoes not stand for the sweeping proposition that\n\n an individual may represent absent class members with regard\n\n to claims as to which he or she has no individual standing[.]\u201d\n\n\n                                         24\n\fCase 1:20-cv-06707-VM    Document 144   Filed 02/05/26   Page 25 of 51\n\n\n\n Yi Xiang v. Inovalon Holdings, Inc., 327 F.R.D. 510, 520\n\n (S.D.N.Y. 2018) (quoting Stadnick v. Vivint Solar, Inc., No.\n\n 14-CV-9283, 2015 WL 8492757, at *17 (S.D.N.Y. Dec. 10, 2015),\n\n aff\u2019d, 861 F.3d 31 (2d Cir. 2017)).\n\n       \u201cIn NECA-IBEW Health & Welfare Fund, the Second Circuit\n\n allowed a plaintiff to bring claims on behalf of a class under\n\n the   same   statutes    regarding     different    prospectuses        and\n\n registration statements.\u201d Lozada, 710 F. Supp. 3d at 313.\n\n \u201c[I]t did not, however, allow the ability to bring class\n\n claims that stretch across different statutes.\u201d Id.; see also\n\n Stadnick, 2015 WL 8492757, at *18 (\u201c[P]laintiff here does not\n\n have statutory standing on his own right to pursue a claim\n\n under \u00a7 12(a)(2). Rather than expanding from his own statutory\n\n standing to represent a class of people with the same set of\n\n concerns,    plaintiff     instead     asserts     merely     that      the\n\n similarity between claims under \u00a7 11 and claims under \u00a7\n\n 12(a)(2) is enough. It is not, and plaintiff\u2019s lack of\n\n statutory standing for a \u00a7 12(a)(2) claim is dispositive.\u201d).\n\n       Here, Plaintiff \u201cdoes not have statutory standing in his\n\n own right to pursue a claim under Section 12(a)(2).\u201d Stadnick,\n\n 2015 WL 8492757, at *18. Though Plaintiff does have class\n\n standing to pursue his Section 11 claim as to the SPO against\n\n certain Defendants, this class standing does not \u201cstretch\n\n across different statutes\u201d to Plaintiff\u2019s Section 12(a)(2)\n\n\n                                   25\n\fCase 1:20-cv-06707-VM        Document 144         Filed 02/05/26        Page 26 of 51\n\n\n\n claims.      Lozada,       710   F.   Supp.           3d    at     313.       Therefore,\n\n \u201cplaintiff\u2019s lack of statutory standing for a \u00a7 12(a)(2) claim\n\n is dispositive.\u201d Stadnick, 2015 WL 8492757, at *18. Because\n\n there is not a named plaintiff who has statutory standing to\n\n bring    the    Section      12(a)(2)      claim,          this    action       must     be\n\n dismissed. Having addressed standing, the Court now turns to\n\n the Plaintiff\u2019s remaining claims, beginning with his Section\n\n 11 claim.\n\n         B.     SECTION 11\n\n         \u201cSection 11 establishes liability on the part of issuers\n\n of registration statements if \u2018any part of the registration\n\n statement, when such part became effective, contained an\n\n untrue statement of a material fact or omitted to state a\n\n material fact required to be stated therein or necessary to\n\n make the statements therein not misleading.\u2019\u201d City of Pontiac\n\n Policemen\u2019s & Firemen's Ret. Sys. v. UBS AG, 752 F.3d 173,\n\n 182   (2d      Cir.    2014)     (quoting        15    U.S.C.          \u00a7    77k(a)).     \u201cA\n\n misstatement          or   omission   is         material         if       \u2018there   is    a\n\n substantial       likelihood       that      a     reasonable              person   would\n\n consider the stated or omitted facts important in deciding\n\n whether to buy or sell shares of stock.\u2019\u201d In re Hut 8 Corp.\n\n Sec. Litig., No. 24-CV-904, 2025 WL 2636150, at *12 (S.D.N.Y.\n\n Sept. 12, 2025) (quoting Operating Local 649 Annuity Trust\n\n Fund v. Smith Barney Fund Mgmt. LLC, 595 F.3d 86, 92\u201393 (2d\n\n\n                                         26\n\fCase 1:20-cv-06707-VM    Document 144       Filed 02/05/26   Page 27 of 51\n\n\n\n Cir. 2010) (internal quotation marks omitted)). \u201cTo state a\n\n claim under Section 11, the plaintiff must allege that: (1)\n\n [they] purchased a registered security, either directly from\n\n the issuer or in the aftermarket following the offering; (2)\n\n the   defendant     participated      in   the   offering        in   a   manner\n\n sufficient to give rise to liability under section 11; and\n\n (3) the registration statement \u2018contained an untrue statement\n\n of a material fact or omitted to state a material fact\n\n required to be stated therein or necessary to make the\n\n statements therein not misleading.\u2019\u201d In re Morgan Stanley\n\n Info. Fund Sec. Litig., 592 F.3d 347, 358\u201359 (2d Cir. 2010)\n\n (quoting 15 U.S.C. \u00a7 77k(a)).              \u201cPlaintiffs need not allege\n\n scienter, reliance, or causation.\u201d City of Pontiac, 752 F.3d\n\n at 182.\n\n       Typically,      \u201cin     assessing     [Section]       11    claims,     we\n\n \u2018conduct    a    preliminary     inquiry     into   whether       plaintiffs\u2019\n\n allegations are premised on fraud,\u2019 or merely on negligence,\n\n to determine the appropriate pleading standard.\u201d Id. at 183\n\n (quoting In re Lehman Bros. Mortgage\u2013Backed Sec. Litig., 650\n\n F.3d 167, 174 (2d Cir. 2011)). Here, however, the Second\n\n Circuit has already determined that Plaintiff\u2019s allegations\n\n sound in negligence rather than fraud, making Rule 8 notice\n\n pleading the appropriate standard. (See Dkt. No. 113.) As\n\n discussed       previously,    Rule   8    requires    that      a    complaint\n\n\n                                       27\n\fCase 1:20-cv-06707-VM    Document 144      Filed 02/05/26   Page 28 of 51\n\n\n\n includes \u201cenough facts to state a claim for relief \u2018that is\n\n plausible on its face.\u2019\u201d Laguerre v. Related Mgmt. Co., No.\n\n 25-CV-5594, 2025 WL 2998053, at *1 (S.D.N.Y. Oct. 24, 2025)\n\n (quoting Twombly, 550 U.S. at 570). To prevail, plaintiff\n\n must have alleged \u201cfactual content that allows the court to\n\n draw the reasonable inference that the defendant is liable for\n\n the misconduct alleged.\u201d New Jersey Carpenters Health Fund v.\n\n Royal Bank of Scotland Grp., PLC, 709 F.3d 109, 120-21 (2d\n\n Cir. 2013) (quoting Iqbal, 556 U.S. at 678). \u201c[F]actual\n\n content     that   is   \u2018merely   consistent       with,\u2019     rather       than\n\n suggestive of, a finding of liability will not support a\n\n reasonable inference.\u201d Id. at 121 (quoting Twombly, 550 U.S.\n\n at 556). \u201cAlthough not subject to Rule 9(b)\u2019s heightened\n\n pleading standard, \u2018the complaint must still allege a false\n\n or misleading statement or omission in more than conclusory\n\n terms.\u2019\u201d In re Hut 8, No. 24-CV-904, 2025 WL 2636150, at *11\n\n (quoting Harris v. AmTrust Fin. Servs., Inc., 135 F. Supp. 3d\n\n 155, 170 (S.D.N.Y. 2015), aff\u2019d, 649 F. App\u2019x 7 (2d Cir.\n\n 2016)).\n\n      The SAC alleges multiple misstatements and omissions of\n\n material fact made in the Offering Documents. Specifically,\n\n the SAC alleges that (1) QTT misrepresented that it had an\n\n effective    screening    program    to    prevent     the   placement      of\n\n illegal advertisements on the QTT app, including the use of\n\n\n                                     28\n\fCase 1:20-cv-06707-VM         Document 144       Filed 02/05/26    Page 29 of 51\n\n\n\n artificial intelligence to screen advertisements (SAC \u00b6\u00b6 107-\n\n 08, 122); (2) QTT omitted from stating in the Offering\n\n Documents that it was actively placing a material amount of\n\n illegal advertisements on the QTT app at the time of the IPO\n\n and SPO (id. \u00b6\u00b6 109-11, 125-27); (3) a material amount of\n\n QTT\u2019s revenue growth came from placing illegal advertisements\n\n rather than from a strategy of targeting underserved users in\n\n lower tier cities (id. \u00b6\u00b6 8, 99-101, 116-17); and (4) QTT\n\n failed to disclose certain related party transactions (id. \u00b6\u00b6\n\n 48-66).      The     Court    will    address         each   of   these    alleged\n\n misstatements and omissions in turn.\n\n               1.   QTT\u2019s Statements Regarding the Screening of\n               Illegal Advertisements\n\n        The SAC alleges that QTT misled investors by stating in\n\n its    IPO    Offering        Documents        that    QTT    used    \u201cartificial\n\n intelligence\u201d and \u201cdeep learning methods\u201d to \u201cmonitor and\n\n identify objectionable visual content with a high degree of\n\n accuracy\u201d and flag \u201csuspicious content for manual review.\u201d\n\n (Id.   \u00b6     107).    According      to   Plaintiff,         these   claims       were\n\n misleading because they highlighted the effectiveness of\n\n QTT\u2019s content screening technology without disclosing that\n\n the Company placed ads declined by the screening technology\n\n on the QTT app after a second manual review by QTT employees.\n\n (See id. \u00b6\u00b6 73, 108).\n\n\n\n\n                                           29\n\fCase 1:20-cv-06707-VM      Document 144         Filed 02/05/26    Page 30 of 51\n\n\n\n         Defendants        argue     that        references           to     screening\n\n technology using \u201cartificial intelligence\u201d and \u201cdeep learning\n\n methods\u201d referred not to the screening of advertisements, but\n\n to the screening of user content on the QTT app. (Defs.\u2019 Mem.\n\n at 16-17.)\n\n        Here,   the     Court      agrees       with    Defendants           that     the\n\n references to \u201cartificial intelligence\u201d referred not to the\n\n screening of advertisements, but to the screening of QTT\u2019s\n\n core   content      for   consumers.          The   IPO   Offering          Documents\n\n contained      a      section     titled        \u201cAdvertising,\u201d              that     was\n\n immediately followed by a separate section titled \u201cContent\n\n Screening Technology.\u201d (SAC \u00b6 107.) The \u201cAdvertising\u201d section\n\n discussed QTT\u2019s use of technology to deliver targeted ads to\n\n users, making no mention of artificial intelligence and its\n\n implications for screening illegal ads. (Id.) In the very\n\n next section labeled \u201cContent Screening Technology,\u201d QTT\n\n described its use of \u201cartificial intelligence\u201d and \u201cdeep\n\n learning\u201d      to     decline      and     flag       certain        objectionable\n\n \u201ccontent.\u201d (Id.) This context indicates that the artificial\n\n intelligence        technology     was     being      used      to    screen       user\n\n content, like news articles, rather than advertisements.\n\n        While   Plaintiff        claims    that      QTT   itself          referred    to\n\n \u201cadvertising content\u201d in the Offering Documents, those same\n\n documents      also     referred     to       \u201ccontent       and      advertising\u201d\n\n\n                                          30\n\fCase 1:20-cv-06707-VM     Document 144       Filed 02/05/26     Page 31 of 51\n\n\n\n separately in other locations, indicating that QTT viewed\n\n content and advertising as distinct concepts. (Id.; Dkt. No.\n\n 124-12 at 16, 124-13 at 18.) Given that the statements\n\n regarding the use of artificial intelligence came in the\n\n \u201cContent    Screening     Technology\u201d        section,        rather   than     the\n\n immediately preceding \u201cAdvertising\u201d section, no reasonable\n\n investor     could     have     plausibly      interpreted         Defendant\u2019s\n\n statements to mean that QTT\u2019s screening technology was used\n\n to screen advertisements.\n\n             2.   QTT Did Not Disclose That It Was Placing\n             Illegal Advertisements On the QTT App\n\n       The   SAC   alleges       that   the     Offering       Documents        were\n\n materially false and misleading because they did not disclose\n\n to   investors    that    QTT    was    actively       violating       People\u2019s\n\n Republic of China (\u201cPRC\u201d) advertising laws and regulations at\n\n the time those documents became effective. (See SAC \u00b6\u00b6 101,\n\n 105, 109-11, 118, 121, 126-27.) To support that illegal ads\n\n were being placed on the platform at the time the Offering\n\n Documents became effective, Plaintiff points to confidential\n\n witness     allegations       regarding      the    placement         of   \u201cnon-\n\n conforming\u201d ads on the QTT App, public reporting of illegal\n\n ads, a lawsuit filed against QTT regarding gambling ads, and\n\n a talk between QTT and a Chinese regulator. (Id. \u00b6\u00b6 72-75,\n\n 88-95.) Plaintiff also argues that QTT\u2019s risk disclosures\n\n\n\n\n                                        31\n\fCase 1:20-cv-06707-VM    Document 144     Filed 02/05/26    Page 32 of 51\n\n\n\n regarding illegal advertisements on the QTT App do not protect\n\n Defendants    from     liability   because    at   the     time   the      risk\n\n disclosures     were      made     QTT   \u201cwas      actively       violating\n\n [advertising] regulations.\u201d (Pl.\u2019s Opp\u2019n at 11.) Defendants\n\n respond that QTT fully disclosed its illegal advertisement\n\n risks, including the risk that the Company could be currently\n\n violating PRC advertising laws and regulations at the time\n\n the disclosures were made. (Defs.\u2019 Mem. at 12-15.)\n\n      The Court finds that the SAC fails to allege that the\n\n Offering Documents contained materially false and misleading\n\n statements regarding the existence of illegal advertisements\n\n at the time the statements became effective because QTT fully\n\n disclosed the risk of illegal advertisements on the QTT App.\n\n      In its Offering Documents, QTT disclosed the risk that\n\n illegal advertisements could appear on its platform. In the\n\n Offering Documents QTT expressly warned investors that it\n\n \u201ccannot assure [investors] that all the advertisements shown\n\n on [its] mobile applications are true, accurate, appropriate\n\n and in full compliance with applicable laws and regulations.\u201d\n\n (SAC \u00b6 110.) This disclosure of risk is in the present tense.\n\n It tells investors that at the time the statements were made,\n\n QTT \u201ccannot assure\u201d that \u201call the advertisements\u201d on the\n\n platform fully complied with PRC laws and regulations. (Id.)\n\n Though   \u201ccautionary       words    about    future       risk\u201d   are       not\n\n\n                                     32\n\fCase 1:20-cv-06707-VM      Document 144     Filed 02/05/26    Page 33 of 51\n\n\n\n sufficient      to   protect   against      risks     that   have      occurred\n\n already and are likely to occur again, the words used by QTT\n\n indicate that at the time of the disclosures, QTT could have\n\n been    in     active    violation    of   PRC    advertising       laws     and\n\n regulations. Van v. Bright Health Grp., Inc., No. 24-3132-\n\n CV, 2025 WL 3171688, at *3 (2d Cir. Nov. 13, 2025) (quoting\n\n Set Cap. LLC v. Credit Suisse Grp. AG, 996 F.3d 64, 85 (2d\n\n Cir. 2021)).\n\n         Plaintiff states that the disclosures in this case are\n\n similar to the disclosures that the Second Circuit found\n\n inadequate in Meyer v. Jinkosolar Holdings Co., Ltd., 761\n\n F.3d 245, 250 (2d Cir. 2014). In that case, the Second Circuit\n\n found that the \u201cfailure to disclose then-ongoing and serious\n\n pollution violations\u201d was actionable despite investors being\n\n \u201cwarned of a financial risk to the company from environmental\n\n violations.\u201d Jinkosolar, 761 F.3d at 251. However, in that\n\n case,    the    defendant    had     submitted    a    report     to    Chinese\n\n Regulators       about    existing     problems       regarding     pollution\n\n violations. Id. The Court found that given the known existence\n\n of problems at the time the offering documents were published,\n\n the company\u2019s \u201cgeneric warning\u201d of a risk that that non-\n\n compliance with environmental regulations may be costly would\n\n \u201cnot suffice when undisclosed facts on the ground would\n\n substantially affect a reasonable investor\u2019s calculations of\n\n\n                                       33\n\fCase 1:20-cv-06707-VM     Document 144     Filed 02/05/26    Page 34 of 51\n\n\n\n probability.\u201d Id. Here, Plaintiff does not identify any such\n\n self-disclosure or knowledge of ongoing violations by QTT.\n\n         This case is more similar to Jiajia Luo v. Sogou, Inc.,\n\n 465 F. Supp. 3d 393, 409\u201310 (S.D.N.Y. 2020), where the court\n\n found     that    the    company\u2019s    disclosures          properly     warned\n\n investors that the company could not assure or guarantee that\n\n they were currently complying with the law. In Sogou, the\n\n offering documents included a statement that \u201c[a]lthough we\n\n are committed to complying with . . . PRC laws and regulations\n\n applicable to Internet-related service . . . activities, we\n\n cannot guarantee that we are now or will in the future be in\n\n full compliance with any such laws and regulations that apply\n\n to our services and activities.\u201d           465 F. Supp. 3d at 410. The\n\n court in that case found that because of the company\u2019s risk\n\n disclosure, \u201cno reasonable investor could infer that [the\n\n company\u2019s] compliance efforts were particularly effective.\u201d\n\n Id. Here, QTT similarly acknowledged the current and ongoing\n\n risk    that     it   \u201ccannot   assure    [investors]        that     all   the\n\n advertisements shown on [QTT\u2019s] mobile applications are true,\n\n accurate, appropriate and in full compliance with applicable\n\n laws and regulations.\u201d (SAC \u00b6 110.) Based on QTT\u2019s risk\n\n disclosures, no reasonable investor could infer that QTT\u2019s\n\n compliance efforts were currently effective.\n\n\n\n\n                                      34\n\fCase 1:20-cv-06707-VM   Document 144     Filed 02/05/26   Page 35 of 51\n\n\n\n        Additionally, Plaintiff fails to allege any omission by\n\n Defendants    of   a   violation   of    PRC     advertising    laws     and\n\n regulations at the time of the IPO and SPO that would render\n\n QTT\u2019s risk disclosure ineffective or misleading. Plaintiff\n\n attempts to support his argument that QTT knew it was placing\n\n illegal ads on its platform at the time the Offering Documents\n\n became effective in several ways. First, Plaintiff argues\n\n that    allegations     by   confidential        witnesses     support     a\n\n plausible    inference   that   QTT     placed    illegal    ads   on    the\n\n platform at the time of the Offerings. (See SAC \u00b6\u00b6 72-75.)\n\n Second, Plaintiff points to public reporting indicating that\n\n QTT had illegal advertisements on its platform. (See id. \u00b6\u00b6\n\n 88-89.) Third, Plaintiff claims there was a lawsuit filed\n\n against QTT\u2019s Chinese entity Jifen in January 2019 regarding\n\n illegal gambling advertisements on the QTT app. (See id. \u00b6\n\n 90.) Fourth, Plaintiff asserts that QTT was summoned for a\n\n talk regarding illegal advertisements on June 18, 2019, with\n\n the Shanghai Municipal Market Supervision Bureau, a Chinese\n\n regulator. (See id. \u00b6 91.) The Court will address each of\n\n these allegations in turn.\n\n        Plaintiff alleges that confidential witnesses support a\n\n plausible inference that QTT placed illegal advertisements on\n\n the QTT App at the time of the Offerings. Plaintiff identifies\n\n two confidential witnesses. The first is a channel manager at\n\n\n                                    35\n\fCase 1:20-cv-06707-VM    Document 144        Filed 02/05/26   Page 36 of 51\n\n\n\n Dianguan from June 2019 to September 2020 (\u201cFormer Channel\n\n Manager\u201d). (See id. \u00b6\u00b6 72-73.) The Former Channel Manager\n\n claimed     that   while      QTT    used         technology     to    screen\n\n advertisements, if an advertisement that \u201ctoed the line\u201d was\n\n screened out, the ads could be subject to a second manual\n\n review that would allow those \u201cnon-conforming\u201d ads to be put\n\n on the platform. (Id. \u00b6\u00b6 71, 73.) The second confidential\n\n witness was a former sales director (\u201cFormer Sales Director\u201d)\n\n of Dianguan from March 2019 to May 2020 who explained that\n\n the second manual review was conducted by two teams, one team\n\n that dealt with well-known and qualified advertisers and a\n\n second team that dealt with riskier, unqualified advertisers.\n\n (Id. \u00b6\u00b6 72, 74-75.) The Former Sales Director alleged that\n\n the second team dealing with the unqualified advertisers\n\n outsourced due diligence to outside contractors who often\n\n opened accounts for any advertiser without conducting the\n\n proper due diligence. (Id. \u00b6 74.)\n\n        \u201c[T]he Court may properly take account of the alleged\n\n testimony of [a confidential witness] even though some of\n\n [their]     testimony    is    based        on     hearsay     and    indirect\n\n knowledge.\u201d City of Warren Police & Fire Ret. Sys. v. World\n\n Wrestling Ent. Inc., 477 F. Supp. 3d 123, 132 (S.D.N.Y. 2020).\n\n \u201cFor    a   complaint   to    rely     on        information    provided     by\n\n confidential sources\u201d, the source must be described in the\n\n\n                                      36\n\fCase 1:20-cv-06707-VM   Document 144   Filed 02/05/26   Page 37 of 51\n\n\n\n complaint with sufficient detail to \u201csupport the probability\n\n that a person in the position occupied by the source would\n\n possess   the   information   alleged.\u201d    Id.   (quoting     Novak    v.\n\n Kasaks, 216 F.3d 300, 314 (2d Cir. 2000)). The question here\n\n is whether it is probable that the two confidential witnesses\n\n were in a position to possess information regarding the\n\n screening and placement of illegal advertisements by QTT at\n\n the time of the Offerings.\n\n      The Court finds that the confidential witnesses are not\n\n described in the SAC in a manner sufficient to support the\n\n probability that they were in a position to possess the\n\n information alleged. First, the Former Channel Manager was\n\n hired after the April 2019 SPO and is not alleged to have\n\n worked on advertising at QTT. (SAC \u00b6 72.) Given that the\n\n Former Channel Manager was not working at QTT at the time of\n\n either offering and did not work in advertising at QTT, they\n\n are not someone who \u201cwould possess the information alleged.\u201d\n\n City of Warren, 477 F. Supp. 3d at 132. For the Former Sales\n\n Director, the SAC itself acknowledges that they \u201cdid not deal\n\n with unqualified advertisers,\u201d and only learned \u201cabout how\n\n the Company dealt with those advertisers from co-workers.\u201d\n\n (Id. \u00b6 74.) These confidential witnesses\u2019 allegations are\n\n based not on direct observations, but instead on \u201csecond-hand\n\n information, obtained only through intermediaries.\u201d Janbay v.\n\n\n                                  37\n\fCase 1:20-cv-06707-VM      Document 144      Filed 02/05/26     Page 38 of 51\n\n\n\n Canadian Solar, Inc., 2013 WL 1287326, at *8 (S.D.N.Y. Mar.\n\n 28,   2013).    Such     second-hand      information        undermines        \u201cthe\n\n likelihood     that      [the   confidential      witness]       had   personal\n\n knowledge of the allegations.\u201d Id. Given these issues, the\n\n SAC does not \u201csupport the probability that a person in the\n\n position[s] occupied by the [confidential witnesses] would\n\n possess the information alleged.\u201d City of Warren, 477 F. Supp.\n\n 3d at 132.\n\n       Even if the SAC properly described the confidential\n\n witnesses     as   occupying     positions      that     would    possess       the\n\n information alleged, the witnesses would still not allege\n\n that illegal advertisements were placed on the QTT App. The\n\n confidential witnesses speak of \u201crisky,\u201d advertisements that\n\n \u201ctoed the line.\u201d (SAC \u00b6\u00b6 72-75.) However, nowhere does the\n\n SAC explicitly state that the confidential witnesses alleged\n\n that illegal advertisements were being placed on the QTT App.\n\n Given the fact that neither confidential witness explicitly\n\n stated that illegal ads were being placed on the QTT App at\n\n the   time    of   the    Offerings,      neither      witness     supports       a\n\n plausible inference that QTT placed illegal ads during the\n\n IPO and SPO.\n\n       Next,    Plaintiff\u2019s       allegations      that       public    reporting\n\n revealed that QTT was placing illegal advertisements on the\n\n QTT   App     represent     claims     of    \u201cuncharged,         unadjudicated\n\n\n                                      38\n\fCase 1:20-cv-06707-VM    Document 144      Filed 02/05/26   Page 39 of 51\n\n\n\n wrongdoing    or    mismanagement\u201d        that   Defendants       were     not\n\n obligated to disclose in the Offerings. Ciresi v. Citicorp,\n\n 782 F. Supp. 819, 823 (S.D.N.Y. 1991), aff\u2019d, 956 F.2d 1161\n\n (2d Cir. 1992). Further, any such reporting regarding illegal\n\n advertisements on the QTT app would be entirely consistent\n\n with QTT\u2019s risk disclosure that it could not assure investors\n\n that all advertisements on the platform complied with PRC\n\n laws and regulations.\n\n      Addressing Plaintiff\u2019s allegations that a January 2019\n\n lawsuit against QTT\u2019s Chinese entity Jifen showed that QTT\n\n placed gambling ads on the QTT app, the Chinese court in that\n\n matter   dismissed     the    case   without      making    any    findings\n\n regarding ads. (See SAC \u00b6 90.) Accordingly, there was no\n\n finding regarding a violation of PRC advertising laws or\n\n regulations for QTT to disclose in the Offering Documents.\n\n      Lastly, Plaintiff alleges that on June 18, 2019, QTT was\n\n summoned for a talk and sternly warned by the Shanghai\n\n Municipal Market Supervision Bureau, a Shanghai regulator,\n\n regarding QTT\u2019s illegal advertising practices. (See id. \u00b6\n\n 91.) First, this discussion took place two months after the\n\n April 2019 SPO. As Defendants point out, this discussion with\n\n a   regulator      cannot    \u201cretroactively      render     the    offering\n\n documents materially false or misleading.\u201d (Defs.\u2019 Mem. at\n\n 14); see Sogou, 465 F. Supp. 3d at 406 (\u201cIt is not sufficient\n\n\n                                      39\n\fCase 1:20-cv-06707-VM     Document 144        Filed 02/05/26    Page 40 of 51\n\n\n\n that, at some point after the registration statement became\n\n effective,      some     subsequent         event    made      it    no   longer\n\n accurate.\u201d); see also In re Hut 8, 2025 WL 2636150, at *12\n\n (\u201c[A]n actionable misstatement is one that \u2018was false at the\n\n time it was made.\u2019\u201d (quoting In re Lululemon Sec. Litig., 14\n\n F.Supp.3d 553, 571 (S.D.N.Y. 2014))).\n\n         Given QTT\u2019s risk disclosures and the fact that the SAC\n\n fails    to   properly    plead      any    undisclosed       advertising      law\n\n violations by QTT, the Court does not find there to be any\n\n actionable     misrepresentations           or   omissions      by   Defendants\n\n regarding the placement of illegal advertisements on the QTT\n\n App at the time of the IPO and SPO.\n\n               3.   QTT\u2019s Failure to Disclose Knowledge of\n               Illicit Advertising as a Key Driver of Revenue\n               Growth\n\n         It is well established that \u201ccompanies do not have a\n\n duty to disclose uncharged, unadjudicated wrongdoing.\u201d City\n\n of   Pontiac,    752     F.3d   at    184    (internal        quotation   marks\n\n omitted). However, \u201cthe duty to disclose uncharged wrongdoing\n\n may arise in three scenarios: (1) \u2018when a corporation puts\n\n the reasons for its success at issue, but fails to disclose\n\n that a material source of its success is the use of improper\n\n or illegal business practices\u2019; (2) \u2018when a defendant makes\n\n a statement that can be understood, by a reasonable investor,\n\n to deny that the illegal conduct is occurring\u2019; or (3) \u2018when\n\n\n                                        40\n\fCase 1:20-cv-06707-VM       Document 144       Filed 02/05/26    Page 41 of 51\n\n\n\n a   defendant     states     an    opinion      that,    absent      disclosure,\n\n misleads    investors       about       material    facts      underlying       that\n\n belief.\u2019\u201d In re Teva Sec. Litig., 671 F. Supp. 3d 147, 211\u2013\n\n 12 (D. Conn. 2023) (quoting Menaldi v. Och-Ziff Capital Mgmt.\n\n Grp. LLC, 164 F. Supp. 3d 568, 581 (S.D.N.Y. 2016)). \u201cWhen a\n\n securities fraud action rests on the failure to disclose\n\n uncharged       illegal    conduct,       the    complaint      must    state      a\n\n plausible       claim   that      the    underlying      conduct     occurred.\u201d\n\n Menaldi, 164 F. Supp. 3d at 578. Because Plaintiff alleges\n\n that Defendants provided reasons for the Company\u2019s growth in\n\n revenue but \u201cfail[ed] to disclose that a material source of\n\n its success\u201d was the placement of illegal advertisements on\n\n the QTT App, they must state a \u201cplausible claim that the\n\n underlying conduct occurred.\u201d Id.\n\n         Plaintiff alleges that investors were misled about what\n\n drove QTT\u2019s revenue growth because Defendants \u201cfailed to\n\n disclose that illicit advertising was also a key driver.\u201d\n\n (Pl.\u2019s Opp\u2019n at 16.) Specifically, the SAC alleges that\n\n statements      in   the    Offering      Documents      that     increases      in\n\n revenue were caused by QTT\u2019s strategy of targeting users in\n\n lower    tier    cities     were    materially       false     and     misleading\n\n because they did not \u201cdisclose that a substantial portion of\n\n QTT\u2019s \u2018rapidly\u2019 increasing revenue was derived from illegal\n\n ads.\u201d (Id.) Plaintiff also alleges that QTT\u2019s statements\n\n\n                                          41\n\fCase 1:20-cv-06707-VM     Document 144       Filed 02/05/26   Page 42 of 51\n\n\n\n regarding revenue growth were misleading in that they omitted\n\n that \u201creduc[ing] [QTT\u2019s] reliance\u201d on Baidu in favor of a new\n\n \u201cadvertising agent\u201d Dianguan \u201cincreased the likelihood of\n\n illegal ads\u201d being placed on the QTT platform. (Id. at 16-\n\n 17.) Plaintiff argues that under Rule 8 they have \u201cadequately\n\n pled that illegal ads materially contributed to QTT\u2019s revenue\n\n growth, as evidenced by its first ever year-over-year revenue\n\n decrease after enacting remedial measures to halt illegal\n\n ads[.]\u201d (Id. at 18.) Plaintiff further alleges that the\n\n omission was material to investors \u201cas evidenced by QTT\u2019s\n\n ADSs\u2019    falling    24     [percent]      after    investors    learned      the\n\n truth.\u201d (Id.)\n\n         Defendants argue that Plaintiff does not support his\n\n claim regarding illegal advertisements being a key driver of\n\n revenue    for     QTT   with   \u201cwell-plead        factual     allegations.\u201d\n\n (Defs.\u2019 Reply at 1.) Specifically, Defendants argue that the\n\n \u201cSAC includes no allegation regarding the volume of allegedly\n\n illegal     advertisements\u201d         and     that     the     \u201ccircumstantial\n\n allegations on which Plaintiff relies . . . are either\n\n unreliable, speculative, or conclusory.\u201d (Id.)\n\n         Plaintiff    has     not    adequately       pled      that   illegal\n\n advertisements       materially      contributed       to    QTT\u2019s    revenue\n\n growth.    As    evidence    that   illegal       advertisements      were    so\n\n \u201csubstantial\u201d that they constituted a material contribution\n\n\n                                        42\n\fCase 1:20-cv-06707-VM    Document 144   Filed 02/05/26   Page 43 of 51\n\n\n\n to QTT\u2019s revenue growth, Plaintiff points to QTT\u2019s first ever\n\n year-over-year revenue decrease after QTT enacted remedial\n\n measures to prevent illegal ads. (Pl.\u2019s Opp\u2019n at 18.)\n\n      The   Court   is    not   persuaded   that    this    evidence     is\n\n sufficient to support a plausible inference that QTT failed\n\n to disclose that a material number of illegal advertisements\n\n existed on the QTT App at the time of the Offerings. First,\n\n the drop in revenue took place in 2020, after both the\n\n September 2018 IPO and the April 2019 SPO were filed. This\n\n does not demonstrate that prior to 2020, QTT knew that a\n\n substantial portion of advertisements were illegal. Plaintiff\n\n must demonstrate that Defendants knew the statements were\n\n misleading at the time of the registration statements became\n\n effective, rather than later in time. See In re Tufin Software\n\n Techs. Ltd. Sec. Litig., No. 20-CV-5646, 2022 WL 596861, at\n\n *5 (S.D.N.Y. Feb. 25, 2022) (\u201cThe veracity of a registration\n\n statement which may give rise to liability under [Section 11]\n\n is determined by assessing the facts as they existed when the\n\n statement became effective.\u201d) (quoting Ladmen Partners, Inc.\n\n v. Globalstar, Inc., No. 07-CV-0976, 2008 WL 4449280, at *10\n\n (S.D.N.Y. Sept. 30, 2008)); Scott v. Gen. Motors Co., 46 F.\n\n Supp. 3d 387, 394 (S.D.N.Y. 2014), aff\u2019d, 605 F. App\u2019x 52 (2d\n\n Cir. 2015) (\u201cPlaintiffs must, \u2018at a minimum, plead facts to\n\n demonstrate that allegedly omitted facts both existed, and\n\n\n                                   43\n\fCase 1:20-cv-06707-VM    Document 144     Filed 02/05/26   Page 44 of 51\n\n\n\n were known or knowable, at the time of the offering.\u2019\u201d)\n\n (quoting Lin v. Interactive Brokers Grp., Inc., 574 F. Supp.\n\n 2d 408, 421 (S.D.N.Y. 2008)); In re Coty Inc. Sec. Litig.,\n\n No. 14-CV-919, 2016 WL 1271065, at *6 (S.D.N.Y. Mar. 29, 2016)\n\n (decline in operating income after IPO \u201coffer little guidance\n\n as to the information that was available at the time of the\n\n IPO\u201d). Plaintiff therefore fails to allege that QTT knew that\n\n there were a substantial number of illegal advertisements on\n\n its platform at the time the Offerings.\n\n         Additionally, a certain drop in QTT\u2019s revenue does not\n\n equate to the equivalent drop in the number of illegal\n\n advertisements on the QTT App. While a substantial number of\n\n advertisements being illegal is a possible explanation for\n\n why   revenue   decreased    in   2020     after    QTT   took    remedial\n\n measures, without more this explanation is not brought into\n\n the realm of plausible, as there are a myriad of reasons why\n\n revenue can decrease from year-to-year. Plaintiff cannot\n\n allege any evidence regarding the high prevalence of illegal\n\n advertisements at the time the Offering Documents were filed,\n\n let alone that QTT knew that there was a substantial number\n\n of illegal advertisements on the QTT App at that time.\n\n         Regarding Plaintiff\u2019s allegation that Defendants misled\n\n investors by omitting that the acquisition of Dianguan as\n\n QTT\u2019s    \u201cadvertising    agent\u201d   \u201cincreased        the   likelihood      of\n\n\n                                   44\n\fCase 1:20-cv-06707-VM    Document 144     Filed 02/05/26    Page 45 of 51\n\n\n\n illegal ads,\u201d Plaintiff has not pled non-conclusory facts\n\n that taken as true would support such a claim. (Pl.\u2019s Opp\u2019n\n\n at 16.) Plaintiff provides no support for any such allegation,\n\n which runs counter to QTT\u2019s statements in Offering Documents\n\n that they acquired Dianguan as their advertising agent to\n\n \u201cenhance [its] platform\u2019s monetization capabilities.\u201d (SAC \u00b6\u00b6\n\n 101, 112, 118, 124.) While Plaintiff alleges that Dianguan\u2019s\n\n founder   lacked       experience   in     digital        marketing,       that\n\n circumstance has little bearing on whether the acquisition\n\n would increase the likelihood of illegal ads being placed on\n\n the QTT App compared to the previous advertising agent Baidu.\n\n            4.   QTT Failed to Disclose Related Party\n            Transactions\n\n      Plaintiff alleges that Defendants failed to disclose\n\n related   party    transactions     as    required        under   Generally\n\n Accepted Accounting Principles (\u201cGAAP\u201d), SEC Regulation S-X\n\n (SAC \u00b6\u00b6 52-53), and Financial Accounting Standards Board\n\n (\u201cFASB\u201d) Accounting Standards Codification (\u201cACS\u201d) 850 (SAC\n\n \u00b6 54). Related parties under FASB ASC 850 include: (1)\n\n \u201cAffiliates of the entity\u201d (ASC 850-10-20); (2) \u201cPrincipal\n\n owners of the entity and members of their immediate families\u201d\n\n (id.); (3) \u201c[m]anagement of the entity and members of their\n\n immediate families\u201d (id.); (4) \u201c[o]ther parties with which\n\n the entity may deal if one party controls or can significantly\n\n\n\n                                     45\n\fCase 1:20-cv-06707-VM        Document 144      Filed 02/05/26     Page 46 of 51\n\n\n\n influence the management or operating policies of the other\n\n to an extent that one of the transacting parties might be\n\n prevented from fully pursuing its own separate interests\u201d\n\n (id.);    and    (5)       \u201c[o]ther   parties      that    can    significantly\n\n influence       the    management      or     operating    policies        of    the\n\n transacting parties or that have an ownership interest in one\n\n of the transacting parties and can significantly influence\n\n the other to an extent that one or more of the transacting\n\n parties    might      be    prevented       from   fully   pursuing        its   own\n\n separate interests\u201d (id.).\n\n        Plaintiff alleges that QTT omitted material facts in the\n\n Offering Documents by not disclosing certain related party\n\n transactions. (See SAC \u00b6\u00b6 48-66.) First, Plaintiff alleges\n\n that QTT\u2019s acquisition of Dianguan should have been disclosed\n\n as a related party transaction, because QTT\u2019s co-founder and\n\n CEO Tan had a \u201cclose business relationship\u201d with Dianguan\u2019s\n\n founder,    Xiang      \u201cSean\u201d       Liang    (\u201cLiang\u201d).        (Id.   \u00b6\u00b6   57-61.)\n\n Second, Plaintiff alleges that QTT also failed to disclose\n\n that   transactions          with   advertisers      Mengtui,         Fangce,    and\n\n Shihui Miao were related party transactions because these\n\n entities were related parties benefitting Tan. (See id. \u00b6\u00b6\n\n 62-66.)\n\n\n\n\n                                         46\n\fCase 1:20-cv-06707-VM      Document 144    Filed 02/05/26    Page 47 of 51\n\n\n\n         The analysis below first considers Plaintiff\u2019s claim\n\n regarding Dianguan, and then turns to the claims regarding\n\n Mengtui, Fangce, and Shihui Miao.\n\n                     a. Dianguan\n\n         According to the SAC, Liang founded Dianguan four months\n\n prior to its acquisition by QTT in February 2018. (Id. \u00b6 57-\n\n 58.) Liang was Dianguan\u2019s director and legal representative\n\n at the time of the acquisition. (Id. \u00b6 58.) The SAC argues\n\n that     \u201cLiang     and   Tan\u2019s     business     relationship       was     so\n\n intertwined that Dianguan would have been prevented from\n\n fully    pursing    its    own    separate    interest[.]\u201d      (Id.    \u00b6   61\n\n (internal quotations omitted).)\n\n         The SAC provides two factual assertions to support its\n\n contention that Liang had a special relationship with Tan at\n\n the    time   QTT   acquired      Dianguan.    First,      before   founding\n\n Dianguan, Liang was an investment director of a company called\n\n Shanghai      Taiyun   Investment     Management     Co.     Ltd.   (\u201cTaiyun\n\n Capital\u201d), in which Tan had 99 percent ownership. (Id. \u00b6 58.)\n\n Second, Plaintiff alleges that \u201cwithin weeks of the Dianguan\n\n Acquisition, [] Tan invested in a company [called Nantong\n\n WooFoo Jinxin Equity Investment Fund Partnership (\u201cWoofoo\n\n Equity\u201d)] which was the executive partner of another company\n\n at which Liang was the director of domestic investment.\u201d (Id.\n\n \u00b6 60.) Plaintiff alleges that, because of these connections,\n\n\n                                      47\n\fCase 1:20-cv-06707-VM     Document 144        Filed 02/05/26   Page 48 of 51\n\n\n\n \u201cLiang and Tan\u2019s business relationship was so intertwined\n\n that Dianguan would have been prevented from fully pursing\n\n its own separate interest.\u201d (Id. \u00b6 61 (internal quotation\n\n marks omitted).)\n\n       While Plaintiff describes a close business relationship\n\n between Liang and Tan, he fails to adequately plead that this\n\n relationship was so intertwined that Dianguan might have been\n\n prevented    from     fully   pursuing       its    own   interests.    First,\n\n because Tan\u2019s involvement with Woofoo Equity came after QTT\u2019s\n\n acquisition of Dianguan, it has no bearing on whether Liang\n\n and Tan were related parties at the time of the transaction\n\n between QTT and Dianguan, which is the \u201cpertinent point.\u201d In\n\n re Hebron Tech. Co., Ltd. Sec. Litig., No. 20-CV-4420, 2021\n\n WL 4341500, at *13 (S.D.N.Y. Sept. 22, 2021) (rejecting\n\n plaintiff\u2019s claim that defendant failed to disclose a related\n\n party transaction where the SAC did not allege a relationship\n\n at the time of the relevant transactions). That Liang served\n\n as an investment director at Taiyun Capital, a company 99\n\n percent owned by Tan, also does not sufficiently allege that\n\n Tan   had   control    over   Liang     so     as   to    make   the   Dianguan\n\n acquisition a related party transaction. The existence of\n\n business relationship between Tang and Liang did not trigger\n\n a duty to disclose. \u201c[T]he fact of a separate association\n\n between [] two men\u201d does not mean that one individual had\n\n\n                                       48\n\fCase 1:20-cv-06707-VM      Document 144        Filed 02/05/26      Page 49 of 51\n\n\n\n control over another so as to make the transaction a \u201crelated\n\n party transaction.\u201d In re Hebron, 2021 WL 4341500, at *15.\n\n Here, Liang\u2019s role at a third company primarily owned by Tan,\n\n Taiyun Capital, does not meet the related party standard\n\n because    Plaintiff      does   not   plausibly          allege     how    Liang\u2019s\n\n business relationship with Tan would have \u201cprevented [Liang]\n\n from fully pursuing [his] own separate interest.\u201d Id. at *11.\n\n                     b. Mengtui, Fangce, and Shihui Mioa\n\n         Plaintiff also fails to allege any undisclosed related\n\n party     transactions     at    the   time        of     the   Offerings         with\n\n advertisers    Mengtui,      Fangce,        and    Shihui       Mioa.   Plaintiff\n\n alleges that QTT\u2019s transactions with its advertisers Mengtui,\n\n Fangce, and Shihui Miao should have been disclosed in the\n\n Offering Documents as related party transactions. (SAC \u00b6\u00b6 62-\n\n 65.) While the Defendants\u2019 do not dispute that these are\n\n related     party      transactions,           they       state      that     these\n\n transactions were properly disclosed in QTT\u2019s 2019 annual\n\n report. (Defs.\u2019 Mem. at 24-25.) Defendants argue that the\n\n \u201cSAC     persists    in    pleading      no       facts    regarding        [QTT\u2019s]\n\n transactions with these entities at the time of the September\n\n 2018 IPO or April 2019 SPO, defeating this claim.\u201d (Id. at\n\n 25.) Because the SAC does not allege that the transactions\n\n began before the IPO and SPO and because they were disclosed\n\n as part of QTT\u2019s annual review, the SAC fails to adequately\n\n\n                                        49\n\fCase 1:20-cv-06707-VM   Document 144   Filed 02/05/26   Page 50 of 51\n\n\n\n plead that QTT did not disclose related party transactions at\n\n the appropriate time. See Sogou, 465 F. Supp. 3d at 406 (\u201cIt\n\n is not sufficient that, at some point after the registration\n\n statement became effective, some subsequent event made it no\n\n longer accurate.\u201d)\n\n      C.    SECTION 15\n\n      Section 15 of the Securities Act creates liability for\n\n individuals or entities that \u201ccontrol[ ] any person liable\u201d\n\n under Sections 11 or 12. 15 U.S.C. \u00a7 77o(a). To state a claim\n\n for control person liability under Section 15, \u201ca plaintiff\n\n must allege \u2018a primary violation by a controlled person, and\n\n control by the defendant of the primary violator\u2019\u201d Ohio Pub.\n\n Emps. Ret. Sys. v. Discovery, Inc., 715 F. Supp. 3d 483, 505\n\n (S.D.N.Y. 2024), aff\u2019d, No. 24-646-CV, 2024 WL 4647131 (2d\n\n Cir. Nov. 1, 2024) (quoting In re Global Crossing, Ltd. Secs.\n\n Litig., 322 F. Supp. 2d 319, 349 (S.D.N.Y. 2004)) (cleaned\n\n up). \u201cIf the plaintiff has not adequately alleged a primary\n\n violation \u2013 i.e. a viable claim under another provision of\n\n the Securities Act \u2013 the Section 15 claim must be dismissed.\u201d\n\n In re Hut 8, No. 24-CV-904, 2025 WL 2636150, at *6. Here, the\n\n Court has found that there are no viable claims under Section\n\n 11 or Section 12. Therefore, Plaintiff does not have a viable\n\n Section 15 claim.\n\n\n\n\n                                  50\n\fCase 1:20-cv-06707-VM   Document 144     Filed 02/05/26   Page 51 of 51\n\n\n\n                              IV.    ORDER\n\n      For the preceding reasons, it is hereby\n\n      ORDERED that the motion (the \u201cMotion\u201d) (Dkt. No. 122) of\n\n Defendants Oliver Yucheng Chen, China Merchants Securities\n\n (HK) Co., Ltd., Citigroup Global Markets Inc., Yongbo Dai,\n\n Deutsche Bank Securities Inc., Jianfei Dong, Jefferies Group\n\n LLC, Shaoqing Jiang, KeyBanc Capital Markets Inc., Feng Li,\n\n Lei Li, James Jun Peng, Qutoutiao Inc., Eric Siliang Tan, UBS\n\n Securities LLC, Jingbo Wang, and Xiaolu Zhu to dismiss the\n\n Second Amended Consolidated Class Action Complaint (Dkt. No.\n\n 118) is GRANTED.\n\n      The Clerk of Court is respectfully directed to close\n\n Dkt. No. 118.\n\n\n\n SO ORDERED.\n\n Dated:     5 February 2026\n            New York, New York\n\n\n\n\n                                    51\n\f","ocr_status":2,"date_upload":"2026-06-17T04:16:29.679815-07:00","document_number":"144","attachment_number":null,"pacer_doc_id":"127039019909","is_available":true,"is_free_on_pacer":true,"is_sealed":null,"document_type":1,"description":"Order on Motion to Dismiss","acms_document_guid":""}],"date_created":"2026-02-05T13:11:57.343027-08:00","date_modified":"2026-07-06T04:22:55.681300-07:00","date_filed":"2026-02-05","time_filed":"15:48:34","entry_number":144,"recap_sequence_number":"2026-02-05.001","pacer_sequence_number":582,"description":"  DECISION AND ORDER granting (122)  Motion to Dismiss in case 1:20-cv-06707-VM.  For the preceding reasons, it is hereby ORDERED that the motion (the \"Motion\") (Dkt. No. 122) of Defendants Oliver Yucheng Chen, China Merchants Securities (HK ) Co., Ltd., Citigroup Global Markets Inc., Yongbo Dai, Deutsche Bank Securities Inc., Jianfei Dong, Jefferies Group LLC, Shaoqing Jiang, KeyBanc Capital Markets Inc., Feng Li, Lei Li, James Jun Peng, Qutoutiao Inc., Eric Siliang Tan, UBS Securities  LLC, Jingbo Wang, and Xiaolu Zhu to dismiss the Second Amended Consolidated Class Action Complaint (Dkt. No. 118) is GRANTED. The Clerk of Court is respectfully directed to close Dkt. No. 118. SO ORDERED.   (Signed by Judge Victor Marrero on 2/5/2026)  Filed In Associated Cases: 1:20-cv-06707-VM, 1:20-cv-07717-SHS  (jca)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/435822274/","id":435822274,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/17464782/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/450247865/","id":450247865,"tags":[],"absolute_url":"/docket/17464782/143/in-re-qutoutiao-inc-securities-litigation/","date_created":"2025-08-25T18:08:43.174109-07:00","date_modified":"2026-06-16T08:37:35.704642-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"143","attachment_number":null,"pacer_doc_id":"127038099683","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Reply Memorandum of Law in Support of Motion","acms_document_guid":""}],"date_created":"2025-08-25T18:08:43.149147-07:00","date_modified":"2026-06-16T08:37:35.686784-07:00","date_filed":"2025-08-25","time_filed":"20:53:26","entry_number":143,"recap_sequence_number":"2025-08-25.001","pacer_sequence_number":579,"description":"REPLY MEMORANDUM OF LAW in Support re: 122 MOTION to Dismiss Plaintiff's Second Amended Consolidated Class Action Complaint. . Document filed by Oliver Yucheng Chen, China Merchants Securities (HK) Co., Ltd., Citigroup Global Markets Inc., Yongbo Dai, Deutsche Bank Securities Inc., Jianfei Dong, Jefferies Group LLC, Shaoqing Jiang, KeyBanc Capital Markets Inc., Feng Li, Lei Li, James Jun Peng, Qutoutiao Inc., Eric Siliang Tan, UBS Securities LLC, Jingbo Wang, Xiaolu Zhu..(Wang, George) (Entered: 08/25/2025)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/435063380/","id":435063380,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/17464782/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/449467507/","id":449467507,"tags":[],"absolute_url":"/docket/17464782/142/in-re-qutoutiao-inc-securities-litigation/","date_created":"2025-08-18T14:08:07.103872-07:00","date_modified":"2026-06-16T08:37:35.663468-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"142","attachment_number":null,"pacer_doc_id":"127038060047","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Stipulation and Order","acms_document_guid":""}],"date_created":"2025-08-18T14:08:07.088577-07:00","date_modified":"2026-06-16T08:37:35.646405-07:00","date_filed":"2025-08-18","time_filed":"15:12:59","entry_number":142,"recap_sequence_number":"2025-08-18.001","pacer_sequence_number":575,"description":"JOINT STIPULATION AND ORDER: NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS: Defendants withdraw their letter opposition to the pre-motion letter seekingsubstitution of Rosemary Korines as Lead Plaintiff, while reserving all rights, defensesand arguments concerning whether Ms. Korines is an adequate class representative andwhether other requirements for class certification can be satisfied. SO ORDERED. (Signed by Judge Victor Marrero on 8/18/2025) (rro) (Entered: 08/18/2025)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/434838810/","id":434838810,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/17464782/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/449236859/","id":449236859,"tags":[],"absolute_url":"/docket/17464782/141/in-re-qutoutiao-inc-securities-litigation/","date_created":"2025-08-15T10:07:52.155093-07:00","date_modified":"2026-06-16T08:37:35.623296-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"141","attachment_number":null,"pacer_doc_id":"127038048689","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Proposed Stipulation and Order","acms_document_guid":""}],"date_created":"2025-08-15T10:07:52.138391-07:00","date_modified":"2026-06-16T08:37:35.604454-07:00","date_filed":"2025-08-15","time_filed":"12:46:30","entry_number":141,"recap_sequence_number":"2025-08-15.001","pacer_sequence_number":573,"description":"PROPOSED STIPULATION AND ORDER. Document filed by Oliver Yucheng Chen, Yongbo Dai, Jianfei Dong, Shaoqing Jiang, Feng Li, Lei Li, James Jun Peng, Qutoutiao Inc., Eric Siliang Tan, Jingbo Wang, Xiaolu Zhu..(Wang, George) (Entered: 08/15/2025)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/434752967/","id":434752967,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/17464782/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/449148987/","id":449148987,"tags":[],"absolute_url":"/docket/17464782/140/in-re-qutoutiao-inc-securities-litigation/","date_created":"2025-08-14T14:10:46.205555-07:00","date_modified":"2026-06-16T08:37:35.579921-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"140","attachment_number":null,"pacer_doc_id":"127038042419","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Stipulation and Order","acms_document_guid":""}],"date_created":"2025-08-14T14:10:46.189940-07:00","date_modified":"2026-06-16T08:37:35.560782-07:00","date_filed":"2025-08-14","time_filed":"15:33:53","entry_number":140,"recap_sequence_number":"2025-08-14.001","pacer_sequence_number":569,"description":"JOINT STIPULATION AND ORDER: NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS: 1.The parties shall file a stipulation by August 15, 2025 stating whether there remains any opposition to Plaintiff's substitution motion and, as appropriate, setting forth a briefing schedule for such motion. SO ORDERED. (Signed by Judge Victor Marrero on 8/14/2025) (jca) (Entered: 08/14/2025)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/434209451/","id":434209451,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/17464782/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/448585862/","id":448585862,"tags":[],"absolute_url":"/docket/17464782/139/in-re-qutoutiao-inc-securities-litigation/","date_created":"2025-08-08T18:46:17.179393-07:00","date_modified":"2026-06-16T08:37:35.539277-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"139","attachment_number":null,"pacer_doc_id":"127038013646","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Proposed Stipulation and Order","acms_document_guid":""}],"date_created":"2025-08-08T18:46:17.012476-07:00","date_modified":"2026-06-16T08:37:35.520811-07:00","date_filed":"2025-08-08","time_filed":"19:10:32","entry_number":139,"recap_sequence_number":"2025-08-08.001","pacer_sequence_number":567,"description":"PROPOSED STIPULATION AND ORDER. Document filed by Oliver Yucheng Chen, Yongbo Dai, Jianfei Dong, Shaoqing Jiang, Feng Li, Lei Li, James Jun Peng, Qutoutiao Inc., Eric Siliang Tan, Jingbo Wang, Xiaolu Zhu..(Wang, George) (Entered: 08/08/2025)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/433677856/","id":433677856,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/17464782/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/448036782/","id":448036782,"tags":[],"absolute_url":"/docket/17464782/138/in-re-qutoutiao-inc-securities-litigation/","date_created":"2025-08-04T14:07:10.406324-07:00","date_modified":"2026-06-16T08:37:35.498306-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"138","attachment_number":null,"pacer_doc_id":"127037978930","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Stipulation and Order AND ~Util - Set Deadlines","acms_document_guid":""}],"date_created":"2025-08-04T14:07:10.389417-07:00","date_modified":"2026-06-16T08:37:35.481189-07:00","date_filed":"2025-08-04","time_filed":"15:13:58","entry_number":138,"recap_sequence_number":"2025-08-04.001","pacer_sequence_number":562,"description":"JOINT STIPULATION AND ORDER: NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS:1. The parties shall advise the Court by August 8, 2025, whether they consent for the Court to deem the pre-motion letters to constitute a fully briefed motion to substitute lead plaintiff and rule on the basis of those letters, or whether the parties request supplemental or full briefing;2. If the parties request supplemental or full briefing, they shall submit a proposed briefing schedule on or before August 8, 2025; 3. Defendants shall file their reply in further support of their motion to dismiss on August25, 2025. SO ORDERED. (Replies due by 8/25/2025.) (Signed by Judge Victor Marrero on 8/4/2025) (jca) (Entered: 08/04/2025)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/433504720/","id":433504720,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/17464782/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/447858223/","id":447858223,"tags":[],"absolute_url":"/docket/17464782/137/in-re-qutoutiao-inc-securities-litigation/","date_created":"2025-08-01T18:06:24.289078-07:00","date_modified":"2026-06-16T08:37:35.463906-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"137","attachment_number":null,"pacer_doc_id":"127037973250","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Proposed Stipulation and Order","acms_document_guid":""}],"date_created":"2025-08-01T18:06:24.268751-07:00","date_modified":"2026-06-16T08:37:35.446474-07:00","date_filed":"2025-08-01","time_filed":"20:39:43","entry_number":137,"recap_sequence_number":"2025-08-01.001","pacer_sequence_number":560,"description":"PROPOSED STIPULATION AND ORDER. Document filed by Oliver Yucheng Chen, Yongbo Dai, Jianfei Dong, Shaoqing Jiang, Feng Li, Lei Li, James Jun Peng, Qutoutiao Inc., Eric Siliang Tan, Jingbo Wang, Xiaolu Zhu..(Wang, George) (Entered: 08/01/2025)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/432643855/","id":432643855,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/17464782/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/446977728/","id":446977728,"tags":[],"absolute_url":"/docket/17464782/136/in-re-qutoutiao-inc-securities-litigation/","date_created":"2025-07-25T14:06:09.436527-07:00","date_modified":"2026-06-16T08:37:35.428859-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"136","attachment_number":null,"pacer_doc_id":"127037929259","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Stipulation and Order","acms_document_guid":""}],"date_created":"2025-07-25T14:06:09.422347-07:00","date_modified":"2026-06-16T08:37:35.411318-07:00","date_filed":"2025-07-25","time_filed":"16:45:01","entry_number":136,"recap_sequence_number":"2025-07-25.001","pacer_sequence_number":556,"description":"JOINT STIPULATION AND ORDER: NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS: 1.The parties shall advise the Court whether they consent for the Court to deem the pre-motion letters to constitute a fully briefed motion to substitute lead plaintiff and rule on the basis of those letters, or whether the parties request supplemental or full briefing on or before August 1, 2025; 2.If the parties request supplemental or full briefing, they shall submit a proposed briefing schedule on or before August 1, 2025. SO ORDERED. (Signed by Judge Victor Marrero on 7/25/2025) (jca) (Entered: 07/25/2025)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/432532190/","id":432532190,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/17464782/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/446864111/","id":446864111,"tags":[],"absolute_url":"/docket/17464782/135/in-re-qutoutiao-inc-securities-litigation/","date_created":"2025-07-24T22:08:17.888828-07:00","date_modified":"2026-06-16T08:37:35.388701-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"135","attachment_number":null,"pacer_doc_id":"127037922919","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Notice (Other)","acms_document_guid":""}],"date_created":"2025-07-24T22:08:17.869110-07:00","date_modified":"2026-06-16T08:37:35.370624-07:00","date_filed":"2025-07-24","time_filed":"23:51:51","entry_number":135,"recap_sequence_number":"2025-07-24.001","pacer_sequence_number":553,"description":"NOTICE of Joint Stipulation and Proposed Order re: 134 Order,,,,. Document filed by James Pappas..(Ngo, Ivy) (Entered: 07/24/2025)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/431721679/","id":431721679,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/17464782/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/446034914/","id":446034914,"tags":[],"absolute_url":"/docket/17464782/134/in-re-qutoutiao-inc-securities-litigation/","date_created":"2025-07-17T12:55:51.276619-07:00","date_modified":"2026-06-16T08:37:35.352812-07:00","sha1":"78acc0f5cf588f85f515f5bee23e2b6588cda9c3","page_count":2,"file_size":1286166,"filepath_local":"recap/gov.uscourts.nysd.542675/gov.uscourts.nysd.542675.134.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.542675/gov.uscourts.nysd.542675.134.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:20-cv-06707-VM     Document 134   Filed 07/17/25    Page 1 of 2\n\n\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\n                                                                 7/17/2025\n\nIN RE QUTOUTIAO, INC. SECURITIES                   20 Civ. 6707 (VM)\nLITIGATION\n                                                   ORDER\n\n\n\nTHIS DOCUMENT RELATES TO ALL ACTIONS.\n\n\n\nVICTOR MARRERO, United States District Judge.\n\n      The Court is in receipt of Plaintiffs\u2019 letter dated July\n\n16, 2025, informing the Court that the parties have completed\n\nthe   pre-motion        letter   exchange     regarding       Plaintiffs\u2019\n\nanticipated motion to substitute Lead Plaintiff and have\n\nfailed to resolve the issue without resorting to motion\n\npractice. (See Dkt. No. 133; see also Dkt. Nos. 130, 132.)\n\nHaving reviewed the pre-motion letters, the Court is not\n\npersuaded that a pre-motion conference is necessary at this\n\ntime. Accordingly, the Court directs the parties to advise\n\nwhether they consent for the Court to deem the pre-motion\n\nletters to constitute a fully briefed motion to substitute\n\nlead plaintiff and rule on the basis of those letters, or\n\nwhether the parties request supplemental or full briefing. If\n\nthe parties request supplemental or full briefing, they shall\n\nsubmit a proposed briefing schedule within one (1) week of\n\nthe date of this Order.\n\fCase 1:20-cv-06707-VM   Document 134   Filed 07/17/25   Page 2 of 2\n\n\n\nSO ORDERED.\n\nDated:     17 July 2025\n           New York, New York\n\f","ocr_status":2,"date_upload":"2025-07-18T11:42:28.920594-07:00","document_number":"134","attachment_number":null,"pacer_doc_id":"127037879387","is_available":true,"is_free_on_pacer":true,"is_sealed":null,"document_type":1,"description":"Order","acms_document_guid":""}],"date_created":"2025-07-17T12:55:51.251002-07:00","date_modified":"2026-06-16T08:37:35.334149-07:00","date_filed":"2025-07-17","time_filed":"12:36:45","entry_number":134,"recap_sequence_number":"2025-07-17.001","pacer_sequence_number":549,"description":"ORDER: The Court is in receipt of Plaintiffs' letter dated July 16, 2025, informing the Court that the parties have completed the pre-motion letter exchange regarding Plaintiffs' anticipated motion to substitute Lead Plaintiff and have failed to resolve the issue without resorting to motion practice. (See Dkt. No. 133; see also Dkt. Nos. 130, 132.) Having reviewed the pre-motion letters, the Court is not persuaded that a pre-motion conference is necessary at this time. Accordingly, the Court directs the parties to advise whether they consent for the Court to deem the pre-motion letters to constitute a fully briefed motion to substitute lead plaintiff and rule on the basis of those letters, or whether the parties request supplemental or full briefing. If the parties request supplemental or full briefing, they shall submit a proposed briefing schedule within one (1) week of the date of this Order. SO ORDERED. 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