😶🚀8$ZBCN🚀😶-XRP🚀😶

UNITED STATES DISTRICT COURT PROPOSED CLASS ACTION COMPLAINT XRP PURCHASERS AND INVESTORS, INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED, Plaintiffs, v. RIPPLE LABS, INC., BRADLEY GARLINGHOUSE, AND OTHER RESPONSIBLE EXECUTIVES, Defendants. COMPLAINT FOR ALLEGED INVESTOR DECEPTION, MATERIAL MISREPRESENTATION, FRAUDULENT OMISSIONS, AND RELATED VIOLATIONS OF LAW Proposed pleading for investigation and review by qualified securities litigation counsel. ⸻ PRELIMINARY STATEMENT This action arises from an alleged disconnect between Ripple Labs, Inc.‘s public representations concerning the importance of XRP to its corporate strategy and the company’s subsequent commercial decisions, particularly the development, promotion, and integration of its RLUSD stablecoin. For years, Ripple’s leadership has publicly communicated that XRP is fundamental to the company’s purpose, strategy, and commercial future. Ripple CEO Bradley Garlinghouse has characterized XRP as the company’s North Star and has stated that all roads lead back to XRP. Among the statements attributed to Ripple’s leadership are: “All roads lead to XRP.” “XRP is at the center of everything we do.” “XRP is our North Star.” These representations were made by individuals with direct knowledge of Ripple’s corporate strategy and carried significant weight among members of the XRP investment community. Plaintiffs allege that such representations helped establish an expectation that Ripple’s commercial expansion, institutional relationships, payment infrastructure, and growing financial services business would translate into meaningful adoption and utilization of XRP. However, Ripple subsequently developed and expanded RLUSD, a dollar-backed stablecoin that can facilitate payment and settlement transactions without necessarily requiring XRP to function as the bridge asset. Plaintiffs contend that Ripple’s leadership should be required to explain whether the company’s actual commercial strategy was consistent with the expectations created by its repeated public representations. The central issue is not whether Ripple has the right to develop RLUSD. It does. The issue is whether investors were provided a materially accurate picture of XRP’s actual role in Ripple’s commercial strategy while those investments were being solicited and traded.