Shortly after the California Northern District Court told Ice Cube to admit defeat or amend his complaint in a lawsuit against Robinhood, he has filed an amended complaint against the online trading app.

The document, submitted at the Court on July 6, 2021, slams Robinhood for being “an unscrupulous and predatory conglomerate that professes to be a financial services company for the everyday person”.

“At this point, the evidence is clear that Robinhood is selling a dangerous bill of goods to unsuspecting consumers across the nation. Robinhood CEO Vlad “the Stock Impaler” Tenev recently offered corporate crocodile tears during sworn Congressional testimony when confronted with the fact that an inexperienced 20-year-old Robinhood user committed suicide after he was wrongly told he owed over $730,000 due to some risky Robinhood trades”, Ice Cube says.

“Robinhood flagrantly displays its belief that it is exempt from the rules and laws that govern everyone else in the United States”, the plaintiff argues.

At the crux of the lawsuit are events from March 2021, when, according to Ice Cube, Robinhood “shamelessly misappropriated Ice Cube’s image and likeness to promote Robinhood’s horrible products and services – the last things in the world to which Ice Cube would ever attach his image and likeness”.

On March 8, 2021, Defendants impermissibly used Ice Cube’s persona – i.e., his image and likeness – in connection with an advertisement for Robinhood’s financial services and products on the “Robinhood Snacks” website and app. The Advertisement uses Ice Cube’s image and likeness, including his signature catch phrase, in order to create the false impression that Ice Cube actually endorses Robinhood, its products, and its services.

Ice Cube argues that the Advertisement creates the false impression that Ice Cube supports, endorses, or is otherwise associated with Robinhood’s products and services. This is especially true as the Advertisement (mis)quotes the most well-known lyric from Ice Cube’s hit single, “Check Yo Self.” Defendants’ deliberate decision to couple Ice Cube’s famous lyrical catchphrase with his pictorial image evidences their intent to capitalize on Ice Cube’s celebrity to attract customers.

In its own effort to lure investors for its Initial Public Offering, Robinhood admits that the true purpose of “Robinhood Snacks” is entice consumers into using Robinhood’s products and services, Ice Cube explains.

Ice Cube alleges that “Robinhood Snacks” is a gateway point for new, unsophisticated customers for the Robinhood platform. Defendants’ repeated refrain that it is merely an “educational” service is belied by Defendants’ admission in the Form S-1 that “Robinhood Snacks” stands to be deemed as investment advice or recommendations by customers and regulatory agencies, he adds. The commercial nature of “Robinhood Snacks” is clear, he concludes.

The Plaintiff prays for judgment against the Defendants that:

• a. Defendants be preliminarily and permanently enjoined from committing the acts alleged herein in violation of 15 U.S.C. § 1125;
• b. Defendants be ordered to pay Plaintiff’s actual, consequential, incidental, and special damages, as well as the Defendants’ profits attributable to the violations alleged;
• c. Defendants be ordered to pay Plaintiff’s attorneys’ fees and costs to the extent available by law; and
• d. Plaintiff be awarded such other and further relief as the Court deems just and proper.

(The featured image is the one used by Robinhood in the problematic ad. Image source: California Northern District Court.)