Plaintiffs allege insider token dumping, wash trading, and a multi-year pump-and-dump scheme tied to Cere Network
Brad Bao, the Silicon Valley entrepreneur who co-founded $2.4 billion electric scooter company Lime, has been named as a defendant in a federal racketeering lawsuit alleging he participated in a massive cryptocurrency pump-and-dump scheme. The case represents one of the highest-profile RICO actions to hit the crypto sector, drawing a direct line between a marquee name in tech and what plaintiffs describe as a sprawling, multi-year fraud.
The 41-page complaint was filed in the US District Court for the Northern District of California by investor Vivian Liu and investor group Goopal Digital Ltd. The suit names Bao alongside lead defendant Fred Jin, the CEO of a blockchain venture called Cere Network, and seeks $100 million in compensatory and punitive damages.
Cere Network launched as a blockchain-based decentralized data cloud platform, raising approximately $42.96 million from over 5,000 retail investors. Many were US-based, purchasing tokens through the Republic platform under Regulation D.
According to the complaint, Jin publicly represented that insider token holdings would remain locked and would only vest over a period of months after the initial coin offering in November 2021. The plaintiffs allege the opposite occurred: on the day of the ICO, Jin and his associates transferred large quantities of tokens to exchanges including HTX and Kucoin, then sold aggressively in the weeks that followed.
The Cere token hit an all-time high of $0.47 on launch day. By the end of December 2021, it had collapsed to $0.06. Today it trades at roughly $0.0012 — a 99.7% decline. The total proceeds from the alleged insider sell-off came to approximately $41.78 million.
Bao’s involvement in Cere Network went beyond name recognition. The complaint identifies him as a board member who received director’s fees and an early token allocation. More critically, the filing alleges Bao approved transactions designed to funnel investor funds into personal accounts controlled by Jin, and that he failed to act on accounting irregularities that should have triggered concern.
As the co-founder of Lime — which operates shared electric scooters in cities worldwide — Bao’s name carried significant weight with prospective investors. The complaint suggests that credibility was a key part of the calculus.
This isn’t Bao’s first brush with litigation. He and his companies have previously faced a fraud action involving the City of San Francisco, and a separate suit brought by venture firm Khosla Ventures, which alleged fraud and intentional interference tied to a collapsed $30 million acquisition deal.
The complaint traces the alleged proceeds through a network of shell companies and personal accounts controlled by Jin, his wife Maren Schwarzer, and his brother Xin Jin. The corporate entities span multiple jurisdictions:
Beyond the token sales, the plaintiffs allege an additional $16.6 million was siphoned from corporate wallets and lost in speculative decentralized finance (DeFi) investments.
The lawsuit also draws in Gotbit Ltd., a crypto market-making firm the complaint claims was engaged to deploy automated trading bots that conducted wash trading — generating fake volume to mask the insider sell-off happening behind the scenes.
Gotbit’s founder, Alex Andryunin, was subsequently convicted of wire fraud and market manipulation as part of the US Department of Justice’s Operation Token Mirrors, a federal sting operation targeting crypto market manipulation. The criminal conviction adds significant weight to the civil claims.
The complaint outlines a pattern the plaintiffs say dates back years before Cere Network:
The suit brings claims under the Racketeer Influenced and Corrupt Organizations Act (RICO), RICO conspiracy, fraud, aiding and abetting fraud, negligent misrepresentation, and breach of advisory and token sale agreements.
In addition to Bao and Jin, the named defendants include Schwarzer, Xin Jin, Cere CMO Martijn Broersma, director François Granade, and corporate entities Cerebellum Network Inc., Interdata Network Ltd., and CEF AI Inc.
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