Honig

I. BACKGROUND

17 On April 8, 2019, Plaintiff filed a Complaint in the Superior Court of the State of 18 California for the County of San Diego against Defendants. (ECF No. 1-2). Plaintiff is a 19 clinical-stage biotechnology company that develops cancer treatments. Id. ¶ 1. Plaintiff 20 alleges that Defendants, “a group of market manipulators” led by Defendant Barry Honig, 21 accumulated a controlling position in Plaintiff’s stock. Id. ¶ 3. Plaintiff alleges that 22 Defendants “pretended they sought legitimate returns” by investing in Plaintiff, but they 23 really sought to manipulate Plaintiff. Id. Plaintiff alleges that Defendants “defrauded 24 [Plaintiff] through illicit transactions for their enormous profit to the detriment of 25 [Plaintiff].” Id. Plaintiff alleges that, among other things, Defendants caused Plaintiff to 26 issue Defendants “tens of millions of dollars’ worth of common stock;” cut Plaintiff off 27 from legitimate investors; caused Plaintiff to be subjected to a SEC investigation; forced 28 Plaintiff to “publicly disclaim reliance on past financial statements rendered inaccurate by Defendants;” and caused Plaintiff to be…