Lime Co-Founder Brad Bao Named in $100M RICO Lawsuit: Federal Complaint Alleges Massive Crypto Pump-and-Dump Through Cere Network
A federal racketeering lawsuit filed in the U.S. District Court for the Northern District of California has named Brad Bao, co-founder of $2.4 billion electric scooter company Lime, as a defendant in an alleged cryptocurrency pump-and-dump scheme involving the Cere Network token. The 41-page complaint was brought by investor Vivian Liu and investor group Goopal Digital Ltd. against Bao, Cere Network CEO Fred Jin, and multiple other defendants and corporate entities. The plaintiffs are seeking $100 million in compensatory and punitive damages under the Racketeer Influenced and Corrupt Organizations Act (RICO), alleging a coordinated multi-year scheme that defrauded retail investors out of tens of millions of dollars through fraudulent token sales, insider dumping, and wash trading conducted through a market-making firm whose founder has since been criminally convicted.
The case (No. 3:26-cv-00857) centers on Cere Network, which launched as a blockchain-based decentralized data cloud platform and raised approximately $42.96 million from over 5,000 retail investors. Many of these investors were U.S.-based and purchased Cere tokens through the Republic platform under Regulation D. According to the complaint, lead defendant Fred Jin publicly represented ahead of the initial coin offering in November 2021 that insider token holdings would remain locked and would only vest over a period of months. 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 over the following weeks. The total proceeds from the alleged insider sell-off came to approximately $41.78 million.
The price impact was severe. The Cere token reached an all-time high of $0.47 on its launch day, then collapsed to $0.06 by December 31, 2021. The token currently trades at approximately $0.0012, representing a 99.7% decline from its peak value. The complaint describes the token as “utterly worthless as a result of the fraudulent scheme” and alleges that the defendants effectively abandoned the Cere project after extracting value from retail investors.
The complaint identifies Bao’s role as a board member of Cere Network whose participation lent the project credibility with the broader investment community. As the co-founder of Lime, which operates shared electric scooters in cities across the globe, Bao’s name carried significant weight with prospective token buyers. The filing alleges that Bao received director’s fees and an early token allocation in exchange for serving on the board, that he 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 raised concerns for any board member exercising basic fiduciary oversight. Bao has faced prior litigation, including a fraud action involving the City of San Francisco and a separate lawsuit brought by venture capital firm Khosla Ventures, which alleged fraud and intentional interference in connection with a collapsed $30 million acquisition deal.
The complaint traces the alleged proceeds through intermediate cryptocurrency wallets and into a network of shell companies and personal accounts controlled by Jin, his wife Maren Schwarzer, and his brother Xin Jin. The entities named in the suit span jurisdictions including Delaware, the British Virgin Islands, Panama, and Germany. In addition to the alleged insider token sales, the plaintiffs claim an additional $16.6 million was siphoned from corporate wallets and lost in speculative decentralized finance (DeFi) investments, describing a pattern of misappropriation that extended well beyond the initial token offering.
The lawsuit further alleges that Jin and his associates engaged Gotbit Ltd., a crypto market-making firm, to deploy automated trading bots that conducted wash trading — generating fake volume to disguise the insider sell-off. Gotbit’s founder, Alex Andryunin, was subsequently convicted of wire fraud and market manipulation as part of the U.S. Department of Justice’s Operation Token Mirrors, a federal sting operation that specifically targeted crypto market-making firms engaged in wash trading. The criminal conviction of the market maker’s founder provides independent federal corroboration of the type of activity the plaintiffs allege occurred during the Cere token launch. For retail investors monitoring the trading activity at the time, the artificial volume would have created the appearance of healthy market interest while insiders were systematically liquidating their holdings.
Plaintiff Vivian Liu alleges she was recruited by Jin in 2019 to work for and invest in Cere Network, with promises of returns through the company and the Cere token. The complaint states that Jin made repeated misrepresentations about lockup provisions, the company’s Fortune 500 client relationships, and how raised funds would be used to develop the platform. Liu claims she was owed 20 million Cere tokens and Goopal was owed 33.3 million tokens — a combined value of approximately $25 million at the ICO peak price. Neither Liu nor Goopal ever received their tokens, according to the filing, leaving them unable to sell at market price while insiders were allegedly cashing out.
The plaintiffs further allege that Jin’s pattern of conduct predates Cere Network, citing his involvement in a mobile gaming company called Funler in 2015 and an education-blockchain platform called Bitlearn in 2017. The complaint characterizes both ventures as earlier iterations of the same alleged scheme: launch a venture, raise capital under false pretenses, extract value, and move on to the next project. The plaintiffs argue this established pattern is central to the RICO claims, which require demonstration of an ongoing pattern of racketeering activity involving two or more predicate acts.
The suit asserts claims under 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 Maren Schwarzer, Xin Jin, Cere CMO Martijn Broersma, director François Granade, and corporate entities Cerebellum Network Inc., Interdata Network Ltd., and CEF AI Inc. The full federal complaint is available here.
Pranab Bhandari is an Editor of the Financial Blog “Financebuzz”. Apart from writing informative financial articles for his blog, he is a regular contributor to many national and international publications namely Tweak Your Biz, Growth Rocks ETC.
