A second federal civil lawsuit filed in the U.S. District Court for the Northern District of California names Cere Network CEO Fred Jin, Lime co-founder Brad Bao, and several related individuals and entities as defendants in a dispute involving the blockchain project Cere Network.
The new complaint was filed by investor Josef Qu and seeks $57 million in damages. It follows an earlier federal lawsuit filed by Goopal Digital Limited and other plaintiffs that seeks $100 million. Taken together, the two pending cases seek $157 million in damages. The allegations in both complaints have not been proven in court.
According to the Qu complaint, the case concerns alleged misrepresentations made to investors in connection with Cere Network’s token launch, token distribution, and use of investor funds. The filing asserts 10 causes of action, including claims under the Racketeer Influenced and Corrupt Organizations Act (RICO), securities fraud under Sections 10(b) and 20(a) of the Securities Exchange Act, theft, and related state-law claims.
The earlier Goopal lawsuit asserted six claims, including RICO, conspiracy, fraud, negligent misrepresentation, and breach of contract. The newer complaint adds securities-related claims and places greater emphasis on the role of corporate control, token handling, and the movement of funds.
Both lawsuits allege that Cere Network raised substantial sums through private token-related transactions and that investors were told insider token holdings would be subject to lockups or vesting restrictions following the project’s November 2021 launch. The plaintiffs allege that, contrary to those representations, large quantities of tokens were transferred to exchanges, including HTX and KuCoin, and sold shortly after trading began.
The Qu complaint identifies Jin as a central decision-maker at Cere Network and alleges that he controlled treasury wallets, directed token transfers, approved certain financial arrangements, and oversaw the movement of company and investor funds. The complaint also alleges that he authorized decentralized finance investments that resulted in losses and made statements to investors that were inconsistent with how funds and tokens were ultimately handled. Those allegations have not been adjudicated.
Qu alleges that he invested through a Simple Agreement for Future Tokens, or SAFT, in 2019 and that he was entitled to receive 27,777,778 CERE tokens. According to the complaint, he did not receive those tokens despite repeated requests. The earlier plaintiffs make similar allegations, claiming that they were entitled to receive tokens that were never delivered.
The new filing also cites blockchain transaction records that, according to the plaintiff, show movements of tokens and funds from wallets associated with Cere Network. The complaint further alleges that approximately $16.6 million of investor capital was placed into several decentralized finance strategies without investor authorization or adequate disclosure. The filing describes losses tied to positions involving Mochi Protocol, a CVX/ETH liquidity pool, Maple Finance, and the Neutrino USDN protocol.
In addition, both lawsuits allege that proceeds from token sales were routed through a network of related companies and accounts associated with Jin and members of his family. The Qu complaint further alleges that some of those funds were later used for real estate purchases and to support another venture, CEF AI Inc. Those claims remain allegations by the plaintiff.
Bao is named in both cases based on his alleged role as a Cere Network board member. The complaints allege that he received director compensation and token allocations, helped lend credibility to the project, and approved certain financial transactions. The Qu complaint also asserts a Section 20(a) “control person” claim against Bao, which is a securities-law theory used to seek liability against individuals who exercised control over an entity alleged to have violated federal securities laws.
The complaint also references Gotbit Ltd., a crypto market-making firm, and alleges that it was used to create artificial trading activity in CERE tokens. The plaintiff characterizes that activity as part of a broader effort to support trading volume while insiders sold tokens. Those allegations have not been established in court in this case.
The Qu complaint also includes allegations about Jin’s prior business ventures and argues that they are relevant to the pattern element required for the RICO claims. It further seeks injunctive relief and a constructive trust over assets the plaintiff alleges are traceable to the conduct described in the complaint.
In addition to Jin and Bao, the defendants named in the new lawsuit include Maren Schwarzer, Xin Jin, Cere executive Martijn Broersma, director François Granade, and several corporate entities, including Cerebellum Network Inc., Interdata Network Ltd., and CEF AI Inc.
The two cases are Josef Qu v. Fred Jin et al., No. 3:26-cv-01235, and Goopal Digital Limited et al. v. Fred Jin et al., No. 3:26-cv-00857, both pending in the U.S. District Court for the Northern District of California. No court has ruled on the merits of the allegations.
