Labaton Sucharow LLP (“Labaton Sucharow”) announces that on October 14, 2022 it filed a securities class action lawsuit (the “Complaint”) on behalf of its clients Naya 1740 Fund Ltd., Naya Coldwater Fund, Naya Master Fund LP, Nayawood LP, and Quantum Partners LP (collectively “Naya”) against Coupang, Inc. (“Coupang” or the “Company”) (NYSE: CPNG), and related parties (collectively, “Defendants”). The action, which is captioned Naya 1740 Fund Ltd. v. Coupang, Inc., No. 22-cv-8756 (S.D.N.Y.), asserts claims under Sections 11, 12(a)(2), and 15 of the Securities Act of 1933 (the “Securities Act”) on behalf of all persons and entities that purchased or otherwise acquired Coupang Class A common stock pursuant, or traceable, or both, to materials issued in connection with Coupang’s March 2021 initial public offering (the “IPO”). The action also asserts claims under Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 (the “Exchange Act”), and U.S. Securities and Exchange Commission (“SEC”) Rule 10b-5 promulgated thereunder, on behalf of all persons or entities who purchased or otherwise acquired Coupang securities between March 11, 2021, and July 12, 2022, inclusive (the “Class Period”).

The Complaint expands upon the action against Coupang captioned Choi v. Coupang, Inc., No. 22-cv-07309 (S.D.N.Y.) (the “Choi complaint”) by adding the Exchange Act claims that are outlined above. The Complaint also expands upon the Choi complaint by adding the following six underwriter defendants to the Securities Act claims: Citigroup Global Markets Inc., HSBC Securities (USA), Inc., Deutsche Bank Securities Inc., UBS Securities LLC, Mizuho Securities USA LLC, CLSA Limited. Pursuant to the notice published on August 26, 2022, in connection with the filing of the Choi complaint, as required by the Private Securities Litigation Reform Act of 1995, investors wishing to serve as Lead Plaintiff in the securities actions pending against Coupang are required to file a motion for appointment as Lead Plaintiff by no later than October 25, 2022.

Coupang is one of the largest e-commerce companies in Asia. Headquartered in Seoul, South Korea, the Company uses mobile applications and Internet websites to offer a wide range of products and services throughout the South Korean retail market, including home goods, apparel and beauty products, electronics, grocery and restaurant orders and deliveries, and content streaming. Not only does Coupang sell first-party goods it sources itself, but it also provides a marketplace for third-party merchandise. Coupang also provides a “Rocket WOW” customer loyalty program to offer additional benefits to its most engaged and frequent customers. Pursuant to documents filed in connection with the IPO, including Coupang’s registration statement and prospectus (the “IPO Materials”), Coupang sold to the investing public one hundred million shares of Coupang Class A common stock at $35 per share, for total gross proceeds of $3.5 billion.

The Complaint alleges that the IPO Materials, and subsequent statements made by the Defendants during the Class Period, were materially false and misleading because they falsely represented the Company’s relationships with its customers, merchants, suppliers, and employees in a positive light while failing to disclose the following adverse facts: (a) that Coupang was engaged in improper anti-competitive practices with its suppliers and other third parties in violation of applicable regulations, including pressuring suppliers to raise prices of products on competing e-commerce platforms in order to ensure Coupang’s prices would be more competitive and coercing suppliers into purchasing advertisements that would benefit Coupang financially; (b) that Coupang had improperly adjusted search algorithms and manipulated product reviews on its marketplace platform in order to prioritize its own private-label branded products over those of other sellers and merchants, to the detriment of consumers, merchants, and suppliers; (c) that, unbeknownst to its Rocket WOW members, Coupang was selling products to non-member customers at lower prices than those offered to its Rocket WOW members; (d) that Coupang subjected its workforce to extreme, unsafe, and unhealthy working conditions; (e) that all the above illicit practices exposed the Company to a heightened, but undisclosed, risk of reputational and regulatory scrutiny that would harm the Company’s critical relationships with customers, merchants, suppliers, and the workforce; and (f) that Coupang’s lower prices, historical revenues, competitive advantages, and growing market share were the result of systemic, improper, unethical, and/or illegal practices, and, thus, unsustainable.

These illicit practices, heightened regulatory risks, unsustainable revenues, and other undisclosed issues were later revealed to the market through a series of public disclosures during 2021 and 2022, including government investigations, regulatory sanctions, and unsafe working conditions that caused worker deaths and the loss of a key fulfillment center. As a result of these disclosures, the prices of Coupang’s securities dropped significantly. For example. on August 26, 2022, at the time of the filing of the Choi complaint, Coupang Class A common stock closed at $17.14 per share, a 51 percent decline from the IPO price of $35.

If you purchased or acquired Coupang securities during the Class Period or purchased Coupang Class A common stock pursuant and/or traceable to the IPO Materials, you are a member of the “Class” and may be able to seek appointment as Lead Plaintiff. Lead Plaintiff motion papers must be filed no later than October 25, 2022. The Lead Plaintiff is a court-appointed representative for absent members of the Class. You do not need to seek appointment as Lead Plaintiff to share in any Class recovery in this action. If you are a Class member and there is a recovery for the Class, you can share in that recovery as an absent Class member. You may retain counsel of your choice to represent you in this action.

If you would like to consider serving as Lead Plaintiff or have any questions about this lawsuit, you may contact Francis P. McConville, Esq. of Labaton Sucharow, at (212) 907-0650, or via email at fmcconville@labaton.com. You can view a copy of the complaint here.

Naya is represented by Labaton Sucharow, which represents many of the largest pension funds in the United States and internationally with combined assets under management of more than $2 trillion. Labaton Sucharow’s litigation reputation is built on its half-century of securities litigation experience, more than sixty full-time attorneys, and in-house team of investigators, financial analysts, and forensic accountants. Labaton Sucharow has been recognized for its excellence by the courts and peers, and it is consistently ranked in leading industry publications. Offices are located in New York, NY, Wilmington, DE, and Washington, D.C. More information about Labaton Sucharow is available at www.labaton.com.

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