Executive Summary
A federal RICO complaint filed in the Northern District of California has named Brad Bao — best known as the co-founder of $2.4 billion electric scooter company Lime — as a defendant in what plaintiffs describe as a multi-year cryptocurrency pump-and-dump scheme involving the Cere Network token. The case is significant not just for the $100 million in damages sought, but for what it illustrates about a persistent structural problem in crypto: the gap between the names on a project’s leadership page and the actual oversight those individuals provide. The complaint details insider token dumping, wash trading through a subsequently convicted market maker, shell company fund routing across four jurisdictions, and unpaid investor allocations. For anyone evaluating early-stage crypto projects, the fact pattern here is worth studying regardless of how the litigation resolves.
Why This Case Matters Beyond the Headlines
We at TechBullion have covered dozens of crypto fraud cases over the past several years, and the pattern rarely changes: a promising-sounding project raises millions, insiders extract value, retail investors are left holding worthless tokens, and the legal system eventually catches up — years after the damage is done. What makes the Cere Network case worth a deeper look is that it connects a genuinely prominent name in Silicon Valley tech to that same pattern.
Brad Bao isn’t an anonymous crypto founder. He co-founded Lime, the electric scooter company that operates in cities worldwide and reached a $2.4 billion valuation. When someone with that pedigree sits on a blockchain project’s board, it sends a specific signal to investors: this project has been vetted by someone with serious credentials. The complaint filed by investor Vivian Liu and investor group Goopal Digital Ltd. alleges that signal was exactly the point — and that Bao’s involvement lent credibility to a venture that was, according to the plaintiffs, designed to defraud investors from the start.
The lawsuit (Case No. 3:26-cv-00857) names Bao alongside lead defendant Fred Jin, described as Cere Network’s CEO and the alleged architect of the scheme, along with several other individuals and corporate entities. The plaintiffs are seeking $100 million in compensatory and punitive damages under RICO and multiple additional causes of action.
How the Alleged Scheme Worked
The mechanics described in the complaint will be familiar to anyone who has followed crypto fraud cases, but the scale and specificity of the allegations are notable.
Cere Network launched as a blockchain-based decentralized data cloud platform and raised approximately $42.96 million from over 5,000 retail investors, many of them U.S.-based and purchasing tokens through the Republic platform under Regulation D. Ahead of the initial coin offering in November 2021, Jin publicly represented that insider token holdings would remain locked and would only vest over a period of months. According to the complaint, on the day of the ICO, Jin and his associates transferred large quantities of tokens to exchanges including HTX and Kucoin and sold aggressively over the following weeks.
The numbers are stark. The Cere token reached $0.47 on launch day. By December 31, 2021, it had collapsed to $0.06. Today it trades at roughly $0.0012 — a 99.7% decline from its all-time high. The filing states the total proceeds from the alleged insider sell-off came to approximately $41.78 million.
The complaint traces the money through intermediate wallets and into a network of shell companies and personal accounts controlled by Jin, his wife Maren Schwarzer, and his brother Xin Jin, spanning entities in Delaware, the British Virgin Islands, Panama, and Germany. An additional $16.6 million was allegedly siphoned from corporate wallets and lost in speculative DeFi investments.
The Wash Trading Layer: Gotbit and Operation Token Mirrors
If the insider sell-off is the core allegation, the wash trading component is what makes the case technically interesting from a market manipulation standpoint.
The complaint 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 create the appearance of healthy market interest while insiders were systematically liquidating their positions. For retail investors watching the trading activity at the time, the artificial volume would have masked the sell-off entirely.
This matters because 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 fact that the market maker used in the alleged Cere scheme has since been criminally convicted adds a layer of federal precedent to the civil allegations that is difficult to dismiss.
What Bao Is Specifically Accused Of
An honest analysis requires separating what the complaint alleges about Bao specifically from what it alleges about Jin as the lead defendant. The two are not equivalent.
The complaint identifies Bao as a Cere Network board member who received director’s fees and an early token allocation. It alleges 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 triggered concern. The complaint further alleges that Bao’s involvement was strategically important because his Lime pedigree gave the project an aura of legitimacy that it would not otherwise have commanded.
This isn’t Bao’s first appearance in litigation. He and his companies have previously faced a fraud action involving the City of San Francisco and a separate lawsuit brought by venture firm Khosla Ventures, which alleged fraud and intentional interference in connection with a collapsed $30 million acquisition deal.
The question the court will eventually have to resolve is whether Bao’s role constituted active participation in the alleged scheme or whether he was a negligent board member who failed to exercise adequate oversight. For the purposes of this analysis, both scenarios carry meaningful implications for how crypto projects use advisory and board appointments.
The Investor at the Center of the Case
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. According to the complaint, 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 tokens and Goopal was owed 33.3 million tokens — worth a combined $25 million at the ICO peak price. Neither Liu nor Goopal ever received their tokens, according to the filing. The plaintiffs argue they were unable to sell at market price while insiders were secretly cashing out.
A Pattern That Predates Cere Network
One of the more interesting aspects of the complaint is the attempt to establish a pattern of conduct that extends well beyond Cere Network. The plaintiffs allege that Jin was involved in a mobile gaming company called Funler in 2015, followed by an education-blockchain platform called Bitlearn in 2017, both of which the complaint characterizes as earlier iterations of the same playbook: launch a venture, raise money under false pretenses, extract value, and move on.
If the court finds this alleged pattern credible, it has significant implications for the RICO claims specifically. RICO requires a pattern of racketeering activity, and demonstrating a recurring method across multiple ventures is exactly how plaintiffs typically meet that threshold.
What This Tells Us About Crypto’s Accountability Problem
The broader lesson here is structural, and it’s one we’ve seen play out repeatedly in crypto: advisory and board roles at token projects often function as credibility endorsements without corresponding accountability. A recognizable name from traditional tech or finance lends a project legitimacy in the eyes of retail investors, but the individual may have limited operational involvement, limited visibility into how funds are being managed, and limited incentive to ask uncomfortable questions.
For investors, the practical takeaway is that a prominent board member is not a substitute for verifiable on-chain transparency. Vesting claims that can’t be confirmed on-chain should be treated as unverified. Revenue and partnership claims that lack independent validation should be discounted. And the presence of a well-known name on a project’s website is a marketing asset, not a guarantee of fiduciary oversight.
Where the Case Stands
The suit asserts claims under the Racketeer Influenced and Corrupt Organizations Act, 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, 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.
FAQ
What is a RICO lawsuit?
RICO stands for the Racketeer Influenced and Corrupt Organizations Act, a federal law originally designed to combat organized crime. It allows plaintiffs to sue defendants who engage in a “pattern of racketeering activity” — meaning two or more related criminal acts (called “predicate acts”) within a ten-year period. RICO claims carry significant weight because they can result in treble damages and they require the court to evaluate whether the alleged conduct reflects an ongoing enterprise rather than an isolated incident.
Who is Brad Bao?
Brad Bao is the co-founder of Lime, the electric scooter and micro-mobility company that reached a $2.4 billion valuation and operates in cities across the globe. He is named in this lawsuit as a board member of Cere Network. The complaint alleges he lent the project credibility and approved transactions that facilitated the alleged scheme.
What is Cere Network?
Cere Network was pitched as a blockchain-based decentralized data cloud platform designed to improve customer data privacy and security. It raised approximately $42.96 million from over 5,000 retail investors through a token sale in November 2021. The Cere token has since lost 99.7% of its value from its all-time high.
What is Gotbit and why does it matter here?
Gotbit Ltd. was a crypto market-making firm whose founder, Alex Andryunin, was convicted of wire fraud and market manipulation as part of the DOJ’s Operation Token Mirrors. The complaint alleges Gotbit was engaged by Cere’s leadership to conduct wash trading — fake volume generation through automated bots — to disguise the insider sell-off. The criminal conviction of Gotbit’s founder provides independent federal corroboration of the type of activity the plaintiffs allege occurred.
What should crypto investors take away from this case?
The primary takeaway is that prominent names on a project’s board or advisory team are not substitutes for verifiable transparency. Investors should insist on on-chain confirmation of vesting schedules and lockup claims, independent validation of stated partnerships and revenue, and clear governance structures that impose real accountability on board members and advisors. If these cannot be verified, treat the project’s claims as marketing rather than fact.
