b'Marcu v. Cheetah Mobile Inc., Case No. 18- On November 26, 2018, Buzzfeed published an article CV-11184 (JMF), 2020 WL 4016645 (S.D.N.Y.related to a click injection scheme in seven of Cheetahs July 16, 2020)apps. The scheme was premised on a feature where Undisclosed Click Injection Code In Appsnewly installed applications perform a lookback to see where the last click came from and provide a To Increase Revenue referral bonus to the developer at that click. According Cheetah Mobile Inc. (Cheetah) is a China-basedto the article, Cheetah apps required its users to give developer of mobile apps, including both games and utilitypermissions for Cheetah to see when new apps are apps, which are available for download through variousdownloaded, along with the ability to launch other apps. channels, including Google Play, the official app storeThe article reported that Cheetahs apps used those for Googles Android mobile operating system. Some ofpermissions to search for bounties and inject fake clicks Cheetahs apps rank among the most popular apps on theto make it appear as though the users had clicked through Google Play store. Because many of Cheetahs apps arean ad published by Cheetah and downloaded the newly free to users, the company generates revenue primarilyadded application on Cheetahs referral, thus prompting through advertising. Many of these advertisements arereferral payments to Cheetah.for other mobile apps. When someone using a CheetahIn a statement responding to the Buzzfeed article, app clicks on an advertisement for a different app, theyCheetah insisted that [a] third-party . [was] responsible are brought to the Google Play store. If the consumerfor the click injection. Regardless, upon the publication downloads the different app and opens it, the developerof the article, some of Cheetahs apps were removed of that other app makes a small payment, known as from the Google Play Store. Moreover, after the articles install bountiestypically between fifty cents and publication, Google conducted its own investigation, three dollarsto Cheetah.and on December 3, 2018, it reported that one of the In public disclosures between April 21, 2015 andseven apps contained code used to execute ad fraud November 21, 2018, Cheetah reported total revenue,techniques known as click injection and Google removed which was largely attributed to online marketingthe app from the Google Play store. Because Google services, which was generated primarily by referringPlay was an important . means of distribution for its apps, user traffic and selling advertisements on [ ] mobile andthe allegations in the article posed a significant risk to PC platforms. It also generally described its core appsCheetahs business. In response to the Buzzfeed article, and success of those apps, including certain statisticsCheetahs American depositary share price fell nearly about those apps, such as where they ranked in total37%, over the next two trading days.downloads or popularity. Cheetah warned [i]f GoogleInvestors filed a putative securities class action against Play. terminate[s] their existing relationship with us, ourCheetah and certain of its officers asserting claims business, financial condition and results of operations mayunder Sections 10(b) and 20(a) of the 1934 Act. Plaintiffs be materially and adversely affected. complaint alleged that Cheetahs failure to disclose its 70'