Lime Co-Founder Brad Bao Named in $100M RICO Lawsuit Over Alleged Cere Token Pump-and-Dump

A 41-page federal racketeering complaint filed in the U.S. District Court for the Northern District of California names Brad Bao, co-founder of the $2.4 billion electric scooter company Lime, as a defendant in an alleged cryptocurrency pump-and-dump scheme. Plaintiffs Vivian Liu and investor group Goopal Digital Ltd. accuse Bao alongside lead defendant Fred Jin, CEO of Cere Network, and multiple others of defrauding retail investors out of tens of millions of dollars. The suit seeks $100 million in compensatory and punitive damages under the Racketeer Influenced and Corrupt Organizations Act (RICO) and other causes.

CERE token crashed 99.7% from $0.47 to $0.0012

The alleged scheme centered on Cere Network, a blockchain-based data cloud platform that raised approximately $42.96 million from over 5,000 retail investors in November 2021 via Regulation D. According to the complaint, Jin publicly stated insider tokens would remain locked and vest over months after the ICO, but on launch day he and associates transferred large amounts of tokens to exchanges including HTX and KuCoin and sold aggressively, generating about $41.78 million. CERE hit an all-time high of $0.47 on launch day and collapsed to $0.06 by December 31, 2021. The token currently trades around $0.0012, a 99.7% decline. The complaint describes CERE as "utterly worthless as a result of the fraudulent scheme."

Bao's Lime pedigree lent credibility

Bao's role as a Cere board member and Lime co-founder gave the project legitimacy. The complaint alleges Bao received director fees and an early token allocation, approved transactions funneling investor funds to Jin-controlled personal accounts, and ignored accounting red flags. Bao has prior litigation including a San Francisco fraud case and a Khosla Ventures suit. Other defendants include Jin's wife Maren Schwarzer, his brother Xin Jin, CMO Martijn Broersma, director François Granade, and several shell companies in Delaware, BVI, Panama, and Germany.

Gotbit market maker deployed wash trading bots

The suit alleges Jin hired crypto market maker Gotbit to run automated wash trading bots generating fake volume to disguise insider selling. Gotbit founder Alex Andryunin was later convicted of wire fraud and market manipulation in the DOJ's Operation Token Mirrors. Plaintiff Vivian Liu claims Jin recruited her in 2019 with false promises about lockups and Fortune 500 clients. Liu and Goopal were owed 53.3 million CERE (worth ~$25 million at peak) but never received them. The complaint also cites Jin's prior ventures—mobile game company Funler (2015) and education-blockchain platform Bitlearn (2017)—as part of a pattern of racketeering activity.