Brad Bao, co-founder of $2.4 billion scooter company Lime, is among several defendants named in a federal RICO lawsuit alleging a massive crypto fraud scheme.
Brad Bao is best known for building Lime into one of the world’s largest electric scooter companies—a venture that reached a $2.4 billion valuation and put shared micro-mobility on the map in cities across the globe. But now Bao’s name is appearing in a very different context: a 41-page federal racketeering complaint filed in U.S. District Court for the Northern District of California that accuses him and several co-defendants of participating in what plaintiffs describe as a sprawling cryptocurrency pump-and-dump operation.
The lawsuit (Case No. 3:26-cv-00857) was brought by investor Vivian Liu and her investment company Goopal Digital Ltd. They’re seeking $100 million in compensatory and punitive damages, alleging a scheme that bilked tens of millions of dollars from employees and investors who put their trust—and their money—into a crypto project called Cere Network.
Bao’s Role: The Big Name on the Board
In the crypto world, having a recognizable name attached to a project can be the difference between attracting serious capital and being ignored. According to the complaint, that’s the role Bao played at Cere Network. As a board member and co-founder of Lime, his involvement signaled to prospective investors that the project had credible leadership behind it.
The plaintiffs allege Bao received director’s fees and an early token allocation in exchange for his board seat. More critically, the filing claims he approved transactions that were designed to funnel investor funds into the personal accounts of lead defendant Fred Jin—Cere’s CEO and the alleged architect of the scheme. The complaint further alleges Bao turned a blind eye to accounting irregularities that should have triggered alarm bells for any board member exercising basic fiduciary oversight.
Bao’s involvement in litigation isn’t entirely new. He and his companies have previously faced a fraud action involving the City of San Francisco and a separate lawsuit brought by prominent venture firm Khosla Ventures, which alleged fraud and intentional interference in connection with a collapsed $30 million acquisition deal.
The Alleged Scheme: Locked Tokens That Weren’t Locked
The central allegations revolve around Fred Jin, who the complaint describes as having a recurring pattern of launching ventures, raising money under false pretenses, extracting value, and then moving on to the next project. The plaintiffs trace this pattern back to a mobile gaming company called Funler in 2015, then an education-blockchain platform called Bitlearn in 2017, before arriving at Cere Network in 2019.
Cere Network was pitched as a decentralized data cloud platform using blockchain technology to improve customer data privacy and security. The project raised approximately $42.96 million from over 5,000 retail investors—many of them U.S.-based, purchasing tokens through the Republic platform under Regulation D. Ahead of the initial coin offering in November 2021, Jin publicly represented that insiders wouldn’t sell their tokens, and that holdings would only unlock months later under a strict vesting schedule.
According to the complaint, the opposite happened. On the day of the ICO, Jin and his associates allegedly transferred tokens to exchanges including HTX and Kucoin, then sold aggressively over the following weeks. The Cere token reached an all-time high of $0.47 on launch day. By December 31, 2021, it had crashed to $0.06—a collapse the plaintiffs attribute directly to the massive insider selling pressure. The total proceeds from the alleged sell-off came to approximately $41.78 million.
The money didn’t stay on the exchanges. The complaint traces the proceeds 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—entities spanning Delaware, the British Virgin Islands, Panama, and Germany. Separately, the suit alleges an additional $16.6 million was siphoned from corporate wallets and lost in speculative DeFi investments.
The Investor Who Says She Was Promised Millions in Tokens
The complaint includes specific allegations from plaintiff Vivian Liu, who says she met Jin in 2019 and was recruited to work for and invest in Cere Network. According to the filing, Jin promised Liu a return on her investment plus profits through the company and the Cere token. Throughout her tenure, she says 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 alleges she was owed 20 million tokens and Goopal was owed 33.3 million tokens—worth a combined $25 million at the ICO peak price. Despite repeated requests, the complaint says neither Liu nor Goopal ever received their tokens. The plaintiffs argue they were unable to sell at market price while insiders were secretly cashing out.
The Gotbit Connection: A Convicted Market Maker in the Mix
Adding another layer to the allegations, the complaint claims 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 disguise the massive insider sell-off happening behind the scenes. Gotbit’s founder, Alex Andryunin, was subsequently convicted of wire fraud and market manipulation as part of the DOJ’s Operation Token Mirrors, a federal sting operation targeting crypto market makers.
For retail investors watching the trading activity at the time, the artificial volume would have made the Cere token appear to have healthy market interest—even as insiders were systematically dumping their holdings.
Where Things Stand Now
The Cere token currently trades at approximately $0.0012—a decline of 99.7% from its all-time high. The plaintiffs don’t mince words, calling the token “utterly worthless as a result of the fraudulent scheme.” After the sell-off, the complaint alleges the defendants effectively abandoned the Cere project.
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 Francois Granade, and corporate entities Cerebellum Network Inc., Interdata Network Ltd., and CEF AI Inc.
The plaintiffs are represented by John K. Ly and Jennifer L. Chor of Liang Ly LLP. The case is Goopal Digital Limited et al. v. Fred Jin et al., Case No. 3:26-cv-00857, in the U.S. District Court for the Northern District of California.
What This Means for Crypto Investors
This case highlights a question that keeps resurfacing in the crypto space: how much weight should investors give to the names on a project’s board? Bao’s Lime pedigree would have been a strong signal to many retail buyers that Cere Network was a serious venture. The complaint suggests that signal may have been exactly the point.
For anyone evaluating token offerings, the allegations here offer a practical checklist of red flags: vesting promises that aren’t verifiable on-chain, insider selling disguised by wash trading, funds routed through family accounts and offshore shells, and board members whose oversight appears to have been nominal at best. The full federal complaint is available here.
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