Electric scooter company Lime filed an S-1 registration statement with the Securities and Exchange Commission on May 7, seeking to list on the Nasdaq Global Select Market under the ticker symbol “LIME.” The filing arrives as the company’s executive chairman and co-founder, Brad Bao, faces two federal racketeering lawsuits with combined claims of $157 million.
The S-1, led by Goldman Sachs and JPMorgan Chase, discloses $886.7 million in revenue for 2025 and approximately $1 billion in current liabilities. The document does not appear to reference the RICO lawsuits naming Bao or his involvement with the blockchain venture at the center of the fraud allegations.
The legal exposure is compounding at the same time federal prosecutors are arresting and extraditing employees of Gotbit Ltd., the market-making firm both suits allege was hired to manipulate the cryptocurrency at the center of the case.
Lime’s IPO Filing: The Numbers
Lime, formally known as Neutron Holdings Inc., plans to list on the Nasdaq with Goldman Sachs and JPMorgan Chase leading the underwriter syndicate. The filing reveals rapidly growing revenue, from $521 million in 2023 to $686.6 million in 2024 to $886.7 million in 2025, alongside significant financial pressures.
The company reported net losses of $59.3 million in 2025 and approximately $1 billion in current liabilities, with $675.8 million due by the end of 2026. Lime disclosed that it does not have “sufficient liquidity” to cover those obligations. Free cash flow reached $104 million in 2025, nearly double the prior year.
Lime operates in approximately 230 cities across 29 countries. Uber, which is both a major investor and partner, accounts for approximately 14.3 percent of revenue through an exclusive integration within the Uber app. The company operates extensively across the United Kingdom, where it is one of the most visible shared micromobility platforms in London and other major cities.
Two Federal RICO Lawsuits, $157 Million in Claims
The first lawsuit was filed by investor group Goopal Digital Limited (Case No. 3:26-cv-00857), seeking $100 million in damages. The second was brought by San Francisco investor Josef Qu (Case No. 3:26-cv-01235), seeking $57 million.
Both were filed in U.S. District Court for the Northern District of California and allege a coordinated pump-and-dump scheme centered on Cere Network, a blockchain platform that raised approximately $42.96 million from over 5,000 retail investors. The CERE token reached an all-time high of $0.47 on its November 2021 launch day. It now trades at approximately $0.00061, a decline of more than 99.8 percent.
The Qu complaint significantly expands the legal theories from the first suit, adding federal securities fraud claims under Section 10(b) and Section 20(a) of the Securities Exchange Act, theft, and breach of the implied covenant of good faith and fair dealing, bringing the total to ten causes of action across the two filings.
The Gotbit Crackdown
Both RICO lawsuits allege that Cere Network CEO Fred Jin hired Gotbit to deploy automated trading bots that conducted wash trading on the day of the CERE token launch, generating fake volume to mask an insider sell-off of approximately $41.78 million.
Gotbit founder and CEO Aleksei Andryunin pleaded guilty to wire fraud and conspiracy to commit market manipulation in March 2025. He was sentenced to eight months in federal prison and ordered to forfeit approximately $23 million in seized cryptocurrency. Gotbit itself was sentenced to five years of probation and ordered to cease operations.
The enforcement has since widened. Gotbit employee Antoine Tsao was arrested at JFK International Airport and pleaded guilty. Serbian national Nemanja Popov was arrested at San Francisco International Airport and also pleaded guilty. In late March 2026, three additional defendants were arrested in Singapore, extradited to the United States, and made their initial court appearances in Oakland. The charges stem from the DOJ’s Operation Token Mirrors, an FBI sting operation in which agents created fake cryptocurrency tokens to expose market manipulation services.
The Alleged Architect
Both complaints identify Jin as the central figure behind the alleged fraud. As CEO and co-founder of Cere Network, Jin allegedly controlled the treasury wallets, directed the arrangement with Gotbit, authorized high-risk DeFi investments that lost $16.6 million of investor capital, and personally oversaw the movement of funds into accounts held by himself, his wife Maren Schwarzer, and his brother Xin Jin.
Plaintiff Qu invested in Cere Network through a Simple Agreement for Future Tokens in 2019, entitling him to 27,777,778 CERE tokens. He never received any of them, the complaint states. The Qu complaint describes a pattern of prior ventures: a mobile gaming company called Funler (2016), which allegedly lost investors 95 percent of their money, and an education-blockchain platform called Bitlearn (2018), which allegedly followed the same trajectory. Jin has since launched a new AI company, CEF AI Inc., which the plaintiff alleges was funded with proceeds from the Cere Network fraud.
Bao’s Role in the Project
Bao co-founded Lime in 2017 and currently serves as its executive chairman. According to the S-1, Lime generated $886.7 million in revenue in 2025, operates in approximately 230 cities across 29 countries, and generated $104 million in free cash flow last year.
Both lawsuits allege Bao received director’s fees and early token allocations from Cere Network, lent his name and mainstream credibility to attract investors, and approved financial transactions that moved funds into accounts controlled by Jin. The Qu complaint adds Section 20(a) “control person” liability, creating a direct legal pathway to hold Bao accountable as someone who exercised control over an entity alleged to have violated federal securities laws.
Bao has previously faced a fraud action involving the City of San Francisco and a separate lawsuit brought by Khosla Ventures alleging fraud and intentional interference in connection with a collapsed $30 million acquisition deal.
Where the Money Went
Both lawsuits allege proceeds were routed through a network of shell companies and personal accounts controlled by Jin, Schwarzer, and Xin Jin across multiple jurisdictions including Delaware, the British Virgin Islands, Panama, and Germany. The total alleged insider sell-off amounts to approximately $41.78 million.
The Qu complaint adds a detailed accounting of $16.6 million lost in unauthorized DeFi investments made with investor capital: $6.51 million in the Mochi Protocol, $3.27 million in a CVX/ETH liquidity pool, $780,000 in Maple Finance, and $345,000 in the Neutrino USDN protocol. All were allegedly made without investor consent or disclosure.
The IPO Disclosure Question
Lime’s S-1 filing contains extensive risk factor disclosures covering regulatory, operational, cybersecurity, labor, and financial risks. It does not appear to reference the two federal RICO lawsuits naming the company’s executive chairman as a defendant, the underlying fraud allegations tied to Cere Network, or the connections to Gotbit, whose founder has been convicted in a federal sting operation.
An IPO process involves extensive due diligence, SEC registration, and investor roadshows under heightened regulatory scrutiny. The presence of two federal RICO suits naming the executive chairman in an alleged Crypto fraud, with direct ties to a convicted market manipulation firm, represents the type of material legal exposure that underwriters and institutional investors typically evaluate during the offering process.
The SEC has increasingly focused on token offerings as potential unregistered securities, and the allegations in the Qu complaint fall squarely within the agency’s enforcement priorities. The DOJ’s existing familiarity with Gotbit through Operation Token Mirrors could also provide a pathway for criminal investigators to examine related token launches, including Cere Network’s.
What’s Next
In addition to Bao and Jin, the named defendants include Schwarzer, Xin Jin, Cere CMO Martijn Broersma, director François Granade, and corporate entities Cerebellum Network Inc., Interdata Network Ltd., and CEF AI Inc.
The Qu lawsuit is represented by Laith D. Mosely and Joshua C. Williams of Raines Feldman Littrell LLP. The Goopal lawsuit is represented by John K. Ly and Jennifer L. Chor of Liang Ly LLP.
The full federal complaint is available here.

