Randy 🇺🇾🧉歐陽

U.S. Securities and Exchange Commission Division of Enforcement and U.S. Commodity Futures Trading Commission Subject: Complaint Regarding Potential Misrepresentations by Ripple Labs, Inc. and Brad Garlinghouse Concerning the Role and Priority of XRP Dear Sir or Madam: I am writing to request that the SEC and CFTC review statements made by Ripple Labs, Inc. (“Ripple”) and its Chief Executive Officer, Brad Garlinghouse, concerning the centrality of the digital asset XRP to Ripple’s business and strategy. I and other investors purchased XRP in reliance on these statements, which portrayed XRP as Ripple’s essential “North Star” and the asset at the center of its activities. Subsequent public information about Ripple’s payment products, particularly the use of its RLUSD stablecoin, appears inconsistent with the level of priority those statements implied. Public statements by Mr. Garlinghouse have repeatedly described XRP in the following terms (or substantially similar language): • XRP is Ripple’s “North Star” and “reason for existence.” • “All roads lead back to Ripple’s North Star, XRP.” • XRP sits “at the center of everything Ripple does” and is the “heartbeat” of the company’s strategy. • Products and services (including payments, treasury, custody, and RLUSD) are focused on driving utility, liquidity, and success around XRP and the XRP Ledger. These remarks have been made in interviews, social media posts, and events including Ripple’s Swell conferences. I (and, based on discussions in investor communities, many others) interpreted them as indicating that XRP would be the primary or central asset used to facilitate Ripple’s payment and related activities, thereby supporting demand for and the value of XRP. However, Ripple has developed and promoted RLUSD, a U.S. dollar-pegged stablecoin, for use in dollar-to-dollar and other payment flows via its payment infrastructure (including RippleNet). Public descriptions indicate that RLUSD can settle certain transactions without requiring XRP as a bridge asset. While Ripple has stated that RLUSD is complementary to XRP and that the company will not pursue activities it views as harmful to the XRP ecosystem, the practical emphasis on RLUSD for a significant portion of dollar-denominated activity appears to reduce, rather than generate, the transaction demand for XRP that the earlier “North Star” and centrality statements led investors to expect. I purchased XRP on or about [insert dates] in the amount of approximately [insert quantity or dollar value], in part because of the statements referenced above. I believe these statements were material to my investment decision and to those of other retail investors. The apparent gap between the language used to describe XRP’s role and the observed use of RLUSD raises questions about whether investors were provided with an accurate picture of how Ripple’s products would create demand for XRP. I respectfully request that the Commission(s): 1. Review the full set of public statements by Ripple and Mr. Garlinghouse regarding XRP’s role and priority relative to RLUSD and other products. 2. Examine whether those statements, considered in light of actual product usage and payment flows, constituted material misrepresentations or omissions under the federal securities laws (or other applicable statutes within the CFTC’s jurisdiction). 3. Consider whether additional investigation or enforcement action is warranted to protect investors who relied on the statements. 4. Provide any guidance or findings that may assist investors in evaluating the accuracy of similar future statements. I am prepared to provide additional information, including screenshots or links to the relevant statements, my transaction records, and any other evidence upon request. I understand that the resolution of the prior SEC action against Ripple addressed certain issues concerning the status of XRP sales, but I believe the specific concern raised here regarding the