#!This case is about an unprecedented and seemingly coordinated media campaign, by no less than 20 major media outlets, to attack Trump Media & Technology Group (“TMTG”) and its social media platform, Truth Social, by falsely reporting that TMTG had lost $73million. !$#!This number was an utter fabrication. Each defendant, in apparent coordination, reported the exactsame false number within approximately 24 hours of one another, each citing to a public Securities and Exchange Commission (“SEC”) filing, in which the mystery $73 million loss appears nowhere.
FACTUAL BACKGROUND35.!TMTG is a start-up technology company that created and operates the social media platform Truth Social.%(#!Though relying onbridgefinancing to compete against dominant tech giants worth tens of billions of dollars, Truth Social developed its own infrastructure that now gives millions of Americans the opportunity to freely express their views on culture, politics, art, sports, entertainment, and any other topic.!%G#!In October 2021, TMTG and DWAC, a special purpose acquisition company, announced their intention to effect a merger, which would result in TMTG becoming a publicly traded company (thereby enabling retail investors who support TMTG’s mission to invest directly in the company).!%)#!Completing the merger is a crucial part of TMTG’s business plan, as repeatedly expressed in public statements by both TMTG and DWAC,and in DWAC’s public filings with the SEC.!39.!On November 13, 2023, DWAC submitted an amended registration statement on form S-4 to the SEC, a major milestone toward completing the planned merger. The S-4 is publicly available.40.!That same day, and continuing into the next, numerous media outlets, including the named Defendants, in apparent coordination, ran materially identical headlines and stories, each citing to the S-4 filing with the SEC, and falsely claiming that the S-4 showed that TMTG lost$73million.&"#!The $73 million figure appears nowhere in the S-4 or anywhere else. It was a complete fabrication—a fabrication made by these 20Defendants within a 24-hour period.