This case was last updated from U.S. District Courts on 08/29/2025 at 04:37:04 (UTC).

State Teachers Retirement System of Ohio et al v. ZoomInfo Technologies Inc et al

Case Summary

On 09/04/2024 State Teachers Retirement System of Ohio filed a Civil - Securities and Financial Instruments lawsuit against ZoomInfo Technologies Inc. This case was filed in U.S. District Courts, Washington Western District. The Judge overseeing this case is Tiffany M. Cartwright. The case status is Open.
Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    3:24-cv-05739

  • Filing Date:

    09/04/2024

  • Case Status:

    Open

  • Case Type:

    Civil - Securities and Financial Instruments

Complaint

TABLE OF CONTENTS
NATURE OF THE ACTION 1
JURISDICTION AND VENUE 1
PARTIES 2
BACKGROUND 4
DEFENDANTS’ MATERIALLY FALSE AND MISLEADING STATEMENTS AND
OMISSIONS ISSUED DURING THE CLASS PERIOD 9
CLASS ACTION ALLEGATIONS 43
ADDITIONAL SCIENTER ALLEGATIONS 44
LOSS CAUSATION 46
APPLICATION OF THE PRESUMPTION OF RELIANCE: FRAUD ON THE
MARKET 47
NO SAFE HARBOR 48
COUNT I 49
COUNT II 50
PRAYER FOR RELIEF 50
JURY DEMAND 51

COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS

- i -

KELLER ROHRBACK L.L.P. , Suite 3400 Seattle, WA - 3052 Telephone: 206/


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Plaintiff City of Pontiac Police and Fire Retirement System (“plaintiff”), on behalf of itself and all others similarly situated, by plaintiff’s undersigned attorneys, for plaintiff’s complaint against defendants, alleges the following based upon personal knowledge as to plaintiff and plaintiff’s own acts, and upon information and belief as to all other matters based on the investigation conducted by and through plaintiff’s attorneys, which included, among other things, a review of U.S. Securities and Exchange Commission (“SEC”) filings of ZoomInfo Technologies, Inc. (“ZoomInfo” or the “Company”), the Company’s press releases, analyst reports, media reports, and other publicly disclosed reports and information about the Company. Plaintiff believes that substantial additional evidentiary support will exist for the allegations set forth herein after a reasonable opportunity for discovery.

NATURE OF THE ACTION

This is a securities class action on behalf of all purchasers of ZoomInfo Class A common stock between November 10, 2020 , and August 5, 2024 , both dates inclusive (the “Class Period”), seeking to pursue remedies under the Securities Exchange Act of 1934 (the “ 1934 Act”) against ZoomInfo and certain of the Company’s senior executive officers and controlling shareholders.

JURISDICTION AND VENUE

The claims asserted herein arise under and pursuant to §§10(b) and 20(a) of the 1934 Act, 15 U.S.C. §§78j(b) and 78t(a), and Rule 10b-5 promulgated thereunder, 17 C.F.R. §240.10b-5. This Court has jurisdiction over the subject matter of this action pursuant to 28 U.S.C. § 1331 and §27 of the 1934 Act, 15 U.S.C. §78aa. Venue is proper in this District pursuant to 28 U.S.C. § 1391 (b), and §27 of the 1934 Act, because ZoomInfo is headquartered in this District and many of the acts and practices complained of herein occurred in substantial part in this District. In connection with the acts alleged in this complaint, defendants, directly or indirectly, used the means and instrumentalities of interstate commerce, including, but not limited

COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS

- 1 -

KELLER ROHRBACK L.L.P. , Suite 3400 Seattle, WA - 3052 Telephone: 206/

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Judge Details

Presiding Judge

Tiffany M. Cartwright

 

Party Details

Plaintiffs

Hampton Roads Shipping Association, International Longshoreman's Association

Francisco Javier Martin Escanciano

State Teachers Retirement System of Ohio

Ohio Public Employees Retirement System

Defendants

ZoomInfo Technologies Inc

Henry Schuck

Cameron Hyzer

TA Associates Management LP

The Carlyle Group Inc

DO Holdings (WA) LLC

12 More Parties Available

Attorney/Law Firm Details

Defendant Attorney

Molly McCafferty

Other Attorneys

Derek W Loeser

Brian E Cochran

Francisco J Mejia

Samuel H Rudman

Juli E. Farris

37 More Attorneys Available

 

Court Documents

#100

(#100) NOTICE of Change of Address/Change of Name of Attorney Molly McCafferty. Filed by Defendants DO Holdings (WA) LLC, Joseph Christopher Hays, Cameron Hyzer, Henry Schuck, ZoomInfo Technologies Inc. (McCafferty, Molly) (Entered: 08/25/2025)

#99

(#99) REPLY, filed by Defendants TA Associates Management LP, The Carlyle Group Inc, TO RESPONSE to #87 MOTION to Dismiss for Failure to State a Claim (Rugani, Paul) (Entered: 08/25/2025)

92 #14

Exhibit 14

92 #11

Exhibit 11

92 #6

Exhibit 6

92 #3

Exhibit 3

92 #2

Exhibit 2

87 #1

Proposed Order

#87

(#96) RESPONSE, by Plaintiffs Ohio Public Employees Retirement System, State Teachers Retirement System of Ohio, to #87 MOTION to Dismiss for Failure to State a Claim . Oral Argument Requested. (Selig, Joshua) (Entered: 07/25/2025)

#2

(#2) Summons(es) Electronically Issued as to defendant(s) DO Holdings (WA) LLC, Cameron Hyzer, Henry Schuck, TA Associates Management LP, The Carlyle Group Inc, ZoomInfo Technologies Inc. (MW) (Entered: 09/05/2024)

1 #7

Summons TA Associates Management LP

1 #6

Summons The Carlyle Group Inc

1 #5

Summons Henry Schuck

1 #4

Summons Cameron Hyzer

1 #3

Summons DO Holdings (WA) LLC

1 #2

Summons ZoomInfo Technologies Inc

1 #1

Civil Cover Sheet

#1

(#5) Notice of Filing Deficiency re #1 Complaint,,. ***Action Required*** Pro Hac Vice Admission.See attached letter for more information and instructions. cc via ad hoc Attorneys Rudman, Cochran and Mejia(CDA) (Entered: 09/09/2024)

138 More Documents Available
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Docket Entries

08/25/2025
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Docket(#100) NOTICE of Change of Address/Change of Name of Attorney Molly McCafferty. Filed by Defendants DO Holdings (WA) LLC, Joseph Christopher Hays, Cameron Hyzer, Henry Schuck, ZoomInfo Technologies Inc. (McCafferty, Molly) (Entered: 08/25/2025)

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08/25/2025
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Docket(#99) REPLY, filed by Defendants TA Associates Management LP, The Carlyle Group Inc, TO RESPONSE to #87 MOTION to Dismiss for Failure to State a Claim (Rugani, Paul) (Entered: 08/25/2025)

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08/25/2025
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Docket(#98) REPLY by Defendants DO Holdings (WA) LLC, Joseph Christopher Hays, Cameron Hyzer, Henry Schuck, ZoomInfo Technologies Inc to #92 Request,, (Kramer, James) (Entered: 08/25/2025)

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08/25/2025
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Docket(#97) REPLY, filed by Defendants DO Holdings (WA) LLC, Joseph Christopher Hays, Cameron Hyzer, Henry Schuck, ZoomInfo Technologies Inc, TO RESPONSE to #91 MOTION to Dismiss Corrected Amended Complaint (Kramer, James) (Entered: 08/25/2025)

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07/25/2025
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Docket(#96) RESPONSE, by Plaintiffs Ohio Public Employees Retirement System, State Teachers Retirement System of Ohio, to #87 MOTION to Dismiss for Failure to State a Claim . Oral Argument Requested. (Selig, Joshua) (Entered: 07/25/2025)

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07/25/2025
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Docket(#95) MEMORANDUM re #92 Request,, in Opposition to Request for Judicial Notice by Plaintiffs Ohio Public Employees Retirement System, State Teachers Retirement System of Ohio (Selig, Joshua) (Entered: 07/25/2025)

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07/25/2025
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Docket(#94) RESPONSE, by Plaintiffs Ohio Public Employees Retirement System, State Teachers Retirement System of Ohio, to #91 MOTION to Dismiss Corrected Amended Complaint. Oral Argument Requested. (Selig, Joshua) (Entered: 07/25/2025)

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05/27/2025
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Docket(#93) PROPOSED ORDER (Unsigned) to #92 REQUEST FOR JUDICIAL NOTICE by Defendants DO Holdings (WA) LLC, Joseph Christopher Hays, Cameron Hyzer, Henry Schuck, ZoomInfo Technologies Inc. in support of #91 MOTION to Dismiss Corrected Amended Complaint (Kramer, James) (Entered: 05/27/2025)

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05/27/2025
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Docket(#92) REQUEST FOR JUDICIAL NOTICE by Defendants DO Holdings (WA) LLC, Joseph Christopher Hays, Cameron Hyzer, Henry Schuck, ZoomInfo Technologies Inc re #91 MOTION to Dismiss Corrected Amended Complaint (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17, #18 Exhibit 18)(Kramer, James) (Entered: 05/27/2025)

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05/27/2025
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Docket(#91) MOTION to Dismiss Corrected Amended Complaint, filed by Defendants DO Holdings (WA) LLC, Joseph Christopher Hays, Cameron Hyzer, Henry Schuck, ZoomInfo Technologies Inc. Oral Argument Requested. (Attachments: #1 [Proposed] Order) Noting Date 8/25/2025, (Kramer, James) (Entered: 05/27/2025)

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09/13/2024
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Docket(#8) APPLICATION OF ATTORNEY Samuel H. Rudman FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff City of Pontiac Police and Fire Retirement System (Fee Paid) Receipt No. AWAWDC-8626718 (Farris, Juli) (Entered: 09/13/2024)

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09/10/2024
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Docket(#7) APPLICATION OF ATTORNEY Francisco J. Mejia FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff City of Pontiac Police and Fire Retirement System (Fee Paid) Receipt No. AWAWDC-8620580 (Farris, Juli) (Entered: 09/10/2024)

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09/10/2024
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Docket(#6) APPLICATION OF ATTORNEY Brian E. Cochran FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiff City of Pontiac Police and Fire Retirement System (Fee Paid) Receipt No. AWAWDC-8620563 (Farris, Juli) (Entered: 09/10/2024)

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09/09/2024
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Docket(#5) Notice of Filing Deficiency re #1 Complaint,,. ***Action Required*** Pro Hac Vice Admission.See attached letter for more information and instructions. cc via ad hoc Attorneys Rudman, Cochran and Mejia(CDA) (Entered: 09/09/2024)

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09/09/2024
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Docket(#4) CORPORATE DISCLOSURE STATEMENT indicating no Corporate Parents and/or Affiliates. Filed pursuant to Fed.R.Civ.P 7.1(a)(1). Filed by City of Pontiac Police and Fire Retirement System. (Farris, Juli) (Entered: 09/09/2024)

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09/05/2024
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Docket(#3) ORDER REGARDING INITIAL DISCLOSURES, JOINT STATUS REPORT, DISCOVERY, DEPOSITIONS AND EARLY SETTLEMENT by District Judge Tiffany M. Cartwright. FRCP 26(f) Conference Deadline is 11/20/2024, Initial Disclosure Deadline is 11/27/2024, Joint Status Report due by 12/4/2024. (MET) (Entered: 09/05/2024)

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09/05/2024
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Docket(#2) Summons(es) Electronically Issued as to defendant(s) DO Holdings (WA) LLC, Cameron Hyzer, Henry Schuck, TA Associates Management LP, The Carlyle Group Inc, ZoomInfo Technologies Inc. (MW) (Entered: 09/05/2024)

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09/05/2024

DocketDistrict Judge Tiffany M. Cartwright added. (MW) (Entered: 09/05/2024)

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09/05/2024
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DocketAttorney Juli E. Farris for City of Pontiac Police and Fire Retirement System added; per #1 Complaint. (MW) (Entered: 09/05/2024)

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09/04/2024
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Docket(#1) COMPLAINT against defendant(s) DO Holdings (WA), LLC, Cameron Hyzer, Henry Schuck, TA Associates Management LP, The Carlyle Group Inc., ZoomInfo Technologies Inc with JURY DEMAND (Receipt # AWAWDC-8613101) Attorney Derek W Loeser added to party City of Pontiac Police and Fire Retirement System(pty:pla) filed by City of Pontiac Police and Fire Retirement System. (Attachments: #1 Civil Cover Sheet, #2 Summons ZoomInfo Technologies Inc, #3 Summons DO Holdings (WA) LLC, #4 Summons Cameron Hyzer, #5 Summons Henry Schuck, #6 Summons The Carlyle Group Inc, #7 Summons TA Associates Management LP)(Loeser, Derek) (Entered: 09/04/2024)

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State Teachers Retirement System of Ohio et al v. ZoomInfo Technologies Inc et al
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