--- title: "Adjust GmbH: AppLovin’s measurement company" language: en canonical: https://dossiertwist.com/dossiers/applovin-corp/adjust/ as_of: 2026-10-16 keywords: ["AppLovin","Adam Foroughi","Herald Chen","KKR Denali","Voting Agreement","Angel Pride Holdings","Hontai App Fund","Orient Hontai","Hao Tang","Midterm Success","Adjust","Machine Zone","Tripledot","MoPub","Culper Research","Muddy Waters Research","Fuzzy Panda Research","securities class action","The Privacy Collective","Hart-Scott-Rodino Act"] --- # Adjust GmbH: AppLovin’s measurement company - Role: AppLovin subsidiary for mobile measurement and attribution - Also known as: adeven GmbH - Jurisdiction: Germany (DE) - Company register: HRB 140616 B (Amtsgericht Charlottenburg (Berlin), commercial register) **Question.** What is Adjust GmbH, who ran it, and which disputes concern it? **Answer.** Adjust GmbH, founded in Berlin in 2012 as adeven GmbH, measures and attributes mobile advertising campaigns. AppLovin bought it in April 2021; its 2020 accounts list twelve subsidiaries, including Unbotify, bought in 2019. Its founding managers Paul Müller and Christian Henschel left in 2021–2022. Adjust is a co-defendant in the Dutch privacy collective action and is named in a short seller's claims and in the Justice Department's HSR suit against KKR. ## Company and group - Analysis: Adjust GmbH was founded in 2012 and is registered in Berlin under HRB 140616 B, with its office at Saarbrücker Straße 37A; register publications show it was first registered as adeven GmbH. Its 2020 consolidated statements, audited by Deloitte GmbH and filed by AppLovin, list twelve wholly owned subsidiaries in the United States, Great Britain, Israel, Germany, Japan, China, Korea, France, Singapore and Brazil. On January 28, 2019 Adjust bought Unbotify Ltd. of Tel Aviv, a developer of bot-detection software, for EUR 16.9 million plus contingent consideration. adjust International Holding GmbH was registered in 2019 and is marked dissolved by aggregators. [src-025] [src-072] [src-088] [src-071] - Documented: Adjust GmbH, founded in 2012 and registered in Berlin under HRB 140616 B, has its registered office at Saarbrücker Straße 37A; register publications show it was first registered as adeven GmbH. Its purpose is developing and operating platforms for the verification, optimisation and targeted delivery of digital campaigns, especially on mobile devices. [src-025] [src-072] - Qualification: The former name and purpose come from a register aggregator; the founding year, seat and register number are stated in Adjust's audited 2020 statements filed with the SEC. - Documented: adjust International Holding GmbH was registered in Berlin on August 21, 2019 with share capital of EUR 25,000 and Christian Henschel and Paul Müller as managing directors; aggregators mark it as dissolved. [src-088] [src-071] - Qualification: Read in a business-directory or register-aggregator copy, not in the official register. ## Management - Analysis: The 2020 statements were signed by the management board, Paul Müller and Christian Henschel, and record the February 2021 agreement to sell Adjust to AppLovin. Register publications shown by aggregators record Müller as managing director until 2022 and Henschel until October 2021; Henschel also manages Spree Eternity GmbH, a party to the purchase agreement. An aggregator lists Andrey Kazakov and Egor Lukomsky as current managing directors and phm equity GmbH as a 6.3% holder in 2020. [src-072] [src-087] [src-088] [src-025] - Documented: Register publications shown by an aggregator list Christian Henschel as managing director of Spree Eternity GmbH (registered in 2012 as Spree Eternity UG), a party to the 2021 Adjust share purchase agreement, and as a former director of Adjust's British subsidiary Adjust Software Limited until May 2021. [src-088] - Qualification: Read in a business-directory or register-aggregator copy, not in the official register. The record does not explain Spree Eternity's role in the purchase. ## Disputes that name Adjust - Analysis: The Privacy Collective's Dutch collective action of May 2026 names Adjust as AppLovin's German group company and alleges that the two jointly process users' data unlawfully through their SDKs. Fuzzy Panda Research alleged, citing unnamed former executives, that after the purchase AppLovin whitelisted itself in Adjust's fraud detection and cut its anti-fraud team, and described a California class action over the Adjust SDK; AppLovin says Adjust and MAX operate independently. The Justice Department alleges that a KKR fund indirectly acquired Adjust through AppLovin's purchase without a prior HSR filing. [src-085] [src-068] [src-076] [src-077] - Attributed: The Privacy Collective (TPC) sues on behalf of Dutch residents who since May 25, 2018 have used Android or iOS apps containing AppLovin or Adjust software development kits, a group it puts at no fewer than 8.5 million people, including about 1.5 million minors. It alleges that processing their data through the SDKs and real-time bidding auctions lacks a legal basis, transparency and protection for children, in breach of the GDPR, including its information duties (Articles 12 to 14) and the ban on processing special categories of data such as health, religion and sexual orientation (Article 9), and of Article 11.7a of the Dutch Telecommunications Act. TPC describes Adjust as a German group company of AppLovin providing measurement and attribution services and alleges that the two jointly determine the purposes and means of the processing. It seeks a declaration of joint and several liability, orders stopping the SDK practices and deleting data, penalty payments of EUR 1,000,000 per violation plus EUR 250,000 a day capped at 4% of the defendants' worldwide annual turnover, and compensation for non-material and material damage; the press reported claims of EUR 1,500 per child and EUR 500 per adult, amounts not stated in the register extract. [src-085] [src-068] - Qualification: These are the claimant's allegations; Adjust's place in the group is separately documented in AppLovin's subsidiary lists. - Outcome: The case was due for its first docket date on August 26, 2026. No ruling on the merits is in the record as of mid-October 2026. - Attributed: Citing unnamed former Adjust executives, Fuzzy Panda Research alleged that after buying Adjust, AppLovin whitelisted itself in Adjust's fraud detection and fired a majority of Adjust's anti-fraud team. [src-076] - Qualification: Based on unnamed sources. No regulator or court has ruled on these allegations in the record. - Response: AppLovin said Adjust and MAX operations are "entirely independent and transparent, with no conflicts or house bias". - Attributed: Short seller Fuzzy Panda Research wrote in February 2025 that a class action filed in California in August 2024 (Santa Clara County Superior Court, No. 24CV434574), which AppLovin had not disclosed, accuses the company of using the Adjust SDK to collect a "wealth of information", including precise location, IP addresses and device identifiers, and to track users without their consent. [src-076] - Qualification: The complaint itself was not retrieved; AppLovin's filings in the record do not name this case, and its course is not known. - Attributed: Count 16 of the Justice Department's complaint, against the same defendants, alleges that on April 22, 2021 KKR Americas Fund XII L.P. indirectly acquired Adjust, through AppLovin's purchase, for between $376 million and $919 million without a prior premerger filing, again corrected on December 3, 2021. [src-077] - Qualification: These are allegations in a government complaint; the defendants consented to a proposed judgment without any admission or adjudication of fact or law, and AppLovin is not a defendant. - Response: According to the Justice Department, KKR told the FTC in December 2021 that the failures to file were inadvertent and arose from an unusual and unanticipated set of circumstances related to the timing of a complicated restructuring transaction, and made corrective filings for both transactions. - Outcome: A proposed final judgment filed on August 26, 2026 requires KKR & Co. GP LLC to pay a $250 million civil penalty within 30 days of its entry; the Federal Register notice of September 4, 2026 opened a 60-day comment period, so the judgment had not been entered in the record. ## Sources - [src-025] Corporate registry source · src-025 - [src-072] Adjust GmbH audited consolidated financial statements for 2020 (Exhibit 99.1), U.S. Securities and Exchange Commission (EDGAR), 2021 - [src-088] Corporate registry source · src-088 - [src-071] Corporate registry source · src-071 - [src-087] Corporate registry source · src-087 - [src-085] Extract for the Dutch central register of collective actions: Stichting The Privacy Collective v. AppLovin Corporation and Adjust GmbH, De Rechtspraak (Dutch judiciary), 2026-05-21 - [src-068] Media source · src-068 - [src-076] Research source · src-076 - [src-077] United States v. KKR & Co. Inc., et al.: proposed final judgment and competitive impact statement, Federal Register (U.S. Department of Justice notice), 2026-09-04