---
title: "Evidence records"
language: en
canonical: https://dossiertwist.com/dossiers/applovin-corp/evidence-records/
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"]
---

# Evidence records

**Question.** Which records support the articles?

**Answer.** Full assertions with source references, qualifications, responses and known outcomes. The topic articles explain these records in context.

## AppLovin Corp: control, investors, deals and disputes

- Documented: AppLovin Corporation is a Delaware corporation with its principal executive offices at 1100 Page Mill Road, Palo Alto, California. Its SEC Central Index Key is 0001751008, its U.S. employer identification number is 45-3264542 and its SEC commission file number is 001-40325; the SEC's registrant record classifies it as a large accelerated filer with a December 31 fiscal year end. [src-002] [src-024]
- Documented: The header of an SEC filing records a change of AppLovin's conformed name on August 23, 2018 from "Applovin Corp" to "AppLovin Corp", a change of capitalisation only; the SEC's registrant record lists no other former names. [src-094]
- Documented: AppLovin's Class A common stock has traded on the Nasdaq Global Select Market under the symbol APP since its initial public offering on April 15, 2021, which was priced at $80.00 per share; the Class B and Class C shares are neither listed nor traded. [src-002]

## Who controls AppLovin: share classes and major holders

- Documented: AppLovin has three classes of common stock: Class A carries one vote per share, Class B carries 20 votes per share and Class C, of which none is outstanding, has no voting rights except where the law requires them. [src-001]
- Documented: AppLovin's 2026 proxy statement calculates ownership on 306,086,916 Class A shares, 30,207,521 Class B shares and no Class C shares outstanding on March 31, 2026. [src-001]
- Documented: Adam Foroughi and Herald Chen, with affiliated trusts and entities, are parties to a Voting Agreement under which all AppLovin shares they hold are voted as Foroughi and Chen determine. The 2026 proxy statement attributes to the shares under the agreement (all Class B shares on its beneficial-ownership basis and 2,866,505 Class A shares) 66.9% of the voting power as of March 31, 2026, enough to decide director elections, charter amendments and major transactions. [src-001]
- Documented: Because the Voting Agreement parties, Adam Foroughi and Herald Chen, hold a majority of the voting power, AppLovin is a "controlled company" under Nasdaq corporate governance rules. It says, however, that it does not rely on the exemptions available to controlled companies and keeps the corresponding governance practices. [src-001]
- Documented: At December 31, 2025 AppLovin had about 32 holders of record of Class A shares and 8 of Class B shares; all Class B shares were beneficially held by Adam Foroughi and Herald Chen together with certain affiliated trusts. [src-002]
- Documented: As of March 31, 2026 Adam Foroughi beneficially owned 2,420,296 Class A shares and 27,936,907 Class B shares, 92.5% of the Class B class and 61.6% of AppLovin's total voting power. [src-001]
- Documented: As of March 31, 2026 Herald Chen beneficially owned 446,209 AppLovin Class A shares and 697,668 Class B shares (2.3% of Class B, 1.6% of the voting power), partly through family trusts of which he and his spouse are trustees. In the 2025 proxy the same holding was 2,397,668 Class B shares (7.4% of the class, 5.1% of the votes), including 1,680,201 shares obtainable on exercise of options. [src-001] [src-041]
- Documented: Form 4 filings show continued changes in the two controlling holders' AppLovin stakes in 2026: Herald Chen converted 143,791 Class B shares into Class A shares and gave away 100,000 Class A shares on August 13, 2026, leaving 223,676 Class B shares; Adam Foroughi held 2,324,954 Class A shares directly on August 20, 2026, with further Class A shares held indirectly through three holdings. [src-027] [src-028]
- Documented: At AppLovin's IPO in April 2021 the Class B shares were held by Adam Foroughi, Herald Chen and KKR Denali Holdings L.P. (with affiliates), who together had 93.4% of the voting power. Their Voting Agreement then provided that all Class B shares would be voted as determined by two of Foroughi, Chen and KKR Denali, one of whom had to be Foroughi. [src-006]
- Documented: As of March 31, 2022 Adam Foroughi held 27,936,907 AppLovin Class B shares (35.5% of the class, 29.9% of the votes) and Herald Chen 4,646,459 Class B shares (4.8% of the votes). Other holders above 5% were KKR Denali Holdings L.P. (60,735,000 Class A and 38,905,489 Class B shares, 44.8% of the votes), Hontai App Fund Limited Partnership (8.8% of Class A), co-founders John Krystynak (7.8%) and Andrew Karam (7.1%) and The Vanguard Group (5.2%); the shares under the Voting Agreement carried 87.7% of the votes. Angel Pride Holdings Limited is not among the holders above 5% in that table. [src-056]
- Documented: As of March 31, 2023 KKR Denali Holdings L.P. held 60,735,000 AppLovin Class A and 38,905,489 Class B shares (48.7% of the votes) and Adam Foroughi 27,936,907 Class B shares (32.4%); the Voting Agreement shares carried 86.5%. Other holders above 5% of Class A were Hontai App Fund Limited Partnership (8.7%), John Krystynak (7.0%), Andrew Karam (6.7%) and The Vanguard Group (5.3%); Angel Pride Holdings Limited is again not listed. [src-010]
- Documented: In a Schedule 13G amendment for September 30, 2024, Adam Foroughi reported holding 3,885,217 AppLovin Class A shares (including 1,477,929 restricted stock units) and 27,936,907 Class B shares; with the other Voting Agreement parties, Herald Chen and KKR Denali, the group beneficially owned 43,307,451 shares, 12.8% of Class A on an as-converted basis, with voting decided by two of the three parties including Foroughi. [src-039]
- Documented: As of March 31, 2025 Adam Foroughi held 2,835,590 AppLovin Class A and 27,936,907 Class B shares (60.9% of the votes) and Herald Chen 2,397,668 Class B shares (5.1%); the Voting Agreement shares carried 68.2%. Holders above 5% of Class A were Angel Pride Holdings Limited (17,244,541 shares, 5.6%), BlackRock, Inc. (5.4%) and The Vanguard Group (5.4%); Midterm Success Limited and Hao Tang are not listed. [src-041]
- Documented: AppLovin's 2026 proxy statement lists, based on Schedule 13G filings, The Vanguard Group with 24,954,427 Class A shares (8.2%, filing of October 30, 2025), BlackRock, Inc. with 21,386,458 (7.0%, filing of October 17, 2025) and Angel Pride Holdings Limited with 17,244,541 (5.6%) as holders above 5%. [src-001]
- Documented: AppLovin's IPO prospectus also lists Nimble Ventures (11,480,000 Class A shares, 6.2%) and Eduardo Vivas (10,865,818 shares, 5.9%) among the holders above 5% before the offering. [src-006]
- Documented: Other insider holdings of AppLovin shares as of March 31, 2026 include Eduardo Vivas with 6,963,289 Class A shares (2.3%) and Vasily Shikin with 3,805,555 (1.2%, including options); 154,500 shares counted for Margaret Georgiadis are held by Blue Sage Partners, LLC and 147,516 counted for Maynard Webb by Webb Investment Network LLC, in each case with voting and dispositive power shared with a spouse. [src-001]
- Documented: On May 12, 2025 AppLovin director Eduardo Vivas entered into a prepaid variable forward sale contract with an unaffiliated counterparty and received $131,099,760 in cash; he pledged 550,000 Class A shares and must deliver up to that number of shares, or their cash value, at settlement in May 2027, with a floor price of $261.94 and a cap of $605.08. He keeps beneficial ownership of the pledged shares. [src-094] [src-030] [src-001]

## AppLovin's business, results and capital

- Documented: In its annual report for 2025 AppLovin describes its advertising business through four products: Axon Ads Manager, its user-acquisition solution powered by the Axon AI recommendation engine; MAX, its in-app bidding solution for publishers' monetisation; Adjust, its measurement and analytics platform; and Wurl, its connected-TV platform. [src-002]
- Documented: AppLovin's annual report for 2025 shows revenue from continuing operations of $5,480.7 million in 2025, $3,224.1 million in 2024 and $1,841.8 million in 2023, and net income from continuing operations of $3,433.2 million, $1,589.5 million and $457.8 million in the same years. [src-002]
- Documented: In the letter opening its 2026 proxy statement AppLovin describes 2025 as a year with $5.5 billion of revenue (up 70%), $4.5 billion of Adjusted EBITDA and $4.0 billion of free cash flow, $2.2 billion of Class A share repurchases and the sale of its Apps business; Adjusted EBITDA and free cash flow are the company's own non-GAAP measures. [src-001]
- Documented: Before the sale of the Apps business, AppLovin's annual report for 2022 showed revenue of $2,817.1 million in 2022, $2,793.1 million in 2021 and $1,451.1 million in 2020, with a net loss of $192.9 million in 2022, net income of $35.3 million in 2021 and a net loss of $125.9 million in 2020. [src-034]
- Documented: At December 31, 2025 AppLovin's debt consisted of $3,550.0 million principal of unsecured senior notes issued in December 2024 (5.125% notes due 2029, 5.375% notes due 2031 and 5.500% notes due 2034 of $1.0 billion each, and $550.0 million of 5.950% notes due 2054), carried at $3,513.0 million and not guaranteed by any subsidiary. The notes and an unsecured $1.0 billion revolving credit facility maturing in December 2029 replaced the secured 2018 Credit Agreement; $200.0 million drawn under the revolver in March 2025 for share repurchases was repaid, and nothing was outstanding at year end. [src-002]
- Documented: AppLovin's stockholders' equity was $2,134.7 million at December 31, 2025 (2024: $1,089.8 million). Under the repurchase programme approved in February 2022 the company repurchased and retired 5.5 million Class A shares for $2.2 billion in 2025, the board added $3.2 billion to the authorisation, and $3.3 billion remained available at year end. [src-002]
- Documented: Deloitte & Touche LLP is AppLovin's independent registered public accounting firm: it audited internal control over financial reporting for 2022 and was proposed for ratification for the 2026 financial year. [src-001] [src-034]

## KKR's investment in AppLovin, 2018–2024

- Documented: In August 2018 AppLovin sold 109,090,908 shares of Series A convertible preferred stock to KKR Denali Holdings L.P. for $399,999,996. Herald Chen, later AppLovin's President and Chief Financial Officer, was affiliated with KKR at the time of the transaction and is a limited partner in KKR Denali and other KKR entities. [src-006]
- Documented: Herald Chen signed AppLovin's Investors' Rights Agreement of August 15, 2018 on behalf of KKR Denali Holdings, L.P. as President of its general partner, KKR Denali Holdings GP LLC. [src-052]
- Documented: Before AppLovin's IPO, KKR Denali Holdings L.P. directly owned 110,550,489 Class B shares, 73.6% of that class and 69.3% of the voting power. The prospectus lists the KKR entities that may be deemed to share beneficial ownership, starting with KKR Denali Holdings GP LLC as general partner and KKR Americas Fund XII L.P. as its managing member and ending with KKR & Co. Inc., KKR Management LLP and its founding partners Henry R. Kravis and George R. Roberts. [src-006]
- Documented: KKR Denali was represented on AppLovin's board throughout its investment. Under the voting agreement of November 12, 2019, Edward Oberwager and Cathy Sun were elected as designees of the Series A preferred holders. After the IPO a Director Nominations Agreement let KKR Denali nominate one director while it kept at least 25% of its pre-IPO Class B shares (Oberwager was its designee in 2023) and approve one independent nominee while it held at least 5% of the shares; the 2023 proxy names Margo Georgiadis as the independent director so approved. In 2024 KKR Denali fell below both thresholds and the agreement terminated. [src-006] [src-010] [src-041]
- Documented: KKR Capital Markets LLC, a KKR affiliate, was joint lead arranger and joint bookrunner for AppLovin's 2018 Credit Agreement and was paid $1.5 million in 2020, $2.3 million in 2021, nothing in 2022, $1.2 million in 2023 and $0.1 million in 2024 in connection with it. A KKR Denali affiliate was among the lenders of $150.0 million and $250.0 million borrowed under the revolving facility in November 2020 and March 2021, repaid from the IPO proceeds in April 2021, and KKR Corporate Lending (CA) LLC provided $15.0 million of revolving commitments. The 2018 Credit Agreement was terminated in December 2024. [src-002] [src-034]
- Documented: KKR Capital Markets LLC also acted as an underwriter of AppLovin's April 2021 IPO, receiving about $5.9 million in underwriting discounts and commissions, and was paid $5.0 million in March 2022 as independent financial adviser on the December 2021 secondary offering of Class A shares. [src-010] [src-056]
- Documented: KKR Denali sold its AppLovin stake between 2023 and 2024. AppLovin repurchased 15,952,381 Class A shares from it in May 2023 at $21 a share ($335.0 million) and 15,000,000 in August 2023 at $36.85 ($552.8 million). In a February 2024 secondary offering KKR Denali sold 19,866,397 shares through underwriters represented by BofA Securities, Inc., and on March 6, 2024 AppLovin bought back 10,466,397 of them at the offering price of $54.46. By September 30, 2024 KKR Denali's beneficial holding was 5,342,283 shares (about 1.8% of Class A); during 2024 it converted its remaining Class B shares, sold all its shares and ceased to be a related party by December 31, 2024. [src-002] [src-070]
- Documented: The Justice Department's complaint describes KKR & Co. Inc. as owning and controlling KKR & Co. GP LLC, which is the sole general partner of Kohlberg Kravis Roberts & Co. L.P., the parent of KKR's global asset-management business. [src-077]

## Orient Hontai, Applovin Holdings and the Hontai App Fund

- Documented: AppLovin's Investors' Rights Agreement of August 15, 2018 lists two investors, KKR Denali Holdings, L.P. and Applovin Holdings LLC (with an address in Beijing). The agreement defines "Hontai" as Applovin Holdings LLC and "Hontai GP" as Orient Hontai Capital Investment (Chengdu) Co., Ltd., a PRC corporation, and its stockholders, and lets Hontai count up to five limited partners or affiliates of Hontai GP as its affiliates; Hontai remained a "Major Investor" while holding at least 8,698,137 registrable shares. [src-052]
- Documented: Yuntao Ma signed the 2018 Investors' Rights Agreement as director of Applovin Holdings LLC, and the same name appears as authorised signatory of Hontai App Fund Limited Partnership, Hontai Capital Cayman Inc. and Yunjoy Capital Cayman Inc. in their 2024 Schedule 13G amendment. [src-052] [src-017]
- Documented: On January 3, 2019 AppLovin and Applovin Holdings LLC entered into a Warrant Transfer Agreement under which a common-stock warrant issued in connection with earlier debt financing was transferred to Angel Pride Holdings Limited (26,021,583 Class A shares) and Hontai App Fund Limited Partnership (8,794,734 shares); the two holders then exercised it, paying $868 and $293 respectively. [src-006]
- Documented: Hontai App Fund Limited Partnership held 26,167,242 AppLovin Class A shares before the IPO (14.1% of the class). Its general partner is Hontai Capital Cayman Inc., whose controlling stockholder is Yunjoy Capital Cayman Inc.; all three, with an address in Grand Cayman, may be deemed to share voting or dispositive power over the shares, and they reported the same holding on Schedule 13G in February 2022. [src-006] [src-010]
- Documented: Hontai App Fund's 2024 Schedule 13G amendment reports that by December 31, 2023 the fund had distributed all of its AppLovin Class A shares to its limited partners, so that neither the fund, its general partner nor Yunjoy any longer owned AppLovin stock. The filing does not name the limited partners that received the shares. [src-017]
- Attributed: Culper Research asserted that Hontai App Fund's 2023 distribution went mainly to Midterm Success Limited, a company of Hao Tang: it noted that Midterm's first Schedule 13G, filed eight days after a Hontai filing reporting the distribution, showed 23,167,242 shares. [src-005] [src-010] [src-079]
  - Qualification: Culper Research published this while holding a short position in AppLovin; the account is its own and was not adopted by AppLovin or any authority in the record. The filings in the record show Hontai App Fund last holding 26,167,242 shares, exactly 3,000,000 more than Midterm Success's first reported holding, but no retained filing states where Midterm Success's shares came from.
- Attributed: Culper Research also asserted, citing Hong Kong company records that are not in the record, that Hao Tang and Orient Hontai's chief executive Yuntao Ma were co-directors of a Hong Kong company, Kunshan Technology Investment (HK) Limited, and that AppLovin had issued convertible notes in September 2017 to Applovin Holdings LLC and to a "Kuntai" company before the warrant was transferred. [src-079]
  - Qualification: Culper Research published this while holding a short position in AppLovin; the account is its own and was not adopted by AppLovin or any authority in the record. The registry records and note terms it cites are not retained; Yuntao Ma's role as signatory for the Hontai entities is documented, his role at Orient Hontai is not.
- Attributed: A May 2026 article in a crypto-news section of a financial website called Hao Tang the architect of the 2016 Orient Hontai deal, said CFIUS had stopped it the following year because of Hontai's relationship with a state-connected financial institution without any finding against AppLovin or Tang, and described Hontai App Fund as connected to Tang and Angel Pride as controlled by his sister. [src-114]
  - Qualification: A single unsigned article whose form suggests sponsored content; no filing in the record links Hao Tang to Orient Hontai or Hontai App Fund, or records a family relationship.

## Angel Pride Holdings and its AppLovin stake

- Documented: Angel Pride Holdings Limited held 26,021,583 AppLovin Class A shares before the April 2021 IPO, 14.0% of the class. The prospectus names Tang Ling as Angel Pride's shareholder and sole director, and Angel Pride's amended Form 3 states that Ms. Tang holds voting and investment discretion over its shares and may be deemed their beneficial owner, while disclaiming beneficial ownership beyond any pecuniary interest. The SEC's insider register lists Angel Pride as a 10% owner from April 14, 2021. [src-006] [src-012] [src-029]
- Documented: In a Schedule 13G amendment filed in February 2024, Angel Pride and Ling Tang reported 20,493,747 AppLovin Class A shares as of December 31, 2023 (7.7% of the class), held of record by Angel Pride, of which Ling Tang was the shareholder and sole director with voting and investment discretion. [src-018]
- Documented: Angel Pride's Schedule 13G amendment signed in October 2024 reports that, from an event date of September 17, 2024, its sole shareholder was Prominence Trust Limited of Hong Kong; Angel Pride and Prominence Trust reported shared voting and dispositive power over 20,493,747 Class A shares (6.9%) and moved from the filing rule used for exempt holders to the one used by passive investors. A separate amendment by Ling Tang dated October 21, 2024 reports that she no longer beneficially owned any AppLovin shares. [src-023] [src-015]
- Documented: Angel Pride and Prominence Trust's Schedule 13G amendment of January 30, 2025 reports 17,244,541 Class A shares as of December 31, 2024 (5.8%). AppLovin's 2025 and 2026 proxy statements rely on this filing, list Angel Pride at 5.6% and describe Prominence Trust as Angel Pride's sole shareholder that may be deemed to share beneficial ownership; Angel Pride's principal business address is the Vistra Corporate Services Centre in Road Town, Tortola, and Prominence Trust's is 18/F, Three Exchange Square, Central, Hong Kong. [src-003] [src-001]
- Documented: The Schedule 13G amendments of October 2024 and January 2025 for both Angel Pride and Prominence Trust were signed by one authorised signatory, CHENG Hong Wai. An SEC full-text search finds his name only in these Angel Pride filings concerning AppLovin. None of the filings names the beneficiaries behind Prominence Trust. [src-003] [src-054]
- Documented: The Hong Kong Intellectual Property Department's journal of November 19, 2021 accepted for registration two applications filed on October 19, 2021 by AP Investment Capital Company Limited, one for the mark "Angel Pride Holdings Limited" and one for a series of "Angel Pride" marks, both in classes 35 and 36. The applicant's address is 18/F, Three Exchange Square, 8 Connaught Place, Central. [src-093]
- Documented: Ling Tang's 2024 Schedule 13G amendment gives a Hong Kong address in Global Gateway Tower, 61-63 Wing Hong Street, Lai Chi Kok, and Hao Tang's 2023 Schedule 13G gives a business address at 26 Wing Hong Street in the same district. [src-015] [src-005]
  - Qualification: A shared office or agent address does not by itself show common ownership, control or coordination.
- Attributed: Culper Research asserted, citing BVI register filings, that JPMorgan registered a charge against Angel Pride in January 2022 for a margin loan secured on securities in an account at JPMorgan, added charges in August 2024 covering margin-loan, ISDA and account-control agreements, that Angel Pride's amended memorandum shows the margin loan guaranteed by "Mr. Tang Hao", and that HSBC registered a charge against Midterm Success Limited in April 2024 for a banking facility including margin trading; it said the charges were still open in May 2025 and had not been disclosed to AppLovin investors. [src-079]
  - Qualification: Culper Research published this while holding a short position in AppLovin; the account is its own and was not adopted by AppLovin or any authority in the record. The guarantee document and the January 2022 and April 2024 charges are not reproduced in legible form in the record.
- Attributed: Short seller CapitalWatch, in a January 2026 report summarised by a Chinese online encyclopedia, and a May 2026 crypto-news article describe Ling Tang as Hao Tang's sister; the encyclopedia entry also repeats CapitalWatch's account, citing a French court record, that Hao Tang moved money to accounts of a company controlled by his sister. [src-104] [src-114]
  - Qualification: No filing or register in the record states a family relationship between Ling Tang and Hao Tang. CapitalWatch's report itself was not retrieved, and in February 2026 CapitalWatch withdrew other statements about Tang, including its association of a French court ruling with him.
- Documented: The 2023 Schedule 13G gives Midterm Success's address at Sea Meadow House in Road Town, Tortola, and Asian Creative Capital's as care of the Vistra Corporate Services Centre in Road Town, the same registered-agent address that Angel Pride Holdings and Discovery Key Investments use. [src-005] [src-001] [src-011]
  - Qualification: The Vistra centre is a corporate services provider's address used by many British Virgin Islands companies; sharing it does not connect the companies to each other.

## Hao Tang: AppLovin holdings, companies and allegations

- Documented: In a Schedule 13G dated October 6, 2023, Hao Tang reported beneficial ownership of 23,167,242 AppLovin Class A shares (8.4% of the class) as of September 26, 2023. The shares were held of record by Midterm Success Limited, a British Virgin Islands company wholly owned by Asian Creative Capital Limited, itself wholly owned by Hao Tang; Tang signed as director of Asian Creative Capital and Xuanhui Liu as director of Midterm Success. [src-005]
- Documented: In a Schedule 13G amendment of January 30, 2025, Hao Tang reported 11,969,535 Class A shares (4.0%) as of December 31, 2024: 9,969,535 held by Midterm Success Limited and 2,000,000 by Discovery Key Investments Limited, another British Virgin Islands company of which he is the sole shareholder. Kevin Shum signed for Midterm Success, Asian Creative Capital and Discovery Key as authorised signatory. AppLovin's 2025 and 2026 proxy statements do not list Tang or his companies among holders above 5%. [src-011]
- Attributed: A March 2026 press report described Tang Hao as holding a roughly 3.2% stake in AppLovin worth about $4.6 billion, citing a 2025 filing. [src-086] [src-011]
  - Qualification: No filing in the record shows 3.2%; the latest Schedule 13G amendment in the record (January 2025) reports 4.0% as of December 31, 2024, and the record contains no later holder filing.
- Documented: A Schedule 13D amendment on The Stars Group Inc. filed in March 2020 names Tang Hao as director of Uptrend Trade Limited and Discovery Key Investments Limited, gives their contact address as 18/F Three Exchange Square in Central, Hong Kong, and shows that Discovery Key bought Stars Group shares on the market in July to September 2017; by the filing date the two companies held none and Tang Hao held 119,700 shares (0.08%). [src-089]
- Documented: In the same March 2020 filing Tang Hao and his two companies, Uptrend Trade and Discovery Key, stated that during the previous five years they had not been convicted in a criminal proceeding or been subject to a civil judgment finding a violation of securities laws. [src-089]
- Refuted: Some secondary accounts linked Hao Tang to the Tuandai online-lending fraud case and to a 2021 arrest and court ruling in Bordeaux. [src-066] [src-079] [src-082]
  - Qualification: Refuted in the record: a 2025 press investigation and Culper Research's own report attribute the Tuandai-related red notice and the Bordeaux arrest to a different businessman, and in February 2026 short seller CapitalWatch withdrew its association of the Bordeaux ruling with Tang.
- Attributed: A March 2026 press report, citing people familiar with the matter, said JPMorgan Chase had ended its private-banking relationship with Tang Hao months earlier because of know-your-customer concerns, although he had been a significant revenue contributor to its China private-banking unit. [src-086]
  - Qualification: Based on unnamed sources; no bank or regulatory document in the record confirms the account.
  - Response: According to the report, the bank declined to confirm any client relationship and representatives of Tang and of AppLovin declined to comment.

## Related-party dealings at AppLovin

- Documented: Under a repurchase agreement dated March 7, 2024, AppLovin bought back 3,000,000 Class A shares from Midterm Success Limited, then a holder of more than 5%, in a private transaction at $60.74 per share, about $182 million in total; AppLovin's 2025 proxy statement reports it as a related-party transaction. [src-041]
- Documented: AppLovin's 2026 proxy statement states that since January 1, 2025 it has entered into no transactions above $120,000 with related persons other than those it describes: the Investor Rights Agreement with Adam Foroughi, the Equity Exchange Right Agreement with Herald Chen and the employment of Rafael Vivas. [src-001]
  - Qualification: This is the company's own statement; the 2025 annual report separately treats Tripledot and Humans, Inc. as related parties during 2025.
- Documented: Under an Investor Rights Agreement, Adam Foroughi and an entity affiliated with him may require AppLovin to register their shares for sale or to include them in a registration statement the company is filing. [src-001]
- Documented: Under an Equity Exchange Right Agreement made at the IPO, Herald Chen may require AppLovin to exchange Class A shares he receives on exercising pre-IPO options for the same number of Class B shares; the agreement covered options over 2,280,201 shares, of which 330,201 were still unexercised on March 31, 2026. [src-001]
- Documented: Rafael Vivas, the brother of director Eduardo Vivas, is an AppLovin employee; in 2025 he received a salary of $400,000 and restricted stock units over 4,856 Class A shares, and his salary is unchanged for 2026. In March 2019 AppLovin lent him $2.3 million under a promissory note at 2.59% (cut to 0.41% in August 2020) so that he could exercise stock options early; the note of $2,273,400 was still outstanding in April 2023 and was repaid in full with interest in March 2024. [src-001] [src-002] [src-010]
- Documented: When AppLovin launched its mobile game publishing division Lion Studios in July 2018, the trade press reported that it would be headed by president Rafael Vivas; Lion Studios, LLC is listed among AppLovin's subsidiaries in its 2022 annual report. [src-100] [src-099]
  - Qualification: Rafael Vivas's Lion Studios role is reported by the trade press and a business directory, not by AppLovin's filings.
- Documented: Before the IPO AppLovin lent money to executive officers so that they could exercise stock options early: Herald Chen $12,120,000 (November 2019), Katie Jansen three notes of $503,000, $673,600 and $1,464,000 (2019-2020), Basil Shikin $505,200 and $503,000 (March 2019) and Victoria Valenzuela $4,863,343 (July 2020). The interest rates were reduced to the IRS mid-term rate of 0.41% in August 2020, and all four repaid their notes in February 2021. [src-006]
- Documented: In December 2019 AppLovin repurchased 2,475,000 Class A shares from Adam Foroughi and 300,000 from Eduardo Vivas, shares with a fair value of $14.0 million, paying with unsecured five-year 2% promissory notes of $10.0 million and $1.2 million. It repaid both notes in December 2021 for $11.7 million in total; the 2023 proxy puts the amounts paid at about $10.4 million to Foroughi and $1.3 million to Vivas. [src-034] [src-010]
- Documented: In February 2021 AppLovin repurchased 153,541 shares from Herald Chen for $12.3 million and 60,968 shares from Victoria Valenzuela for $4.9 million. [src-056]
- Documented: Cookie Monster Capital, LLC, a mobile game developer owned by director Eduardo Vivas, had a game assignment and revenue-share agreement with AppLovin from October 2020 under which AppLovin published one of its games; AppLovin paid it $0.7 million in 2021 and $0.2 million in 2022, and amounts for 2020 were not material. [src-010] [src-034]
- Documented: On February 14, 2024 AppLovin agreed to invest $50 million in the Series C preferred financing of Humans, Inc., the developer of the Flip Shop shopping app, giving it about 4.1% of Flip Shop's fully diluted shares, and Flip Shop signed a commercial agreement to use AppLovin's AXON technology. On March 27, 2024 Flip Shop merged with Curated, Inc., the company Eduardo Vivas had founded and run; Vivas became Flip Shop's chief operating officer, a board member and a holder of more than 5%. [src-041]
- Documented: AppLovin treated Humans, Inc. as a related party until Eduardo Vivas resigned as its chief operating officer and director in September 2025. No transactions took place under the revenue-share commercial agreement, and in 2025 AppLovin wrote off its entire $50.0 million investment because of Humans' deteriorating finances and doubts about its ability to continue as a going concern. [src-002]
- Documented: Through the directed share programme of AppLovin's IPO, director Margaret Georgiadis bought 3,600 shares and the spouse of director Craig Billings bought 202 shares. [src-056]
- Documented: Since the closing AppLovin accounts for its Tripledot stake by the equity method and treats Tripledot and its subsidiaries as related parties; from the closing to December 31, 2025 it recognised $19.0 million of revenue from their use of its advertising products, and it provided transitional services for up to six months. [src-002]

## AppLovin's board and executive officers

- Documented: At AppLovin's annual meeting on June 3, 2026 stockholders elected nine directors to serve until 2027: Adam Foroughi, Craig Billings, Herald Chen, Margaret Georgiadis, Barbara Messing, Todd Morgenfeld, Victoria Valenzuela, Eduardo Vivas and Maynard Webb. Valenzuela joined the board for the first time; Alyssa Harvey Dawson, who did not stand for re-election, left at the meeting. [src-097] [src-001]
- Documented: AppLovin's 2026 proxy statement names four executive officers: Adam Foroughi (chief executive officer and co-founder), Matthew Stumpf (chief financial officer), Vasily Shikin (chief technology officer) and Victoria Valenzuela (chief administrative and legal officer and corporate secretary). [src-001]
- Documented: On April 2, 2026 the board appointed Craig Billings, lead independent director since the IPO, as independent chairperson in place of Adam Foroughi, who remained chief executive and a director. AppLovin also announced that Vasily Shikin would step down as chief technology officer on July 1, 2026 to become a non-executive Distinguished Engineer, succeeded by chief product and engineering officer Giovanni Ge, and that Victoria Valenzuela would retire on August 1, 2026, succeeded as chief legal officer by deputy general counsel Corina Cacovean; Valenzuela would stand for the board and serve as a consultant until May 31, 2027 for $150,000. [src-009] [src-001]
- Documented: At the time of AppLovin's April 2021 IPO the executive officers were Adam Foroughi (chief executive and chairperson), Herald Chen (president, chief financial officer and director), Katie Jansen (chief marketing officer), Vasily (Basil) Shikin (chief technology officer) and Victoria Valenzuela (chief legal officer), and the non-employee directors were Craig Billings, Margaret Georgiadis, Edward Oberwager, Cathy Sun and Eduardo Vivas. The SEC's insider register also lists Elena Arutunian as chief accounting officer from April 14, 2021. [src-006] [src-029]
- Documented: AppLovin's board membership changed between the IPO and 2025: in April 2022 the eight nominees were Foroughi, Chen, Billings, Georgiadis, Alyssa Harvey Dawson, Edward Oberwager, Asha Sharma and Vivas; in June 2024 stockholders elected Foroughi, Billings, Chen, Georgiadis, Harvey Dawson, Barbara Messing, Todd Morgenfeld, Oberwager and Vivas. [src-056] [src-058]
- Documented: AppLovin's 2023 proxy statement reports that in 2022 one Form 4 was filed late for each of Adam Foroughi (five transactions), Andrew Karam (three) and Eduardo Vivas (one). [src-010]
- Documented: Adam Foroughi co-founded AppLovin and has been its chief executive officer and a director since December 2011; he chaired the board from March 2021 to April 2026. He previously co-founded two advertising technology companies, Lifestreet Media Inc. and Social Hour Inc. The SEC's insider register lists no other U.S. public company for him. [src-001] [src-028]
- Documented: Herald Chen has been an AppLovin director since August 2018 and was its president and chief financial officer from November 2019 to December 2023. Before that he headed technology, media and telecom at Kohlberg Kravis Roberts & Co. L.P. from 2007 to 2019 (and worked there in 1995-1997). He sits on the boards of GoDaddy, Inc. and Internet Brands Inc.; the SEC's insider register also lists earlier directorships at Eastman Kodak Company (from 2009) and WJ Communications Inc (from 2006). [src-001] [src-027]
- Documented: On November 3, 2023 Herald Chen told AppLovin he would resign as president and chief financial officer effective December 31, 2023 while remaining a director; from January 1, 2024 he advised the chief executive for a one-year term, for which he received 62,418 restricted stock units. The board appointed Matthew Stumpf chief financial officer and designated controller Dmitriy Dorosh as principal accounting officer from January 1, 2024. [src-002] [src-008]
- Documented: Craig Billings has been an AppLovin director since December 2020, lead independent director from February 2021 and independent chairperson since April 2026. He has been chief executive and a director of Wynn Resorts, Limited since February 2022 (previously its chief financial officer and treasurer from March 2017 and president from 2019 to 2021), a director of Wynn Macau, Limited since August 2018, and was non-executive chairman of NYX Gaming Group Ltd. from December 2015 to January 2018. [src-001] [src-033]
- Documented: Margaret (Margo) Georgiadis has been an AppLovin director since January 2021. She is co-founder and chief executive of Montai Therapeutics and, since April 2022, a CEO-Partner of Flagship Pioneering Inc.; she was Endurance Partner-in-Residence at General Catalyst (2021-2022), president and chief executive of Ancestry.com LLC (2018-2020), chief executive of Mattel, Inc. (2017-2018) and president of Google Americas (2009-2017), and sits on the board of McDonald's Corporation. The SEC's insider register also lists earlier roles as a director of Amyris, Inc. and Jones Group Inc and as an executive vice president of Discover Financial Services. [src-001] [src-042]
- Documented: Barbara Messing has been an AppLovin director since March 2024 and an operating partner of the growth-equity firm Stripes, LLC since January 2026. She was chief marketing officer of Roblox Corp. (2020-2023) and previously of Walmart U.S. and TripAdvisor, and served on the boards of Vacasa, Inc. (2021-2025), Overstock.com, Inc. (2020-2023) and XO Group Inc. [src-001] [src-044]
- Documented: Todd Morgenfeld was appointed an AppLovin director on September 5, 2023. He was chief financial officer of Pinterest, Inc. from November 2016 and also head of business operations from May 2020 to July 2023, and earlier vice president of finance at Twitter, Inc. (2015-2016), treasurer and senior vice president at Hewlett-Packard Company (2013-2015) and an investment partner at Silver Lake Partners (2004-2013). He sits on the boards of Urban Outfitters, Inc. and Axon Enterprise, Inc. His appointment filing reported no related-party transactions with AppLovin. [src-019] [src-001] [src-043]
- Documented: Eduardo Vivas has been an AppLovin director since August 2018. He was chief operating officer of Humans, Inc., developer of the Flip Shop app (March 2024 to September 2025), co-founder and chief executive of the online retailer Curated, Inc. (2017-2024), head of product for talent solutions at LinkedIn (2014-2017) and co-founder and chief product officer of Bright.com (2011-2014). The SEC's insider register lists no other U.S. public company for him. [src-001] [src-030]
- Attributed: Outside AppLovin's filings, several sources tie its founders and early staff to Adam Foroughi's earlier companies: a 2014 press profile described Eduardo Vivas as a co-founder of Social Hour, which it said the mobile game network PlayPhone bought in 2012 for $51.5 million; an online encyclopedia says Andrew Karam co-founded Social Hour and the design platform Style Page; and Culper Research wrote that Karam, John Krystynak and Rafael Vivas also worked at Social Hour or Lifestreet. [src-060] [src-105] [src-081]
  - Qualification: AppLovin's filings state only Foroughi's own role as co-founder of Lifestreet Media and Social Hour.
- Documented: Maynard Webb was appointed an AppLovin director on April 9, 2025, joining the audit and nominating and corporate governance committees. He founded the venture firm Webb Investment Network in 2010, chaired Liveops, Inc. (2008-2013) and was its chief executive (2006-2011), was chief operating officer of eBay, Inc. (2002-2006), and chaired Yahoo! Inc. until 2017; he sits on the boards of Salesforce, Inc. (since September 2006) and Visa Inc. His appointment filing reported no related-party transactions. [src-001] [src-057] [src-022]
- Documented: Victoria Valenzuela joined AppLovin through its acquisition of Machine Zone, Inc., where she had been chief legal officer and corporate secretary from January 2015 to April 2020; she was AppLovin's chief legal officer from May 2020 and chief administrative and legal officer from July 2025, and earlier general counsel of Cypress Semiconductor Corporation (2004-2014). [src-001] [src-046]
- Documented: Vasily (Basil) Shikin was AppLovin's vice president of engineering from January 2012 and chief technology officer from January 2020; before joining he was a senior software engineer at DeviceAnywhere, Inc. (2008-2012). He holds a master's degree in mathematics from Saint Petersburg State University. [src-001] [src-047]
- Documented: Matthew Stumpf has been AppLovin's chief financial officer since January 2024, after serving as vice president of finance and FP&A (July 2022 to December 2023) and senior director of FP&A from February 2020; from 2006 to 2020 he worked at PricewaterhouseCoopers, most recently as a transaction services director. [src-001] [src-048]
- Documented: Dmitriy Dorosh has been AppLovin's vice president and controller since September 2022 and principal accounting officer since January 2024; he joined in November 2019 after technical accounting roles at Facebook and WageWorks and a career at PricewaterhouseCoopers from 2007 to 2017. [src-008] [src-029]
- Documented: The SEC's insider register lists Giovanni (Xiaochuan) Ge as chief technology officer from July 1, 2026 and Corina I. Cacovean as chief legal officer from August 1, 2026; both report holdings only in AppLovin. [src-029] [src-049] [src-050]
- Documented: Katie Jansen, AppLovin's chief marketing officer at the IPO, resigned on February 10, 2025 with effect from March 14, 2025; the company reported that her resignation was not the result of any disagreement. [src-020] [src-006]
- Documented: Elena Arutunian, chief accounting officer and principal accounting officer, resigned on August 8, 2022 with effect two business days after the filing of the second-quarter 2022 report; AppLovin stated that there was no disagreement with the company or its auditor. [src-035]
- Documented: Edward Oberwager, a managing director in KKR's private equity business since 2008, was an AppLovin director from November 2019 and KKR Denali's designee on the board. On April 8, 2025 he said he would not stand for re-election at the 2025 annual meeting, a decision AppLovin said was not the result of any disagreement. [src-006] [src-022] [src-010]
- Documented: Cathy Sun, a director at KKR since September 2016 and a board member of Internet Brands Inc. from March 2020, was an AppLovin director from November 2019 until she resigned from the board on November 8, 2021 to take up the role of GM, New Initiatives at AppLovin. [src-006] [src-021]
- Documented: Asha Sharma was an AppLovin director from August 2021 until she resigned on September 5, 2023, a resignation AppLovin said was not due to any disagreement. She has been chief operating officer of Maplebear Inc. (Instacart) since February 2021, was chief operating officer of Porch Group, Inc. (2013-2017) and has been on its board since December 2020, and also served on the board of Help Scout PBC; the SEC's insider register lists later directorships at Coupang, Inc. (2024) and The Home Depot, Inc. (2025). [src-010] [src-019] [src-045]
- Documented: Alyssa Harvey Dawson was appointed an AppLovin director on November 8, 2021. She was chief legal officer of Gusto, Inc. (2020-2022) and then of HubSpot, earlier general counsel of Sidewalk Labs, LLC (2017-2020) and vice president for global intellectual property at Harman International Industries (2011-2017). On April 2, 2026 she said she would not stand for re-election, which AppLovin said was not the result of any disagreement. [src-010] [src-009] [src-021]
- Attributed: Fuzzy Panda Research, citing Culper Research, wrote that Adam Foroughi had previously worked at Gator Corporation, which it described as "notorious as one of the first widespread spyware applications", and that Social Hour, founded by Foroughi and Andrew Karam, was banned by Facebook for showing "scammy ads". [src-076]
  - Qualification: AppLovin's proxy statement confirms that Foroughi co-founded Social Hour; his work at Gator and the Facebook ban are not documented in the record.

## AppLovin acquisitions and the 2025 sale of its studios

- Documented: AppLovin's IPO prospectus states that since 2018 it had invested more than $1 billion in 15 strategic acquisitions and partnerships, including PeopleFun (first quarter of 2018), MAX (third quarter of 2018), SafeDK (July 2019) and Machine Zone (May 2020), and that in February 2021 it had agreed to buy Adjust. [src-006]
- Documented: On March 31, 2018 AppLovin bought all shares of PeopleFun, Inc., a mobile game company in Richardson, Texas, for $19.8 million in cash plus an earn-out of up to $79.2 million; the purchase price was recorded at $73.9 million. In December 2018 the earn-out was replaced by a one-time payment of cash and Class A shares, on which AppLovin recognised a $10.8 million gain. [src-102] [src-006]
- Documented: On September 4, 2018 AppLovin bought MAX Advertising Systems, Inc. of San Francisco for $31.9 million in cash and 438,240 shares valued at $0.7 million; MAX became its in-app bidding platform for publisher monetisation. [src-102] [src-006]
- Documented: In 2019 AppLovin added SafeDK (July), whose brand-safety features it integrated into MAX, and the game studio Clipwire Games (November); its accounts show business combinations in 2019 for $54.6 million in total, without a breakdown by company. [src-006] [src-102]
- Documented: In January 2019 AppLovin bought a mobile game from Recoded, an independent foreign-based developer, for $150.0 million upfront and $90.0 million deferred, accounted for as a $240.0 million asset acquisition, with one-time earn-outs of $60.0 million or $30.0 million for each new game developed under a three-year service agreement. In January 2021 it paid Recoded $60.0 million for a further game acquired in 2020 and in February 2021 the $90.0 million deferred consideration. [src-006] [src-034]
- Documented: In August 2019 AppLovin bought four mobile games from a company in Cyprus, developed by an independent foreign developer, for $131.6 million upfront, $22.5 million deferred and four years of earn-outs, recording $167.1 million for the games; in April 2019 it had bought assets of a U.S. game developer for $59.4 million plus $10.5 million deferred. Neither seller is named; AppLovin's 2021 subsidiary list includes a Cyprus company, Samfinaco Limited. [src-102] [src-036]
  - Qualification: The filings name the August 2019 purchase after Samfinaco but do not state whether Samfinaco Limited was the seller or a group vehicle.
- Documented: On January 31, 2020 AppLovin bought all shares of the Czech mobile game company Geewa a.s. for $25.6 million, of which $23.5 million in cash and $2.1 million held back for indemnities. [src-006]
- Documented: On April 6, 2020 AppLovin bought 95.5% of Redemption Games, Inc. for $53.7 million, valuing the company at $56.2 million, and raised its stake to 98.2% in November 2020. [src-006]
- Documented: On April 20, 2021 AppLovin acquired adjust GmbH, a Berlin mobile app tracking and analytics company, buying all shares and settling its debt for a stated $980.0 million: $352.0 million in convertible securities (converted into Class A shares), a $50.0 million cash holdback and $578.0 million in cash, with a fair value of $967.8 million. The buyer under the amended share purchase agreement was AppLovin's subsidiary AppLovin Active Holdings, LLC; Adjust's shareholders and Spree Eternity GmbH were also parties. [src-034]
- Documented: On January 1, 2022 AppLovin bought the MoPub advertising business from Twitter, Inc. for $1.03 billion in cash ($1,030.3 million, of which $632.5 million goodwill), to move MoPub's publishers and demand partners onto its MAX platform. [src-034]
- Documented: On April 1, 2022 AppLovin bought all equity of Wurl, Inc., a connected-TV software company, for $378.2 million: $219.3 million in cash, 2,579,692 Class A shares valued at $137.4 million and a deferred holdback of $22.7 million. [src-034]
- Documented: AppLovin's annual reports name Machine Zone (May 2020), Adjust (April 2021), Twitter's MoPub business (January 2022) and Wurl (April 2022) as examples of its acquisitions, and the report for 2025 states that there were no business combinations in 2024 or 2025. [src-002] [src-034]
- Documented: In August 2022 AppLovin made a non-binding proposal to combine with Unity Software and later withdrew it. [src-034]
- Documented: In April 2025 AppLovin confirmed that it had given the President of the United States an indication of interest in buying TikTok's business outside China; it did not enter into a transaction. [src-002]
- Documented: On February 12, 2025 AppLovin announced a term sheet to sell its mobile gaming business to an unnamed private company for $900 million, $400 million in the buyer's shares and $500 million in cash. [src-020]
- Documented: On May 7, 2025 AppLovin and its subsidiaries Morocco, Inc. and AppLovin GmbH agreed to sell the Apps business to Tripledot, a Cayman Islands company, and its subsidiaries Eton Games, Inc. and Tripledot Group Holdings Limited (named TDS Group Holdings Limited in the amendment). An amendment of June 30, 2025, signed by Adam Foroughi and Tripledot chief executive Lior Shiff, set a minimum cash payment of $150 million and let Tripledot pay the balance in cash instead of by a promissory note. The sale closed on June 30, 2025 for $715.6 million: $430.6 million in cash and 596.9 million Tripledot shares valued at $285.0 million, about 22% of Tripledot's shares and 20% of its fully diluted equity. [src-002] [src-040]
- Documented: After the sale AppLovin kept responsibility for certain legal proceedings concerning its former studios, which it does not expect to be material. [src-002]
- Documented: While AppLovin owned Geewa, Herald Chen was a member of Geewa's board of directors from October 5, 2021 to August 4, 2022. Geewa's legal entity identifier, issued in 2017, has not been renewed since December 2021 and is shown as lapsed. [src-051] [src-110]

## AppLovin's group companies

- Documented: The full subsidiary list filed with AppLovin's annual report for 2021 includes the Adjust group (Adjust GmbH, adjust International Holding GmbH, adjust Inc., Adeven Israel Ltd, Adjust Software Limited in England, Adjust Singapore and other national companies), AppLovin GmbH in Germany, AL HK Ltd in Hong Kong, AppLovin Cayman Limited and AppLovin Corporate Limited in the Cayman Islands, AppLovin Active Holdings, LLC in the United States, AppLovin Business Consulting in China, AppLovin Cyprus Limited, the Israeli companies SafeDK Mobile Ltd and Unbotify Ltd, the merger vehicle Morocco, Inc., Samfinaco Limited in Cyprus and game studios such as Machine Zone, Inc., Geewa a.s., Clipwire Games Inc., Redemption Games, Inc., PeopleFun, Inc., Lion Studios, LLC and the ZenLife companies. [src-036]
- Documented: The subsidiary list filed with the annual report for 2022 names Adjust GmbH (Germany), AppLovin Active Holdings, LLC, AppLovin Cyprus Limited, Clipwire Games Inc. (Canada), Lion Studios, LLC, Machine Zone, Inc., Magic Tavern, Inc., Morocco, Inc., PeopleFun, Inc., WURL, LLC, ZenLife Games Limited (Cyprus) and ZenLife Games Pte. Ltd. (Singapore). [src-099]
- Documented: The subsidiary list filed with the annual report for 2024, also referred to in the report for 2025, names three subsidiaries: Adjust GmbH (Germany), AppLovin Active Holdings, LLC (United States) and AppLovin (Singapore) Pte. Ltd. (Singapore). [src-007]
  - Qualification: Such lists may omit subsidiaries that are not individually significant; earlier lists named many more companies.
- Documented: Two further Singapore companies with the group's name, AppLovin (Singapore) Technologies I Pte. Ltd. (incorporated December 20, 2024, listed with money-transfer and treasury activities) and AppLovin (Singapore) Technologies II Pte. Ltd., with consecutive registration numbers, were struck off the register on January 26, 2026 according to the official gazette list. A directory gives Technologies I the same Cecil Street address as AppLovin (Singapore) Pte. Ltd. and describes it as an AppLovin subsidiary. [src-107] [src-103]
  - Qualification: Neither company is named in AppLovin's subsidiary lists; the connection to the group rests on the names and directory profiles.
- Documented: WURL, LLC is a Delaware limited liability company registered in California as an out-of-state company on July 19, 2022, three months after AppLovin bought Wurl, Inc., with its address at AppLovin's principal office, 1100 Page Mill Road in Palo Alto. [src-038]
  - Qualification: Read in a business-directory or register-aggregator copy, not in the official register. The record does not show whether Wurl, Inc. was converted into WURL, LLC.
- Documented: AppLovin GmbH is registered with the commercial register of the Charlottenburg district court in Berlin under HRB 179573 B and was one of the sellers of the Apps business in 2025. Register data shown by an aggregator give its purpose as developing and distributing advertising solutions for mobile devices and list Dominik Roß, earlier an authorised signatory, as a managing director. [src-040] [src-026]
- Documented: An Israeli Corporations Authority extract dated January 21, 2025 shows SafeDK Mobile Ltd, company number 515138816, registered on September 29, 2014 and active, with AppLovin Corporation as sole shareholder (entry of November 18, 2021) and Arash Adam Foroughi as director since July 8, 2020. [src-055]
  - Qualification: The extract was read in a copy published by short seller Fuzzy Panda Research and partly transcribed by OCR; the identification of the director with AppLovin's chief executive rests on the full name.
- Documented: The U.S. trademark SAFEDK, registered in December 2015 to SafeDK Mobile Ltd of Herzliya, Israel for software that monitors SDKs, was cancelled on July 8, 2022 because no declaration of use was filed. [src-112]

## Adjust GmbH: AppLovin’s measurement company

- Documented: Adjust's consolidated statements for 2020, audited by Deloitte GmbH and filed by AppLovin with the SEC, list twelve wholly owned subsidiaries, including Adjust Inc and Acquired IO Inc in the United States, Adeven Software Ltd. in Great Britain, Unbotify Ltd. and Adeven Israel Ltd in Israel, Adjust International Holding GmbH in Germany and companies in Japan, China, Korea, France, Singapore and Brazil. [src-072]
- Documented: On January 28, 2019, before AppLovin bought Adjust, Adjust acquired all of Unbotify Ltd. of Tel Aviv, a developer of a machine-learning tool that separates real users from bots, for EUR 16.9 million in cash plus contingent consideration. [src-072]
- Documented: Adjust's 2020 statements were signed on February 15, 2021 by its management board, Paul Müller and Christian Henschel, and record that Adjust's shareholders had signed an agreement on February 2, 2021 to sell all of its shares to AppLovin, after which Adjust would remain an independent company within the group. Register publications shown by aggregators record Müller as managing director of Adjust GmbH from 2012 to 2022 and Henschel from 2012 until October 2021, and both as managing directors of adjust International Holding GmbH until 2021-2022. [src-072] [src-087] [src-088]
- Documented: A register aggregator lists Andrey Kazakov and Egor Lukomsky as current managing directors of Adjust GmbH, Paul Müller and Marina Keitel as former managing directors, and phm equity GmbH as holding 6.3% of Adjust in 2020. [src-025]
  - Qualification: Read in a business-directory or register-aggregator copy, not in the official register. The aggregator does not confirm the direction or dates of the relationships.

## Lawsuits and regulatory inquiries involving AppLovin

- Documented: In the legal-proceedings sections of its annual report for 2025 and its quarterly report for the second quarter of 2026, AppLovin says in general terms that it is involved in legal proceedings and claims as well as "governmental and other regulatory investigations and proceedings", but names only the US securities class action and the shareholder derivative litigation. It says it cannot estimate the maximum potential exposure or range of possible loss. [src-002] [src-059]
- Documented: On May 21, 2026 Stichting The Privacy Collective (TPC), an Amsterdam foundation, served a collective-action summons under Article 3:305a of the Dutch Civil Code on AppLovin Corporation and Adjust GmbH, to be brought before the Amsterdam District Court with a first docket date of August 26, 2026, according to the extract filed in the Dutch central register of collective actions. TPC asks the court to appoint it exclusive representative of the affected group. [src-085]
- Attributed: Amnesty International Netherlands publicly supported The Privacy Collective's lawsuit on the day it was filed, saying that AppLovin's tracking software in popular games and apps collects personal data from millions of Dutch users, including one and a half million children, and that the data is allegedly shared with hundreds of other companies and used to build user profiles for selling advertising. It named Block Blast, Subway Surfers, Helix Jump, Vinted and CapCut Video Editor among the apps in which the software had been found. [src-068] [src-118]
  - Qualification: Amnesty supports the claimant; its statement repeats the claimant's case and is not a finding.

## Short-seller reports on AppLovin and its response

- Documented: In 2025 three short sellers published reports on AppLovin while disclosing short positions in its shares: Fuzzy Panda Research and Culper Research on February 26, 2025, Muddy Waters Research on March 27, 2025, and Culper Research again on June 12, 2025. Muddy Waters said it intended to begin covering a substantial majority, possibly all, of its short position upon publication. AppLovin's shares fell 12% on February 26, the day of the first reports, according to the press. [src-080] [src-065] [src-076] [src-081] [src-079]
- Documented: In a "Note from our CEO" published on AppLovin's website on February 26, 2025 as a mid-quarter update, Adam Foroughi called the short reports false and misleading and said they aimed to drive down the stock price for the short sellers' own gain. He said the games AppLovin promotes comply with App Store policies and that every download results from an explicit user choice, "whether via the App Store or our Direct Download experience"; that AppLovin does not track children's data, prohibits apps directed exclusively at children and does not work separately with data brokers; that Adjust and MAX operate independently "with no conflicts or house bias"; and that the claims of financial and accounting improprieties are incorrect, with no duplication of revenue from related parties, a Big Four auditor that has never issued a modified opinion, and a low tax burden explained by stock-based compensation deductions and tax structuring. [src-078] [src-065] [src-080]
  - Qualification: This is AppLovin's own account; the page read is undated, and the date is the one Muddy Waters gives when quoting the note.
- Attributed: In its June 2025 report Culper Research wrote that Adam Foroughi had said on AppLovin's first-quarter 2025 call in May 2025 that "we don't operate inside China", yet AppLovin had formed agency agreements in January 2025 with two Chinese advertising-technology companies, BlueFocus Intelligent Communications Group and eClickTech, to expand cross-border e-commerce operations, which it said were not disclosed to US investors. [src-079]
  - Qualification: The agreements themselves are confirmed by the counterparties' announcements (see below); the conclusion that they contradict the chief executive's statement is Culper's.
- Documented: Both Chinese counterparties announced the arrangements themselves. On January 15, 2025 eClickTech said its Cyberklick brand had become AppLovin's first "Greater China tier-one" agent; BlueFocus's 2024 annual report summary, filed on the Shenzhen exchange's disclosure platform, says it signed with AppLovin at the end of the period and became its first certified e-commerce partner in Greater China, for cross-border e-commerce clients. Neither announcement gives amounts or terms. [src-091] [src-111]
  - Qualification: AppLovin's filings in the record do not mention these arrangements; the announcements are the counterparties' own statements.

## Sources

- [src-002] AppLovin Corporation annual report on Form 10-K for 2025, U.S. Securities and Exchange Commission (EDGAR), 2026 <https://www.sec.gov/Archives/edgar/data/1751008/000175100826000010/app-20251231.htm>
- [src-024] SEC EDGAR submissions record for AppLovin Corp (CIK 0001751008), U.S. Securities and Exchange Commission (EDGAR), 2026-10-16 <https://data.sec.gov/submissions/CIK0001751008.json>
- [src-094] Form 4 filed by Eduardo Vivas (May 2025), U.S. Securities and Exchange Commission (EDGAR), 2025-05-14 <https://www.sec.gov/Archives/edgar/data/1848493/000156218025003832/0001562180-25-003832.txt>
- [src-001] AppLovin Corporation proxy statement for the 2026 annual meeting (Schedule 14A), U.S. Securities and Exchange Commission (EDGAR), 2026-04-20 <https://www.sec.gov/Archives/edgar/data/1751008/000175100826000028/app-20260420.htm>
- [src-041] AppLovin Corporation proxy statement for the 2025 annual meeting, U.S. Securities and Exchange Commission (EDGAR), 2025 <https://www.sec.gov/Archives/edgar/data/1751008/000175100825000041/app-20250421.htm>
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