--- title: "AppLovin Corp: control, investors, deals and disputes" language: en canonical: https://dossiertwist.com/dossiers/applovin-corp/ 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"] --- # AppLovin Corp: control, investors, deals and disputes **Question.** Who controls AppLovin, who were its large outside investors, and which disputes and allegations concern the company? **Answer.** AppLovin Corporation, a Delaware advertising-technology company listed on Nasdaq since April 2021, is controlled by co-founder and chief executive Adam Foroughi and director Herald Chen through a Voting Agreement covering 66.9% of the votes in March 2026. KKR, its private-equity investor from 2018, sold out by the end of 2024. Hontai App Fund, Angel Pride Holdings and companies of Hao Tang held large Class A stakes; a short seller alleges that Tang controlled them, which the holders' SEC filings do not show. AppLovin sold its game studios to Tripledot in 2025 and faces securities class actions in the United States, a Dutch privacy collective action and a reported SEC investigation, none of them resolved. ## What this research adds - Analysis: The dossier sets AppLovin's documented ownership, from the founders' dual-class control and KKR's 2018–2024 investment to the offshore holders Hontai App Fund, Angel Pride Holdings and Hao Tang's companies, beside the short-seller and press accounts that question it, and keeps each account's limits, responses and outcomes with it. It follows the acquisitions from PeopleFun to Wurl and the 2025 sale of the studios to Tripledot, the related-party dealings, the board and officers, and the pending lawsuits in California and the Netherlands, the Unity dispute, the reported SEC investigation and the Justice Department's HSR settlement with KKR. [src-002] [src-024] [src-094] [src-001] [src-006] [src-070] [src-010] [src-012] [src-029] [src-005] [src-079] [src-034] [src-040] [src-080] [src-065] [src-076] [src-081] [src-031] [src-085] [src-068] [src-064] [src-077] ## The company - Analysis: AppLovin Corporation is a Delaware corporation with its principal executive offices at 1100 Page Mill Road in Palo Alto, California; its SEC Central Index Key is 0001751008. A filing header records only a change of capitalisation of its name, from "Applovin Corp" to "AppLovin Corp", in August 2018. Its Class A common stock has traded on the Nasdaq Global Select Market under the symbol APP since the initial public offering of April 15, 2021, priced at $80.00 a share. [src-002] [src-024] [src-094] - Analysis: AppLovin describes its business through four advertising products: Axon Ads Manager, its user-acquisition tool built on the Axon recommendation engine; MAX, its in-app bidding solution for publishers; Adjust, its measurement and analytics platform; and Wurl, its connected-TV platform. Its 2025 annual report shows revenue from continuing operations of $5,480.7 million and net income from continuing operations of $3,433.2 million, against $1,841.8 million and $457.8 million in 2023; the company's own letter to shareholders adds $4.5 billion of Adjusted EBITDA, a non-GAAP measure. [src-002] [src-001] ## Who controls it - Analysis: Class A shares carry one vote and Class B shares 20 votes. Adam Foroughi held 92.5% of the Class B shares and 61.6% of total voting power on March 31, 2026. He and Herald Chen, with affiliated trusts and entities, are parties to a Voting Agreement under which all their shares are voted as the two of them decide; AppLovin's 2026 proxy statement attributes 66.9% of the votes to the shares under the agreement. AppLovin is therefore a "controlled company" under Nasdaq rules, although it says it does not use the exemptions that status allows. [src-001] ## Large outside investors - Analysis: KKR Denali Holdings L.P. bought Series A preferred stock for about $400 million in August 2018; Herald Chen, then a KKR executive, later became AppLovin's president and chief financial officer. KKR Denali sold its stake in 2023 and 2024, partly back to AppLovin, and had no shares left by December 31, 2024. [src-006] [src-002] [src-070] - Analysis: Before the IPO, Hontai App Fund Limited Partnership held 14.1% and Angel Pride Holdings Limited 14.0% of the Class A shares. The prospectus named Tang Ling as Angel Pride's shareholder and sole director. Hontai App Fund distributed all its shares to unnamed limited partners by the end of 2023, and in October 2023 Hao Tang reported 8.4% of the Class A shares, held through Midterm Success Limited. [src-006] [src-010] [src-012] [src-029] [src-005] - Analysis: Short seller Culper Research alleged in June 2025 that Hao Tang had backed AppLovin since at least 2017 and controlled up to 28% of the Class A shares before the IPO through offshore companies. The SEC filings in the record attribute Angel Pride's shares first to Ling Tang and then to Prominence Trust Limited, not to Hao Tang, and Culper's account has not been adopted by AppLovin or any authority. [src-079] ## Acquisitions and the sale of the studios - Analysis: AppLovin built a portfolio of game studios and advertising technology, buying Machine Zone in May 2020, settling its debt for $328.6 million, Adjust GmbH in April 2021 for a stated $980.0 million, Twitter's MoPub business for $1.03 billion on January 1, 2022 and Wurl in April 2022. In 2025 it sold the Apps business, its game studios, to Tripledot for $715.6 million in cash and Tripledot shares, receiving about 22% of Tripledot's shares. [src-006] [src-034] [src-002] [src-040] - Documented: On May 19, 2020 AppLovin acquired the Palo Alto game company Machine Zone, Inc. by merger with Morocco Acquisition Sub, a subsidiary of its subsidiary Morocco, Inc., buying all shares and settling all of Machine Zone's debt for $328.6 million: $287.1 million in cash to Machine Zone's lenders, warrants valued at $38.2 million and $3.3 million of receivables set off. [src-006] [src-034] - Qualification: An online encyclopedia puts the price at about $500 million; the prospectus figure is the accounting purchase price including the debt settlement. ## Lawsuits, inquiries and short sellers - Analysis: In 2025 three short sellers, Fuzzy Panda Research, Culper Research and Muddy Waters Research, published reports against AppLovin while short its shares. Shareholders then sued AppLovin and its senior officers in the Northern District of California, alleging misleading statements about its advertising solutions and growth; AppLovin says the claims lack merit, and the motion to dismiss had not been decided by mid-October 2026. [src-080] [src-065] [src-076] [src-081] [src-079] [src-002] [src-031] - Attributed: Beginning in March 2025, shareholders filed putative class actions in the U.S. District Court for the Northern District of California against AppLovin, Adam Foroughi, Matthew Stumpf and, in two of the three complaints, Herald Chen, alleging violations of Sections 10(b) and 20(a) of the Securities Exchange Act and Rule 10b-5. Two of the complaints, including one filed by the Wayne County Employees' Retirement System, were voluntarily dismissed in May 2025. In the remaining case (No. 4:25-cv-02772), the court-appointed lead plaintiffs, Northern California Pipe Trades Trust Funds and Monroe County Employees' Retirement System, filed an amended complaint on September 12, 2025 that added Basil Shikin as a defendant. It alleges that the defendants made materially false and misleading statements about AppLovin's advertising solutions and financial growth during a class period from November 7, 2024 to March 27, 2025. [src-002] [src-031] - Qualification: These are the plaintiffs' allegations; no court has ruled on them. - Response: AppLovin says the allegations lack merit and that it will vigorously contest the action. - Outcome: The defendants moved to dismiss the amended complaint on November 14, 2025. On April 14, 2026 the court took that motion and the plaintiffs' motion for leave to supplement their complaint under submission without a hearing, and on September 30, 2026 it denied the motion to supplement. No ruling on the merits is in the record as of mid-October 2026. - Analysis: In the Netherlands, the foundation The Privacy Collective sued AppLovin and Adjust in May 2026 under the collective-action rules, alleging unlawful processing of the data of at least 8.5 million people through their software development kits. The press reported in October 2025 that the SEC was investigating allegations that AppLovin had violated platform partners' service agreements to target advertising; AppLovin does not comment on the existence of regulatory matters and names no SEC investigation in its reports. Separately, the Justice Department's suit against KKR entities over missed premerger filings, including for the 2021 AppLovin share acquisition, led to a proposed $250 million civil penalty against KKR & Co. GP LLC without admission. [src-085] [src-068] [src-064] [src-065] [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. - Unresolved: In October 2025 the press reported, citing people familiar with the matter, that the U.S. Securities and Exchange Commission was investigating allegations that AppLovin had violated platform partners' service agreements in order to push more targeted advertising to consumers, acting on a whistleblower complaint filed that year and on several short-seller reports. The reports said neither the company nor its officials had been accused of wrongdoing. AppLovin's shares fell 14% in regular trading after the report. [src-064] [src-065] - Qualification: Neither the SEC nor AppLovin has publicly confirmed the subject or scope of an investigation. AppLovin's annual report for 2025 and its quarterly report for the second quarter of 2026 do not name an SEC investigation; they refer only in general terms to governmental and other regulatory investigations and proceedings. - Response: An AppLovin spokesperson said the company does not typically comment on the "existence or non-existence" of regulatory matters, that it regularly engages with regulators and addresses inquiries in the ordinary course, and that material developments, if any, would be disclosed through the appropriate public channels. - Outcome: In February 2026 the press reported that the SEC, refusing a records request on appeal, had written that an "investigation involving AppLovin is still active and ongoing" and that releasing staff correspondence might "cause harm to the ongoing and active enforcement investigation"; the SEC did not specify the subject or scope of the investigation or accuse AppLovin or its officials of wrongdoing. The SEC letter itself is not in the record. - Attributed: In a complaint filed on January 14, 2025 in the U.S. District Court for the Southern District of New York (United States v. KKR & Co. Inc., et al., No. 1:25-cv-343-LTS), the Justice Department's Antitrust Division alleged that KKR entities failed to make complete and accurate premerger filings under the Hart-Scott-Rodino Act at least sixteen times. Count 15 alleges that KKR Americas Fund XII L.P. acquired additional voting shares of AppLovin on April 19, 2021 for about $6.9 billion without filing first, and that a corrective filing was made only on December 3, 2021; the defendants in that count are KKR & Co. Inc., KKR & Co. GP LLC, Kohlberg Kravis Roberts & Co. L.P. and KKR Americas Fund XII L.P. [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-002] AppLovin Corporation annual report on Form 10-K for 2025, U.S. Securities and Exchange Commission (EDGAR), 2026 - [src-024] SEC EDGAR submissions record for AppLovin Corp (CIK 0001751008), U.S. Securities and Exchange Commission (EDGAR), 2026-10-16 - [src-094] Form 4 filed by Eduardo Vivas (May 2025), U.S. Securities and Exchange Commission (EDGAR), 2025-05-14 - [src-001] AppLovin Corporation proxy statement for the 2026 annual meeting (Schedule 14A), U.S. Securities and Exchange Commission (EDGAR), 2026-04-20 - [src-006] AppLovin Corporation IPO prospectus (Form 424(b)(4)), U.S. Securities and Exchange Commission (EDGAR), 2021-04-15 - [src-070] Schedule 13G amendment by Adam Foroughi (November 2024), U.S. Securities and Exchange Commission (EDGAR), 2024-11-13 - [src-010] AppLovin Corporation proxy statement for the 2023 annual meeting, U.S. Securities and Exchange Commission (EDGAR), 2023 - [src-012] Form 3 amendment by Angel Pride Holdings Limited, U.S. Securities and Exchange Commission (EDGAR), 2021 - [src-029] SEC insider register page for AppLovin Corp as issuer, U.S. Securities and Exchange Commission (EDGAR insider register), 2026-10-16 - [src-005] Schedule 13G by Hao Tang, Asian Creative Capital Limited and Midterm Success Limited, U.S. Securities and Exchange Commission (EDGAR), 2023-10-06 - [src-079] Research source · src-079 - [src-034] AppLovin Corporation annual report on Form 10-K for 2022, U.S. Securities and Exchange Commission (EDGAR), 2023 - [src-040] Amendment No. 1 to the purchase agreement for the sale of the Apps business (Exhibit 2.1), U.S. Securities and Exchange Commission (EDGAR), 2025-06-30 - [src-080] Research source · src-080 - [src-065] Media source · src-065 - [src-076] Research source · src-076 - [src-081] Research source · src-081 - [src-031] Court record source · src-031 - [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-064] Media source · src-064 - [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