Coupang Class Action Submission Form

(a) Coupang was engaged in improper anti-competitive practices with its suppliers and other third parties in violation of applicable regulations, including: (i) pressuring suppliers to raise prices of products on competing e-commerce platforms to ensure Coupang’s prices would be more competitive; (ii) coercing suppliers into purchasing advertisements that would benefit Coupang financially; (iii) forcing suppliers to shoulder all expenses from sales promotions; and (iv) requesting wholesale rebates from suppliers without specifying any terms relating to rebate programs, all of which served to artificially maintain Coupang’s lower prices and artificially inflate Coupang’s historical revenues and market share; (b) Coupang had improperly adjusted search algorithms and manipulated product reviews on its marketplace platform to prioritize its own private-label branded products over those of other sellers and merchants, to the detriment of consumers, merchants, and suppliers; (c) unbeknownst to its Rocket WOW members, Coupang was selling products to non-member customers at lower prices than those offered to its Rocket WOW members; (d) Coupang subjected its workforce to extreme, unsafe, and unhealthy working conditions; (e) all of the above illicit practices exposed Coupang to a heightened, but undisclosed, risk of reputational and regulatory scrutiny that would harm Coupang’s critical relationships with consumers, merchants, suppliers, and the workforce; and (f) Coupang’s lower prices, historical revenues, competitive advantages, and growing market share were the result of systemic, improper, unethical, and/or illegal practices, and, thus, unsustainable.