Welcome to the Infinity Q Securities Settlement Website

This website has been established to provide general information related to the proposed settlement of the class action lawsuits, In re Infinity Q Diversified Alpha Fund Securities Litigation, Index No. 651295/2021 and Dominus Multimanager Fund, Ltd. v. Infinity Q Capital Management LLC, et al., Index No. 652906/2022 (together, the “State Action”), pending in the Supreme Court of the State of New York, County of New York: Commercial Division, along with In re Infinity Q Diversified Alpha Fund and Infinity Q Volatility Alpha Fund Securities Litigation (formerly known as Yang v. Trust for Advised Portfolios, et al.), Case No. 1:21-cv-01047-FB-MMH (E.D.N.Y.), pending in the United States District Court for the Eastern District of New York (the “Federal Action”). The capitalized terms used on this website, and not otherwise defined, shall have the same meanings ascribed to them in the Amended Stipulation of Settlement dated September 7, 2022 (the "Stipulation"), which can be found and downloaded by clicking on the Case Documents tab above. Your rights may be affected by the Settlement if you purchased or otherwise acquired investor shares (Ticker symbol IQDAX) and/or institutional shares (Ticker symbol IQDNX) in Infinity Q Diversified Alpha Fund (the “Diversified Fund”) between February 22, 2016 and February 22, 2021, both dates inclusive (the “Class Period”); and/or (ii) invested through either the Infinity Q Volatility Alpha Fund, L.P., or the Infinity Q Volatility Alpha Offshore Fund, Ltd. (collectively, the “Volatility Fund”) during the Class Period.

The Court appointed Scott+Scott Attorneys at Law and The Rosen Law Firm, P.A. as Co-Lead Counsel in the State Action and Robbins Geller Rudman & Dowd LLP and Boies Schiller Flexner LLP as lead counsel in the Federal Action to represent you and the other Class Members. You will not be directly charged for these lawyers. They will be paid from the Settlement Fund to the extent the Court approves their application for fees and expenses. If you want to be represented by your own lawyer, you may hire one at your own expense.

WHAT IS THIS LAWSUIT ABOUT?

As more fully described in the Notice of Pendency and Proposed Settlement of Class Action (the "Notice"), Lead Plaintiffs claim that Defendants violated one or more of common law claims, §§11, 12(a)(2), and/or 15 of the Securities Act of 1933 (the “Securities Act”) and/or §§10(b) and 20(a) of the Securities Exchange Act of 1934 (the “Exchange Act”), as well as U.S. Securities and Exchange Commission (“SEC”) Rule 10b-5 promulgated thereunder, by reason of materially false and misleading statements made by certain Defendants during the Class Period concerning the Diversified Fund and the Volatility Fund (together, the “Funds”) and in the Registration Statements and Prospectuses for the Diversified Fund. Specifically, Lead Plaintiffs allege that certain Defendants made materially false and misleading statements about, and failed to disclose material information regarding, the way that the Funds and their investment advisors valued certain assets of the Funds, including swap contracts. Lead Plaintiffs also allege that certain Defendants failed to adhere to stated valuation procedures and tampered, or failed to prevent tampering, with third-party pricing models, resulting in valuations that were significantly overstated.

Settling Defendants deny all of Lead Plaintiffs’ allegations and any other wrongdoing. Without limiting the generality of the foregoing in any way, Settling Defendants have denied, and continue to deny, among other things, that any misstatements or materially misleading omissions were made or that Lead Plaintiffs or the Class have suffered any damages, and/or suffered any damages caused by Defendants. Settling Defendants do not admit any liability or wrongdoing in connection with the allegations set forth in the Litigation or any facts related thereto. The Settlement shall in no event be construed as, or deemed to be evidence of, liability, fault, wrongdoing, injury or damages, or of any wrongful conduct, acts, or omissions on the part of any of the Defendants, or of any infirmity of any defense, or of any damages to Lead Plaintiffs or any other Class Member.

The Parties agreed to mediate before Robert A. Meyer, Esq. of JAMS, and have agreed to settle the Litigation on the terms set forth in the Stipulation, subject to the Court’s approval, as detailed in the Notice.

WHAT DOES THE SETTLEMENT PROVIDE?

The proposed Settlement will create a cash settlement fund in the principal amount of up to $48,000,000 plus any interest that may accrue thereon (the “Settlement Fund”).

The Settlement Fund, plus accrued interest and minus the costs of the Notice and all costs associated with the administration of the Settlement Fund, as well as attorneys’ fees and expenses, and the award to Lead Plaintiffs for representing the Class, as approved by the Court (the “Net Settlement Fund”), will be distributed to eligible Class Members who submit valid, timely Proof of Claim and Release forms.

ADDITIONAL INFORMATION

Although the information in this website is intended to assist you, it does not replace the information contained in the Notice and Stipulation, both of which can be found and downloaded by clicking on the Case Documents tab above. We recommend that you read the Notice and other relevant case documents carefully.

IMPORTANT DATES AND DEADLINES