Binance Holdings Limited ("Binance" or "Plaintiff'), as and for its Complaint against Dow Jones & Company, Inc. d/b/a The Wall Street Journal ("Dow Jones" or "Wall Street Journal"), alleges as follows: INTRODUCTION 1. Binance brings this action against the Wall Street Journal for publishing a false and defamatory article on February 23, 2026, which is the subject of this complaint (the "Article"). In the Article, the Wall Street Journal made numerous false and disparaging statements about Binance, and did so knowingly, recklessly, or negligently, and despite the fact that Binance provided factual corrections prior to publication, which the Wall Street Journal disregarded. 2. Binance is the world's largest cryptocurrency exchange by trading volume and users. In addition to holding licenses, registrations, and authorizations in more than 20 jurisdictions, Binance is the first cryptocurrency exchange to have secured full authorization under the Financial Services Regulatory Authority of the Abu Dhabi Global Market's regulatory framework. Binance has built one of the largest and most robust compliance programs in the digital asset industry, dedicating more than 1,500 individuals, nearly a quarter of its global workforce, to compliance, investigative, and risk functions. Binance invests