A federal judge in the Southern District of New York has permanently dismissed a class action lawsuit tied to two of crypto's most notorious memecoin blowups — LIBRA and M3M3 — with prejudice, formally ending litigation against Hayden Davis, Kelsier Ventures, former Meteora CEO Benjamin Chow, and the Meteora protocol itself.
The 81-page ruling, issued on Tuesday, September 29, 2026, by Judge Jennifer L. Rochon, concluded that plaintiffs Omar Hurlock and Anuj Mehta failed to satisfy the legal standards required to support racketeering and fraud allegations under the federal RICO Act. The court also denied leave to file a second amended complaint, permanently closing the case in the Southern District of New York.
The plaintiffs had alleged that wallets associated with Kelsier bought $M3M3 while the liquidity pool was frozen in order to dump into subsequent market demand. In the case of $LIBRA — launched in February 2025 and linked to a post from Argentine President Javier Milei — the filing alleged the extraction of 44.6 million USDC and 249,665 SOL from liquidity reserves. Judge Rochon emphasized that these metrics represented unverified assertions by the litigants rather than established judicial facts, noting that proceedings concluded prior to reaching the evidentiary discovery phase.
The primary legal hurdle was the lack of continuity required under RICO. The alleged unlawful enterprise purportedly operated from October 2024 until the lawsuit was officially filed on March 17, 2025 — roughly six months — which the court found insufficient to establish closed-ended continuity for an organized conspiracy claim. The complaint outlined a single scheme, five defendants, one discrete goal, and wire fraud as the sole underlying predicate offense.
Claims against the Meteora protocol also failed to withstand judicial scrutiny. The plaintiffs argued the protocol functioned as an unincorporated association backed by a 4-of-7 multi-signature wallet used to authorize software updates. The court rejected this, clarifying that holding administrative keys to push code updates is not legally equivalent to a seven-member board executing joint commercial decisions. No actionable basis was found against former CEO Benjamin Chow either, as informal remarks in group calls lacked concrete evidence of deliberate fraudulent intent.
The plaintiffs' attempt to add other tokens — such as $MELANIA, ENRON, and TRUST — was denied as it failed to cure the complaint's underlying structural defects. With federal claims dismissed, the court also found a lack of personal jurisdiction over Davis and Kelsier in New York. While this case is now permanently closed, separate ancillary matters and administrative inquiries surrounding $LIBRA remain ongoing across other regulatory venues.
