A New York federal judge has dismissed the class action against Hayden Davis, Kelsier Labs, Benjamin Chow and Meteora over the LIBRA and M3M3 memecoin launches, closing the case with prejudic
A New York federal judge has dismissed the class action against Hayden Davis, Kelsier Labs, Benjamin Chow and Meteora over the LIBRA and M3M3 memecoin launches, closing the case with prejudice after rejecting the plaintiffs’ attempt to amend their complaint again.
U.S. District Judge Jennifer L. Rochon granted the defendants’ dismissal motions on September 29 in Hurlock v. Kelsier Ventures, No. 1:25-cv-03891. She also denied permission to file a second amended complaint and directed the clerk to close the case.
The litigation had combined allegations surrounding the M3M3 launch with claims tied to LIBRA, the Solana token promoted by Argentine President Javier Milei in February 2025 before its price collapsed.
The civil RICO claims against Kelsier Labs, Hayden Davis, Gideon Davis and Charles Thomas Davis failed because the alleged activity did not establish the required pattern of continued racketeering.
The plaintiffs described an enterprise operating for roughly six months. That period was insufficient to establish closed-ended continuity, while the allegations also failed to establish a continuing threat of future racketeering activity.
The remaining claims against the Kelsier defendants were dismissed for lack of personal jurisdiction in New York. Blockchain transactions passing through U.S. infrastructure and validators did not establish the New York-specific contacts required to keep those claims in the Southern District.
The ruling ends a case that previously produced a temporary freeze on $57.65 million in USDC tied to LIBRA proceeds. That restraint was later dissolved when Rochon denied the request for a preliminary injunction.
Claims against former Meteora CEO Benjamin Chow failed separately under the federal pleading standard.
Allegations surrounding Chow’s involvement in M3M3 did not sufficiently establish fraudulent intent. A statement cited from an M3M3 planning call was compatible with legitimate support for a token launch, while the prospect of earning money from the project was not enough by itself to establish the required intent to defraud.
The lawsuit had later expanded its allegations beyond M3M3 and LIBRA, accusing Chow and Kelsier of participating in a wider series of token launches linked to public figures. That expanded theory did not survive the court’s review.
Meteora also exited the case after the plaintiffs failed to plausibly plead that the protocol was an unincorporated association capable of being sued. Dynamic Labs had intervened to challenge that characterization, maintaining that Meteora is software deployed through permissionless smart contracts rather than a separate legal association.
Rochon denied another amendment that would have extended the allegations to MELANIA, ENRON and TRUST. The September 29 order states that the amended complaint is dismissed with prejudice and closes the federal case.
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