U.S. District Judge Jennifer L. Rochon of the Southern District of New York dismissed a class action lawsuit against Hayden Davis, Kelsier Ventures, and former Meteora CEO Ben Chow over the issuance of LIBRA and M3M3 tokens. The court denied plaintiffs' request to amend their complaint.
The dismissal turned on three core legal failures. Plaintiffs did not demonstrate that Meteora constitutes a recognizable unincorporated entity subject to litigation—a recurring hurdle for loosely structured crypto projects. Their RICO claims failed to establish continuity of criminal activity required to show a pattern of racketeering. Fraud allegations against Chow did not meet the burden of proof needed to support deceptive conduct claims.
Judge Rochon's order made no factual finding on whether market manipulation, fraud, or other misconduct occurred during the token issuance. The dismissal rested solely on procedural and legal sufficiency. The denial of leave to amend prevents plaintiffs from refiling under revised arguments in this jurisdiction.
