Procedural endgame in Manhattan. Federal judge Jennifer L. Rochon has definitively dismissed the class action brought against several alleged promoters of the $LIBRA and $M3M3 memecoins. In an 81-page decision rendered on September 29, the magistrate dismissed all of the requests and refused a new modification of the complaint, deemed unnecessary.
This legal victory does not, however, constitute validation of the launches concerned. The court did not determine whether the manipulations denounced had actually taken place. He concluded that the plaintiffs had failed to properly establish the legal grounds to sue the defendants in New York.
Key Points
All requests against Hayden Davis, his family, Kelsier Ventures, Benjamin Chow and Meteora have been rejected
Six to seven months of token launches are not enough to demonstrate the continuity required by the RICO law
Meteora has not been recognized as an association that can be prosecuted
The decision does not resolve the reality of the accusations of manipulation surrounding $LIBRA and $M3M3
LIBRA and M3M3: six months is not enough to form a RICO company
Omar Hurlock and Anuj Mehta filed the suit in federal court for the Southern District of New York. The first said he had lost around $19,000 on $M3M3, launched in December 2024. The second had bought $LIBRA on the day of its launch in February 2025, after the “Viva La Libertad” message published by Argentine President Javier Milei.
The complaint accused the defendants of grooming insider portfolios, controlling liquidity, artificially inflating prices and then selling their positions before a collapse greater than 90%. These accusations have not been examined on their merits.
The plaintiffs notably invoked the RICO Act, a federal law designed to prosecute organizations engaged in repeated criminal activity. To use it, they had to demonstrate the existence of a structured business and a sufficiently continuous pattern over time.
However, the period described extended over approximately six months, from October 2024 to March 2025. The proposal to add $MELANIA, $ENRON and $TRUST to a new version of the complaint would only have extended this period to seven months. The judge considered this duration insufficient to establish closed continuity.
Open continuity also fails. The plaintiffs' own claims described Kelsier and Meteora as primarily legitimate activities, while the alleged wire fraud did not demonstrate a lasting threat of criminality. Without a racketeering scheme, RICO claims and the associated conspiracy disappear.
Meteora is not a “team” that can be chased
The complaint presented Meteora as an unincorporated association bringing together several participants. Dynamic Labs intervened to argue that Meteora referred to software and not a standalone organization.
The judge held that the plaintiffs had not identified specific members, leaders, rules of governance, or mutual consent around a common objective. Qualifying a protocol or its contributors as a “team” is therefore not enough to create an entity that can be sued.
Fraud claims against Benjamin Chow were also dismissed. Potential gains alone do not demonstrate fraudulent intent. His message published after the crash, in which he admitted having let Hayden Davis act, did not prove that he wanted to deceive buyers from the launch.
Finally, the disappearance of the RICO component deprived the court of the argument which allowed it to exercise national jurisdiction over Kelsier Ventures and the Davis family. The links presented to the State of New York were not sufficient to sustain the prosecution.
