New York judge dismisses LIBRA, M3M3 class action, rejects amended complaint

  • Judge Jennifer L. Rochon dismissed the LIBRA and M3M3 class action with prejudice.
  • The court found the alleged six-month enterprise lacked a RICO pattern.
  • The ruling left alleged token extraction and insider activity unresolved before discovery.

US District Judge Jennifer L. Rochon dismissed with prejudice the amended complaint in Hurlock v. Kelsier Labs, ending a New York class action over the LIBRA and M3M3 memecoins against Meteora, former Meteora CEO Benjamin Chow, Kelsier Labs, trading as Kelsier Ventures, and Hayden Davis. The 81-page ruling, issued on September 29, 2025, also denied leave to file a second amended complaint that would have added MELANIA, ENRON and TRUST token claims, additional defendants and a new plaintiff. The court found that the alleged six-month enterprise did not establish the sustained pattern required for RICO, that fraud allegations against Chow did not adequately show fraudulent intent, and that Meteora was not sufficiently pleaded as an unincorporated association capable of being sued. Claims against Kelsier Labs, Hayden Davis, Gideon Davis and Charles Thomas Davis were also dismissed for lack of New York personal jurisdiction where applicable. The decision addressed the legal adequacy of the complaint, the forum and the defendants named; it did not determine whether alleged insider activity or token extraction surrounding the LIBRA and M3M3 launches occurred. Separately, Bubblemaps said in March 2025 that wallet activity connected to the WOLF memecoin rug pull led to Hayden Davis, while a consumer suit over Magic Eden's ME token was dismissed after its wallet terms waived class actions. Drift Protocol's recovery claims process for users affected by its April 1 hack similarly requires participants to waive claims against the protocol.

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