Judge Dismisses LIBRA Memecoin Class Action With Prejudice

A federal judge has dismissed the class action over the LIBRA and M3M3 memecoin launches, closing the case with prejudice after rejecting the plaintiffs' request to amend their complaint again. Judge Jennifer L. Rochon of the Southern District of New York granted the defendants' dismissal motions on Sept. 29 in Hurlock v. Kelsier Ventures, No. 1:25-cv-03891, and directed the clerk to close the case, CryptoSlate reported on Oct. 3. CryptoAdventure published the same case number and date on Oct. 1.

The defendants included Kelsier Ventures and Hayden Davis, former Meteora chief executive Benjamin Chow, and the Meteora protocol itself. The plaintiffs, Omar Hurlock and Anuj Mehta, alleged that insiders controlled the token launches and drained liquidity pools at the expense of outside buyers.

The central federal claim relied on the Racketeer Influenced and Corrupt Organizations Act, known as RICO. That law requires a pattern of related acts that either spans a long period or shows a continuing threat of criminal activity. The court found the plaintiffs proved neither.

For the first path, the opinion treated the alleged conduct from October 2024 through the March 2025 complaint as roughly six months. Multiple schemes and a large group of alleged victims did not overcome the short span, since Second Circuit precedent generally demands a longer period for this kind of continuity. CryptoSlate described the six-month finding in its account of the opinion.

The second path required facts showing a continuing threat. Broad claims about a repeatable token launch business and referrals to other projects did not show, defendant by defendant, that alleged wire fraud was a regular business practice. The related conspiracy claims failed with the main RICO claim.

Claims against Chow failed on separate grounds. The court held that the allegations did not sufficiently establish fraudulent intent. A statement from an M3M3 planning call was consistent with legitimate support for a token launch, and the chance to earn money from the project was not enough by itself to prove intent to defraud, according to the CryptoAdventure account of the ruling.

Chow's lawyers at Cahill Gordon and Reindel said the court adopted their arguments when it granted his dismissal motion on Sept. 29. The firm noted the win followed an earlier defeat of the plaintiffs' request to freeze Chow's assets last year.

Meteora also left the case. The plaintiffs had not plausibly shown the protocol was an unincorporated association or partnership capable of being sued. Bitcoin.com wrote that Dynamic Labs argued Meteora was only software and could not be sued, and the court agreed the pleading fell short.

The remaining state law claims against the Kelsier defendants were dismissed for lack of personal jurisdiction. Allegations about nationwide social media activity and crypto infrastructure did not establish the New York contacts needed to keep those claims in the Southern District. The court did not reach their merits.

The case combined two token episodes. M3M3 launched on the Meteora platform in December 2024, and LIBRA, a Solana token, launched on Feb. 14, 2025. Argentine President Javier Milei promoted LIBRA on X that day and withdrew his support hours later, the CryptoSlate account says. The complaint said LIBRA's launch was covertly structured so insiders could extract funds once outside buyers arrived.

Estimates cited by Bitcoin.com put the number of affected investors above 44,000. Milei later denied responsibility for the losses, comparing memecoin trading to a casino trip and saying traders knew the risk they were taking.

The litigation once 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, CryptoAdventure noted in its report.

Investors also tried to widen the case. The proposed second amended complaint would have added the MELANIA, ENRON, and TRUST tokens, another plaintiff, and new defendants. The judge found the expansion stretched the alleged racketeering period to only seven months and fixed none of the continuing threat defects, so she denied it.

With the dismissal, the LIBRA matter appears closed in the United States unless other parties bring new claims. In Argentina, two deputies tried to join the local LIBRA case as plaintiffs and had the request rejected by a Buenos Aires federal court, Bitcoin.com reported.

The order decides only the legal sufficiency of the claims and the court's jurisdiction. It makes no finding that every alleged act was lawful, and it leaves any other recovery route outside this district court case untouched.