Judge Dismisses LIBRA and M3M3 Memecoin Class Action Against Meteora and Ben Chow

On 29 September 2026, US District Judge Jennifer L. Rochon of the Southern District of New York granted every motion to dismiss in Hurlock v. Kelsier Labs, the class action over the LIBRA and M3M3 memecoins that named Meteora MET$0.300-6.7%, former Meteora chief executive Benjamin Chow, Kelsier Labs (trading as Kelsier Ventures) and Hayden Davis as defendants. In the same opinion and order, she refused to let the plaintiffs file a second amended complaint that would have added the MELANIA, ENRON and TRUST tokens, wrote that "the Amended Complaint is dismissed with prejudice," and directed the clerk to close the case.

The ruling decides whether the complaint, read on its own terms, stated claims the law recognises. Judge Rochon did not find that the alleged conduct did or did not happen. Chow's lawyers at Cahill Gordon & Reindel described the result on 30 September as "a complete dismissal" for their client. As of 1 October, Meteora's official X account had posted about LP incentives and an upcoming event since the ruling but had not commented on it.

What the LIBRA and M3M3 class action alleged

Plaintiffs Omar Hurlock and Anuj Mehta filed in New York state court on 17 March 2025, and the defendants moved the case to federal court on 9 May 2025, according to the order. The amended complaint brought fraud, conspiracy to defraud, federal racketeering (RICO), New York consumer-protection and unjust-enrichment claims against all defendants.

As the court summarised the allegations, Chow and Meteora launched the M3M3 platform on 4 December 2024, and the defendants took an additional 85.2% of the M3M3 supply from what the complaint called an "otherwise covertly frozen" launch pool. LIBRA launched on 14 February 2025; Argentine President Javier Milei posted his support on X 23 minutes after it was minted. The complaint alleged that wallets linked to the launch extracted 44,593,888 USDC from the LIBRA/USDC pool between 14 and 16 February. None of these points was tested in court. We covered the market fallout from LIBRA in February 2025.

Why the RICO claims failed: six months of memecoin launches

A RICO claim needs a "pattern" of racketeering, and a closed pattern generally has to run for a substantial period. The plaintiffs alleged an enterprise operating from October 2024 to March 2025, and Judge Rochon held that "Six months is not sufficient to demonstrate a 'substantial period of time.'" She also rejected an open-ended pattern, writing that "Plaintiffs' own allegations demonstrate that Defendants are, or work for, legitimate businesses." The RICO and RICO-conspiracy counts were dismissed against Chow and the Kelsier defendants on that basis.

The fraud claims against Chow fell on intent. The court found a statement Chow made on an M3M3 launch-planning call "equally consistent with legitimate support of a token launch," and added that profit, the only motive alleged, "standing alone, is not enough to demonstrate fraudulent intent." Chow's reply to Milei's X post describing a conversation with Hayden Davis ("What changing the world looks like") did not support the LIBRA consumer-protection claim, because the plaintiffs did not allege it was false or materially misleading. The M3M3 consumer claim failed separately: Mehta, a Virginia resident, did not plausibly allege New York consumer-oriented conduct.

Meteora was not pleaded as an entity that can be sued

Meteora was named as "an unincorporated association." Dynamic Labs Limited, which the court describes as the British Virgin Islands developer and purported intellectual-property owner of the Meteora protocol, intervened and argued that Meteora is software. Judge Rochon held that the plaintiffs "have not sufficiently pleaded that Meteora is an unincorporated association capable of being sued under New York or federal law," and dismissed every claim against Meteora without reaching other arguments.

This is the part of the order with the most bearing on other DeFi protocols. The plaintiffs compared the wallet holders who can update Meteora's code to a board of directors, and the court answered that Meteora code being updatable "by a majority of the authorized wallet holders is not 'analogizable to a 7-member Board of Directors.'" The order also notes the plaintiffs dropped that theory in their proposed second amended complaint.

Kelsier Labs and Hayden Davis: claims dismissed for lack of New York jurisdiction

Kelsier Labs, Hayden Davis, Gideon Davis and Charles Thomas Davis won dismissal of the RICO counts for failure to state a claim. Everything else against them was dismissed because the court found no personal jurisdiction in New York, so it did not decide whether those state-law claims were adequately pleaded. The plaintiffs had pointed to "blockchain transactions processed substantially through U.S.-based validators"; the court held that "nationwide validators, cryptocurrency exchanges, and infrastructure" do not establish jurisdiction in New York specifically.

The order's only statement on prejudice is the closing line tying it to the denial of leave to amend. It does not separately discuss the claims dismissed on jurisdictional grounds, and a jurisdictional dismissal ordinarily decides where a defendant can be sued rather than whether the claim has merit.

Second amended complaint: MELANIA, ENRON and TRUST claims rejected as futile

The proposed second amended complaint, filed on 21 October 2025, would have added the three tokens, a new plaintiff who bought MELANIA and LIBRA, and new defendants including Ng Ming Yeow, Dynamic Labs Limited and 20 unnamed Does. Judge Rochon found every amendment futile. The proposed complaint gave no launch dates for MELANIA or ENRON and dated TRUST to April 2025, which stretched the alleged scheme by a month; "a period of seven months is not sufficient for a closed-ended pattern of racketeering," the order says.

The ruling follows Judge Rochon's August 2025 decision dissolving an asset freeze, when, according to Cahill, she said she was "extremely skeptical" about the plaintiffs' chances on the merits.

What the SDNY dismissal means for Meteora and Solana DeFi

Meteora is one of the main liquidity and token-launch venues on Solana. According to Meteora, its liquidity providers earned $140M in fees in the first half of 2026, a figure we reported from its August community call. Chow resigned from Meteora in February 2025, according to a separate April 2025 lawsuit over M3M3 reported by Bloomberg Law.

For Meteora and Chow, the 29 September order closes Hurlock v. Kelsier Labs in the Southern District of New York. It turns on how the claims were pleaded, where they were filed and who was named, and it leaves the facts of the LIBRA and M3M3 launches untested.