A federal judge in New York has dismissed the class action against Hayden Davis, Kelsier Labs, Benjamin Chow, and Meteora over the LIBRA and M3M3 memecoin launches, closing the case with prejudice after rejecting the plaintiffs' latest attempt to amend their complaint.

U.S. District Judge Jennifer L. Rochon granted the defendants' motions to dismiss on September 29 in Hurlock v. Kelsier Ventures, No. 1:25-cv-03891. A dismissal with prejudice operates as a final judgment on the claims raised, barring the plaintiffs from refiling them in federal court. She also denied leave to file a second amended complaint and directed the clerk to close the case.

The litigation had combined allegations surrounding the M3M3 launch with claims tied to LIBRA, the Solana token promoted by Argentine President Javier Milei in February 2025 shortly before its price collapsed.

RICO Claims Fail on Continuity

The civil RICO claims against Kelsier Labs, Hayden Davis, Gideon Davis, and Charles Thomas Davis failed because the alleged conduct did not establish the pattern of continued racketeering required by the statute. Congress built RICO around long-running criminal enterprises and Supreme Court precedent reads closed-ended continuity as requiring predicate conduct that stretches over a few years rather than weeks or months.

The plaintiffs described an enterprise operating for roughly six months. The court found that period insufficient to establish closed-ended continuity, and the allegations likewise failed to show a continuing threat of future racketeering activity.

The remaining claims against the Kelsier defendants were dismissed for lack of personal jurisdiction in New York, a due process threshold that requires sufficient minimum contacts with the forum state. Blockchain transactions passing through U.S. infrastructure and validators did not establish the New York-specific contacts required to keep those claims in the Southern District.

The ruling ends a case that previously produced a temporary freeze on $57.65 million in USDC tied to LIBRA proceeds. That restraint was later dissolved after Rochon denied the request for a preliminary injunction.

Fraud Claims Against Chow Also Dismissed

The claims against former Meteora CEO Benjamin Chow failed separately under the federal pleading standard, which Supreme Court precedent has tightened to demand allegations that make misconduct plausible rather than merely conceivable. The allegations surrounding Chow's involvement in M3M3 did not sufficiently establish fraudulent intent.

A statement cited from an M3M3 planning call was compatible with legitimate support for a token launch, and the prospect of earning money from the project was not enough on its own to establish the required intent to defraud.

The lawsuit later expanded its allegations beyond M3M3 and LIBRA, accusing Chow and Kelsier of participating in a wider series of token launches linked to public figures. That expanded theory did not survive the court's review.

Meteora also exited the case after the plaintiffs failed to plausibly plead that the protocol was an unincorporated association capable of being sued. Dynamic Labs had intervened to challenge that characterization, maintaining that Meteora is software deployed through permissionless smart contracts rather than a separate legal association. The dispute turned on a question that recurs in crypto litigation: whether a DeFi protocol built from permissionless smart contracts can be treated as a sueable legal entity.

Rochon denied another amendment that would have extended the allegations to the MELANIA, ENRON, and TRUST tokens. The September 29 order states that the amended complaint is dismissed with prejudice and closes the federal case.