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Court Dismisses LIBRA and M3M3 Class Action With Prejudice

Judge Jennifer Rochon dismissed the LIBRA and M3M3 class action with prejudice, ruling six months of memecoin launches cannot sustain a RICO claim and Meteora was never pleaded as a suable entity.

Outputs

  1. Judge Jennifer Rochon dismissed the LIBRA and M3M3 class action with prejudice.

  2. The court ruled six months of memecoin launches cannot sustain a civil RICO claim.

  3. Plaintiffs never pleaded Meteora as an entity capable of being sued.

A federal judge has dismissed the class action tied to the LIBRA and M3M3 memecoins with prejudice, closing off the plaintiffs' attempt to pursue the case under civil RICO provisions.

Judge Jennifer Rochon ruled that a six-month span of memecoin launches cannot sustain a claim under the Racketeer Influenced and Corrupt Organizations Act, the statute the plaintiffs invoked to frame the token issuances as an organized scheme. The court also found that the plaintiffs never pleaded Meteora as an entity capable of being sued, a procedural defect that independently undermined the case against the Solana-based liquidity protocol.

The dismissal with prejudice means the court terminated the case on its merits rather than on curable technical grounds. The plaintiffs cannot simply refile an amended complaint in the same court. Any further attempt to litigate these claims would require appealing the ruling to a higher court or initiating a separate suit in a different jurisdiction, subject to procedural barriers such as claim preclusion.

The RICO ruling carries weight beyond this case. Civil RICO claims require plaintiffs to show a pattern of racketeering activity — conduct that extends beyond isolated or loosely connected acts. Judge Rochon's reasoning that roughly six months of memecoin launches do not amount to such a pattern sets a reference point for future plaintiffs who try to recharacterize token promotion campaigns as organized fraud under federal racketeering law.

The finding on Meteora addresses a separate and increasingly common question in crypto litigation: who, or what, is the defendant? Courts have repeatedly dismissed crypto cases at the pleading stage because plaintiffs name protocols, decentralized applications, or token projects without identifying a legal entity — a corporation, partnership, or individual — that can actually bear liability. Judge Rochon concluded the plaintiffs failed at this threshold step, leaving the claims against the protocol structurally defective regardless of their substance.

For defendants in the case, the ruling removes a significant legal overhang. For token issuers and decentralized finance platforms more broadly, it reinforces two lessons: courts will apply traditional entity-and-pattern requirements to crypto disputes rather than relaxing them, and plaintiffs who do not map their allegations onto a suable legal person will not survive a motion to dismiss.

The decision also narrows the practical avenues for investors seeking remedies after memecoin losses. Securities-fraud and consumer-protection theories remain available in appropriate cases, but the RICO route — often attractive because it offers treble damages — now faces a concrete judicial limit in this district when the alleged scheme consists of a sequence of short-lived token launches.

The plaintiffs' remaining option is an appeal to the U.S. Court of Appeals for the Second Circuit, where their lawyers would need to argue that Judge Rochon erred in her reading of the pattern requirement and of the pleading standards governing entity defendants. Absent an appeal, the case stands terminated and the defendants face no further exposure on these claims.

The ruling will likely shape how future class actions in the memecoin sector are drafted, pushing plaintiffs' counsel toward clearer entity identification and longer, more structured allegations of coordinated conduct before they file.

via The Defiant (Source)

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Elena Vasquez

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Staff writer covering marketplaces and e-commerce at Mempool Brief.

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