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Judge Lets Aiding-And-Abetting Claim Survive in Celsius Suit Against Chainalysis

A U.S. federal judge dismissed 15 of 16 claims against Chainalysis in the Celsius bankruptcy estate's lawsuit, allowing one aiding-and-abetting breach of fiduciary duty claim tied to a disputed $3.3 billion 2020 'audit' to proceed.

Outputs

  1. U.S. District Judge Margaret Garnett dismissed 15 of 16 claims against Chainalysis in a Tuesday ruling, leaving one aiding-and-abetting breach of fiduciary duty count alive.

  2. Twelve claims were dismissed with prejudice; three consumer-protection claims were dismissed without prejudice, with an Oct. 20 deadline for plaintiffs to amend or drop them.

  3. The dispute centers on a Dec. 9, 2020 Celsius press release describing a ~$3.3 billion 'audit' using Chainalysis Reactor software; the complaint alleges an initial calculation of ~$1.18 billion before methodology changes.

  4. Celsius froze customer withdrawals in June 2022 and filed for Chapter 11 in July 2022, leaving roughly $4.7 billion in assets inaccessible.

  5. BRIC, the Blockchain Recovery Investment Consortium, brought the suit as litigation administrator for the Celsius estate and certain former customers.

A U.S. federal judge has dismissed 15 of 16 claims against blockchain analytics firm Chainalysis in litigation tied to collapsed crypto lender Celsius Network, leaving one aiding-and-abetting accusation alive in a case built around a contested $3.3 billion "audit."

U.S. District Judge Margaret Garnett of the Southern District of New York issued the ruling Tuesday, finding the complaint "sufficiently alleged" that Chainalysis knew a December 2020 Celsius press release contained false statements and helped disseminate them, according to the order.

Celsius filed for Chapter 11 protection in July 2022, a month after freezing customer withdrawals and leaving roughly $4.7 billion in assets inaccessible during the crypto market downturn. The Blockchain Recovery Investment Consortium (BRIC), which serves as the estate's litigation administrator and recovery manager, brought the suit to recover funds for creditors.

What does the surviving claim allege?

The only count that survived Chainalysis' motion to dismiss is the aiding-and-abetting breach of fiduciary duty claim. Judge Garnett ruled the plaintiffs put forward enough specific factual allegations — including that Chainalysis helped draft, edit and approve the 2020 press release — to support the claim at this preliminary stage.

Chainalysis declined to comment on the ruling. A representative for the Celsius litigation administrator did not respond before publication.

Why were the other claims thrown out?

Judge Garnett dismissed 12 claims with prejudice, foreclosing plaintiffs from re-pleading them in this case. She also dismissed three consumer-protection counts without prejudice. BRIC has until Oct. 20 to amend those three claims or inform the court it will stand down. The with-prejudice dismissals carry the most weight, because they cut off the plaintiffs' ability to relitigate those theories here and narrow the case sharply.

What is the $3.3 billion audit dispute?

The lawsuit centers on a Dec. 9, 2020 Celsius press release announcing an "audit" that confirmed approximately $3.3 billion in Celsius assets. The calculation, performed with Chainalysis' Reactor software, was based on transactions, total deposits and total withdrawals since Celsius launched its yield service in 2018.

According to the complaint as summarized by the court, a Celsius executive first calculated around $1.18 billion in assets under management using Reactor before changes to the methodology roughly tripled the figure to $3.3 billion. The plaintiffs allege Celsius and Chainalysis then packaged the result as an "audit" and "independent verification" despite knowing that characterization did not match what Reactor actually produced.

Chainalysis had argued the complaint failed on the merits and should be dismissed in full. The court's split ruling preserves only the theory that Chainalysis assisted Celsius insiders in breaching their fiduciary duties by helping circulate the disputed figures.

What's next in the case?

With discovery still ahead on the surviving count, BRIC faces an Oct. 20 deadline to either amend the three tossed consumer-protection claims or drop them. Chainalysis retains the right to test the surviving claim at summary judgment and to revisit dismissed counts on appeal, where the litigation administrator's narrower path now runs through a single aiding-and-abetting theory rather than a broader assault on the analytics vendor.

via docs.justia.com (Original)

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Marcus Bennett

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Senior reporter covering business strategy at Mempool Brief.

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