Judge Tosses Milei-Linked LIBRA Memecoin RICO Suit

A U.S. district judge in Manhattan dismissed with prejudice the amended class action against LIBRA and M3M3 memecoins on Sept. 29, ending the case in the Southern District of New York. Judge Jennifer L. Rochon ruled the plaintiffs did not meet the legal requirements for a RICO claim and denied further amendment of the complaint.

The central federal claim invoked the Racketeer Influenced and Corrupt Organizations Act. The court said plaintiffs had not plausibly alleged the continuity element required for a RICO “pattern.” The complaint described token launches and alleged siphoning of liquidity from outside investors in a period the court treated as roughly October 2024 through March 2025. Under Second Circuit precedent cited by the court, that span and the mix of separate schemes and broadly described victims did not establish the temporal continuity RICO requires. The alternative theory — that the conduct posed a regular ongoing threat — failed because the complaint lacked specific facts showing each defendant ran a repeatable fraud-as-business practice.

Plaintiffs sought leave to amend to add three tokens — MELANIA, ENRON and TRUST — another plaintiff and new defendants. The judge denied that request, finding the proposed additions would extend the alleged racketeering period only to about seven months and would not cure the absence of facts tying a continuing threat to each defendant.

After rejecting the RICO claims, the court dismissed remaining state-law claims against the Kelsier defendants for lack of personal jurisdiction. The opinion said general allegations of nationwide social media activity and use of crypto infrastructure did not show the specific New York connections required to sue Kelsier Ventures and related entities in the Southern District. Claims against individual defendant Benjamin Chow were dismissed for pleading defects, including insufficient allegations of fraudulent intent. Claims targeting Meteora were dismissed because plaintiffs did not plausibly allege it existed as a legal association or partnership subject to suit.

The dismissal was entered with prejudice and the SDNY case was closed. The court did not decide whether the underlying conduct was lawful or unlawful and noted that other legal avenues were not addressed in the opinion.