RICO is the 1970 federal statute written for prosecuting the mafia. The civil half lets private plaintiffs sue anyone who ran an enterprise through a pattern of criminal acts, and it pays triple damages. It also allows service on defendants anywhere in the country, which is how Hurlock and Mehta sought to reach Kelsier, a Texas-registered firm, and the three Davises in a New York court.
Mehta received $M3M3 in a Dec. 4, 2024 airdrop and sold out on Feb. 17 and 18, 2025 at a net loss of about $19,164. Hurlock bought and sold $LIBRA on Feb. 14, 2025, the day of the launch, losing about 0.302 wrapped $SOL. The complaint does not say what that was worth in dollars.
Six Months Is Not Enough
The RICO counts failed on continuity, the element that separates a pattern of racketeering from a one-off scheme.
Closed-ended continuity requires predicate acts over a substantial period. The alleged enterprise ran from October 2024 to the filing of the complaint on March 17, 2025. “Six months is not sufficient to demonstrate a ‘substantial period of time,'” Rochon wrote, citing Second Circuit precedent that has never found a period under two years enough.
The plaintiffs argued that the complexity of two separate schemes and the number of victims made up for the short window. Rochon weighed those factors and found they cut the other way: one enterprise, five defendants, a single alleged goal, and wire fraud as the only predicate act.
Open-ended continuity failed because the complaint alleged that Kelsier and Meteora were primarily legitimate businesses, and because wire fraud is not inherently unlawful conduct that implies a threat of repetition. With no substantive RICO claim, the RICO conspiracy count fell with it.
Calling It a Team
Dynamic Labs Limited, which intervened in the case in October 2025, argued that Meteora is software and has no legal existence to sue or be sued. Rochon did not decide whether Meteora is software. She held that Hurlock and Mehta failed to plead it as an unincorporated association or a partnership, which is all the capacity question requires.
Under New York law, a suit against an unincorporated association must name its president or treasurer. The complaint named neither, and alleged neither role. Under the federal definition, an unincorporated association is a voluntary group formed by mutual consent to promote a common objective. The plaintiffs identified members including Chow, Ming Yeow, Zhen Hoe Yong, Siong Ong, Raccoon Labs, Block Raccoon and Dynamic Labs, but did not allege how that group consented to associate.
Their main evidence of joint control was the 4-of-7 multisig holding upgrade authority over Meteora’s programs, which they compared to a seven-member board of directors. “That Meteora code can be updated by a majority of the authorized wallet holders is not ‘analogizable to a 7-member Board of Directors,'” Rochon wrote. Job postings and social media announcements from a “Meteora team” did not establish coordination among members either.
The partnership theory failed on profit sharing, joint control, contributions and intent. Rochon quoted a New York court: “calling an organization a partnership does not make it one.”
All claims against Meteora were dismissed without the court reaching Dynamic Labs’ remaining arguments.
Profit Is Not Motive
Chow, who resigned as Meteora CEO in February 2025, was the only defendant who did not challenge the court’s jurisdiction over him. His motion to dismiss was granted on every count.
The fraud claims failed Rule 9(b)’s scienter standard. The plaintiffs pointed to Chow’s statement on a launch planning call that “no one will play the game if they see, like 90% of the supply already locked up,” to a calculation template he built, and to a post-collapse admission that he “fucked up because [he] enabled” Davis.
Rochon found the only motive alleged was profit. “[P]rofit motive does not provide the requisite inference of fraudulent intent,” she wrote, including when the profit comes as transaction fees. Opportunity without motive is not enough.
The conspiracy count was dismissed because the underlying fraud claims were. The New York General Business Law count over $M3M3 was dismissed because the complaint did not allege consumer-oriented conduct in New York, and the $LIBRA count because it did not allege materially misleading conduct by Chow. The unjust enrichment counts were dismissed as duplicative of the fraud claims.
No Hook for Jurisdiction
Once RICO was gone, so was the plaintiffs’ basis for reaching the Davis family in New York.
RICO’s service provision, 18 U.S.C. § 1965, and Rule 4(k)(2) both depend on a viable federal claim. With the only federal count dismissed, neither applied. New York’s long-arm statute did not reach Kelsier, Hayden Davis, Gideon Davis or Charles Thomas Davis on the facts pleaded, and the conspiracy theory of jurisdiction collapsed with the conspiracy claim against Chow.
Rochon dismissed the remaining state law claims against the Kelsier defendants under Rule 12(b)(2) without reaching their arguments on the merits.
Leave to Amend Denied
The plaintiffs had moved in October 2025 to file a second amended complaint adding $MELANIA, $ENRON and $TRUST, a third plaintiff, Dynamic Labs Limited as a defendant, and 20 Doe defendants.
Rochon denied the motion as futile. The proposed complaint gave no launch dates for $MELANIA or $ENRON and put $TRUST in April 2025, extending the alleged racketeering window by one month. “[A] period of seven months is not sufficient for a closed-ended pattern of racketeering,” she wrote. The amended Meteora allegations, the new scienter allegations against Chow and the new unjust enrichment claim against Dynamic Labs Limited all failed for the same reasons as the originals.
Because every proposed amendment was futile, the amended complaint was dismissed with prejudice and the clerk was directed to close the case.
What the Complaint Alleged
Taken as true for the motions, the allegations describe coordinated extraction around both launches.
For $M3M3, insider wallets funded by the Kelsier defendants bought while the launch pool was frozen, then sold into retail demand between Dec. 5 and 6, 2024. Fully diluted market value briefly passed $150 million on Dec. 6 before the price fell more than 90% from $0.15.
For $LIBRA, one billion tokens were minted about a minute after the 4:37 p.m. launch on Feb. 14, 2025. Argentine President Javier Milei posted support 23 minutes later, linking the project website and the token address, and deleted the post at 10:38 p.m. Between Feb. 14 and 16, intermediary wallets pulled 44,593,888 $USDC out of the LIBRA/$USDC pool, according to the complaint, alongside about 249,665 $SOL sent to three receiving wallets from the LIBRA/$SOL pools. The average position lasted under 10 minutes.
What Davis made has not been established. The case ended at the pleading stage, with no discovery and no forensic accounting, and the complaint pleads wallet flows rather than a total attributable to any defendant. In a video statement on Feb. 15, 2025, Davis said he had “managed to round up” “every single dollar that’s been collected, or from fees or farming, or liquidated,” and that he intended to “inject everything back into the libra chart” within 24 to 48 hours. A press release the same day said he “was responsible for ensuring liquidity for the project and still maintain control over all associated fees and treasury funds.” Neither statement gave a figure.
What Is Still Live
Burwick Law, which filed the case in New York state court in March 2025 before it was removed to federal court, had won a temporary restraining order in May 2025 freezing about $110 million in $LIBRA proceeds and 57,654,371 $USDC. Circle froze the stablecoins that month, and the freeze was lifted in August 2025. No notice of appeal had been docketed as of Sept. 30.
The Argentine criminal investigation runs separately. Federal judge Marcelo Martínez de Giorgi ordered the identification and freezing of 25 LIBRA-linked wallets across Binance, Bybit, OKX and Bitfinex in July. Thursday’s dismissal does not touch it.
