$HAWK TUAH Token Lawsuit: In Re $HAWK Token Securities Litigation
$HAWK token class action by Burwick Law against Hawk Tuah promoters, Memetic Labs, Meteora, and others. Consumer protection.
A class action complaint is pending in the United States District Court for the Eastern District of New York, captioned In Re $HAWK Token Securities Litigation, Case No. 1:24-cv-08650-AMD-JRC, alleging that the defendants orchestrated a coordinated scheme to market and sell the $HAWK cryptocurrency token using the celebrity of Haliey Welch, known publicly as the Hawk Tuah Girl, to extract millions of dollars from retail purchasers. The amended complaint names numerous defendants: Alex Larson Schultz, Solana Sweeper, and their company Memetic Labs LLC, which provided advisory and launchpad services for the token; overHere Limited and its founder Clinton So, which ran the pre-sale and promotional campaign; Tuah The Moon Foundation, a Cayman Islands entity created to receive sale proceeds; Benjamin Chow and Meteora, the trading platform that displayed misleading safety indicators; Dynamic Labs Limited; Johnnie Forster, Welch’s manager; 16 Minutes LLC, Welch’s operating entity; Welch herself; and Doe Defendants 1 through 10.
According to the complaint, on July 18, 2024, Memetic Labs and 16 Minutes LLC executed a “Meme Token Creation and Monetization Agreement” that formalized Welch’s promotional role in the $HAWK launch. Under that agreement, Welch received $125,000 up front and was promised an additional $200,000 upon meeting promotional milestones, while Memetic Labs received a 50% lifetime profit share tied to trading activity. The agreement allegedly contained no provisions for developing any of the utilities publicly advertised to purchasers, including podcast integrations, gaming features, and subscription tiers. Memetic Labs was also granted full access to Welch’s Twitter account to draft and publish promotional posts in her voice.
The complaint alleges that Defendants designed the $HAWK token with an extremely thin public float of approximately 3.3% of total supply, allocated 17% of the supply to insider wallets with no lockups, and pre-funded a sniper wallet through pseudonymous addresses tied to prior token schemes. The token launched on December 4, 2024. Seconds after liquidity was added, the sniper wallet allegedly captured roughly half the public float in the first block. Insiders then executed a series of liquidity-removal transactions through Meteora’s platform, draining approximately $1.27 million. Despite Meteora displaying a “Permanently locked” badge on the liquidity pool, the complaint alleges that insiders retained full control and removed liquidity as retail activity peaked. The price of $HAWK collapsed more than 97% from its peak. The same wallet clusters allegedly participated in similar schemes involving other tokens, including LIBRA, M3M3, AIAI, and the TRUMP token.
The amended complaint asserts six causes of action: sale of unregistered securities under Sections 5 and 12(a)(1) of the Securities Act, common law fraud, deceptive acts and practices under New York General Business Law § 349, false advertising under New York General Business Law § 350, breach of contract (including breach of the implied covenant of good faith and fair dealing), and unjust enrichment. The complaint seeks rescission or rescissory damages, compensatory and statutory damages, disgorgement, injunctive relief, and certification of a class of all persons who purchased $HAWK tokens during the period from November 26, 2024 through the present.
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