$M3M3 and $LIBRA Token Lawsuit: Hurlock v. Kelsier
Burwick Law filed a class action against Meteora, Kelsier Ventures, and Hayden Davis over $M3M3 and $LIBRA token launches on Solana.
On April 19, 2025, a class action complaint was filed in the United States District Court for the Southern District of New York, captioned Hurlock v. Kelsier Labs, LLC, Case No. 1:25-cv-03891-JLR, on behalf of investors who purchased $M3M3 tokens or $LIBRA tokens on the Solana blockchain. An amended complaint was filed on July 29, 2025. The defendants are Kelsier Labs LLC (doing business as Kelsier Ventures), its CEO Hayden Mark Davis, Gideon Davis, Charles Thomas Davis, Benjamin Chow, and Meteora, the decentralized finance protocol on Solana through which both token launches were conducted.
The amended complaint alleges that Chow, the then-CEO of Meteora, and the Davis family, operating through Kelsier Ventures, formed a secret partnership to manipulate memecoin launches on Meteora’s protocols and extract capital from retail investors. According to the complaint, $M3M3 was marketed in December 2024 as the debut token of Meteora’s new “stake-to-earn” platform, promising holders passive income from transaction fees. The complaint alleges that before trading opened to the public, defendants froze the token and allowed approximately 150 insider wallets, funded by Kelsier, to acquire over 95% of the supply at artificially low prices. Once trading was enabled, the complaint alleges, defendants inflated the price through artificial volume and then sold their holdings into the market, causing the price to collapse.
The complaint alleges that defendants repeated this approach with $LIBRA in February 2025, this time claiming the token was tied to an Argentine government initiative endorsed by President Javier Milei. According to the complaint, no legitimate project existed beyond a website created hours before launch. Using Meteora’s Dynamic Liquidity Market Maker (DLMM), the complaint alleges that defendants built one-sided liquidity pools with manipulated price curves, extracting over $57 million in USDC and SOL from retail buyers within hours. The complaint further alleges that defendants retained hidden upgrade authority over Meteora’s smart contracts through a multisig wallet under their exclusive control, allowing them to reconfigure pools, freeze trading, and route fees to insider wallets while publicly describing the system as decentralized.
The amended complaint asserts claims for common law fraud, conspiracy to defraud, violations of the Racketeer Influenced and Corrupt Organizations Act (RICO) under 18 U.S.C. §§ 1962(c) and (d), deceptive acts and false advertising under New York General Business Law §§ 349 and 350, and unjust enrichment. The complaint seeks compensatory damages, treble damages under RICO, disgorgement and restitution, a constructive trust over all proceeds traceable to the token launches, injunctive relief, the appointment of a receiver over Meteora and its smart contract infrastructure, and attorneys’ fees and costs.
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