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SDNY Judge Dismisses Uniswap Scam-Token Class Action With Prejudice

The ruling says open-source protocol authors aren’t liable for scams by unidentified token issuers.

Overview

  • U.S. District Judge Katherine Polk Failla threw out the second amended complaint in Risley v. Universal Navigation, effectively ending the case at the district-court level.
  • The court found the alleged scam-token issuers were "basically unknown and unknowable," rejecting efforts to shift responsibility from anonymous actors to protocol developers.
  • Plaintiffs failed to plausibly allege actual knowledge, deceptive conduct under state consumer laws, or unjust enrichment, and providing a marketplace did not amount to substantial assistance of fraud.
  • The decision clears Uniswap Labs, CEO Hayden Adams, the Uniswap Foundation, and venture backers Paradigm, Andreessen Horowitz, and Union Square Ventures.
  • Uniswap’s UNI token rose roughly 5–6% after the decision, while legal observers cautioned the opinion does not confer blanket immunity and that centralized chokepoints could still face future rules or enforcement.