On March 2, 2026, U.S. District Judge Katherine Polk Failla of the Southern District of New York threw out the final state-law claims in Risley v. Universal Navigation Inc., ending a nearly four-year class action tied to so-called “scam tokens” traded on the Uniswap protocol. The ruling closes the book on a lawsuit that sought to hold the protocol’s creators liable for investor losses tied to rug pulls and pump-and-dump schemes carried out by anonymous third parties.

The case began in April 2022, when lead plaintiff Nessa Risley and other investors alleged they lost money trading 38 fraudulent tokens through Uniswap’s web interface between April 5, 2021, and April 4, 2022. The defendants included Uniswap Labs — formally Universal Navigation Inc. — and Hayden Adams, its founder and CEO.

Plaintiffs argued that by designing and promoting the decentralized exchange and collecting fees, the company effectively facilitated unregistered securities sales and enabled widespread fraud. They also targeted venture backers in earlier pleadings, though those defendants were later dismissed.

Judge Failla had already dismissed federal securities claims in August 2023, concluding Uniswap’s developers were not “statutory sellers” under federal law and that the protocol’s smart contracts were lawful tools capable of facilitating both commodity and token trades. The U.S. Court of Appeals for the Second Circuit affirmed that dismissal in February 2025, but remanded the case for consideration of state-law claims.

Following remand, plaintiffs refashioned their complaint, focusing on aiding and abetting fraud, negligent misrepresentation, violations of consumer protection statutes in New York, North Carolina, and Idaho, and unjust enrichment. On Monday, Failla dismissed those claims with prejudice, finding the amended complaint still failed to plausibly allege liability.

“Despite three chances to get it right, Plaintiffs remain unable to allege plausible claims,” Judge Failla’s ruling states.

Central to the court’s reasoning was the absence of actual knowledge. To state an aiding-and-abetting fraud claim under New York law, plaintiffs had to show the defendants had actual knowledge of the underlying fraud and provided substantial assistance. The court found neither.

Allegations that Uniswap received complaints after losses occurred did not establish contemporaneous knowledge. General warnings on social media about scam tokens were insufficient. Even a March 2022 study alleging high rates of fraudulent token launches did not demonstrate that Uniswap knew about the specific tokens at issue during the relevant period.

The court also rejected the argument that merely providing a platform constituted “substantial assistance.” Drawing comparisons to traditional exchanges and financial institutions, Failla wrote that creating access to a marketplace — even one where bad actors operate — does not equate to participating in fraud. The identities of the token issuers remained unknown, and the complaint repeatedly acknowledged that the issuers’ own misrepresentations caused the losses.

Consumer protection claims fared no better. The court found no materially misleading statements by Uniswap Labs and noted that public blog posts and terms of service warned users about the risks of scam tokens. The alleged omissions were not information uniquely held by the company and unavailable to users.

As for unjust enrichment, plaintiffs failed to plausibly allege that Uniswap Labs directly profited from the transactions at issue during the class period. The protocol’s optional fee switch was never activated, and an interface fee implemented in October 2023 fell outside the relevant timeframe.

In dismissing the complaint in full, the court signaled a continued reluctance by federal courts to extend liability to open-source protocol developers absent direct involvement in misconduct. The opinion emphasizes that grievances about regulatory gaps in decentralized finance may be better addressed by Congress than through expansive judicial interpretation.

Supporters of the decision argue it protects innovation in permissionless systems, where software developers do not control user conduct. “Uniswap wins another case that sets a new legal precedent,” Adams wrote on X. “If you write open source smart contract code, and the code is used by scammers, the scammers are liable, not the open source devs. Good, sensible outcome,” he added.

“Another day, another precedent-setting ruling for DeFi,” Brian Nistler, the General Counsel of the Uniswap Foundation, posted on Monday. “The Federal charges had previously been dismissed, and today the various state claims are dismissed.”

For now, the ruling stands as a clear statement from a New York federal court: designing decentralized infrastructure is not, by itself, the same as orchestrating fraud. Whether plaintiffs pursue another appeal remains to be seen, but after multiple rounds of amendments and appellate review, the legal runway appears short.

• What did the New York federal court decide in the Uniswap case?
  A judge dismissed all remaining state-law claims against Uniswap Labs and its CEO with prejudice, ending the class action.
• Why did the court reject aiding-and-abetting fraud claims?
  The court found no plausible allegations that Uniswap had actual knowledge of specific scams or substantially assisted the fraud.
• Did the court find Uniswap responsible for scam tokens?
  No, the ruling states that providing decentralized infrastructure does not make developers liable for third-party misconduct.
• What does this mean for decentralized finance in the U.S.?
  The decision reinforces judicial limits on holding open-source protocol developers liable, leaving broader regulatory changes to Congress.

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