Judge Failla dismissed the Risley class action against Uniswap Labs with prejudice on March 2, setting a new legal precedent for DeFi open-source developers.
Judge Katherine Polk Failla of the Southern District of New York dismissed all remaining claims in the Risley class action against Uniswap Labs on March 2, 2026. The dismissal came with prejudice. Every count is gone. No path back to court.
The lawsuit was filed in April 2022 by five plaintiffs who claimed losses on 38 scam tokens traded through Uniswap’s interface. Rug pulls, pump and dumps, losses running through the protocol during a class period from April 5, 2021, to April 4, 2022. The scammers behind the tokens were never identified. So plaintiffs went after Uniswap Labs and founder Hayden Z. Adams instead.
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Scammers Liable. Builders Are Not.
Uniswap founder Hayden Adams responded immediately after the ruling. According to haydenzadams on X, the case sets a new legal precedent for open-source development in crypto. His position was direct: when scammers use open-source smart contract code to defraud investors, the scammers carry the liability, not the developers who wrote the code. He described the outcome as good and sensible.
Crypto legal commentator N0th1n3 put it in sharper terms. As N0th1n3 posted on X, this was another precedent-setting ruling for DeFi, and the logic running through it has not changed since the first dismissal in 2023. The court’s own language from that earlier ruling resurfaced here. Plaintiffs still could not hold defendants liable for the “misconduct of the unidentified third-party issuers” simply because Uniswap provided a marketplace. N0th1n3 cited a line from Risley I that reappears in this ruling: that it “defies logic” to hold a smart contract drafter responsible for a third party’s misuse of a platform.
The full court opinion is accessible via CourtListener. That logic held across three complaints and four years of litigation.
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Three Complaints. Zero Claims Survived.
Federal securities claims fell first. The court dismissed those in August 2023 in Risley I, and the Second Circuit upheld that call in February 2025. The appellate court sent state law claims back down for a proper first review. Those, too, are now gone.
The Second Amended Complaint shifted away from federal securities law entirely. It pushed six state-law claims: aiding and abetting fraud, aiding and abetting negligent misrepresentation, consumer protection violations under New York, North Carolina, and Idaho statutes, and unjust enrichment. All six failed.
On the fraud aiding and abetting count, plaintiffs never adequately showed that Uniswap Labs had actual knowledge of specific scams at the time they were happening. User complaint emails arrived after purchases were already made. Social media warnings targeted other investors, not defendants. A March 2022 report citing widespread rug pulls landed too late in the class period and said nothing specific about the 38 tokens named in the complaint.
Substantial assistance failed on equally firm ground. The court drew the same line courts have drawn before with banks and messaging platforms. Running a service that bad actors exploit is not the same as helping those actors commit fraud. The judge pointed directly to the U.S. Supreme Court’s Twitter v. Taamneh ruling to reinforce it.
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State Claims Fell on Deception, Causation, and Enrichment
Consumer protection claims under three state laws collapsed on three separate grounds.
Deception first. Plaintiffs pointed to a Discord bot response stating Uniswap could not prevent scam coins from trading. The court found that statement accurate, not misleading. Labs had published a 2020 blog post acknowledging publicly that filtering scams from legitimate tokens was growing harder. That post was a warning to users. Its Terms of Service carried similar disclosures, available throughout the class period.
Causation broke next. The Second Amended Complaint itself, across more than 450 paragraphs, repeatedly tied plaintiffs’ losses to the issuers’ own misrepresentations and omissions. Plaintiffs’ own language broke the causal chain between Uniswap’s conduct and their damages.
Unjust enrichment collapsed entirely. Labs never activated the fee switch that would have routed protocol transaction fees to itself during the class period. The interface fee only launched in October 2023, well outside the relevant window. No enrichment, no claim.
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The Clerk of Court has been directed to terminate all pending motions and close the case. For DeFi developers, the ruling draws a line courts have now held at every level. Writing open-source code that others misuse does not make a developer liable for those misuses. The scammer holds the liability. Not the protocol. Not the interface. Not the engineer who built the tools.
