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A federal judge in Manhattan has just made a significant ruling for the DeFi space. Uniswap Labs and Hayden Adams won in a class action case that has been ongoing for nearly four years. The dismissal with prejudice means this is serious—plaintiffs can no longer bring the same claims.
The story began in April 2022 when investors named Nessa Risley and others felt harmed while trading 38 fraudulent tokens through the Uniswap platform between April 2021 and April 2022. They accused Uniswap Labs, officially Universal Navigation Inc., of intentionally facilitating unregistered securities sales and allowing scams to flourish. Judge Katherine Polk Failla dismissed the federal claims earlier in August 2023, and the appellate court confirmed this in February 2025, but sent the case back for consideration of state law claims.
This time, after the plaintiffs attempted again with an amended complaint, Judge Failla again said no. The core issue is knowledge. To prove aiding and abetting fraud under New York law, they need to show that Uniswap actually knew about the specific scam and provided material assistance. The court found no such evidence. Accepting a complaint after the harm occurred is not the same as knowledge at that time. Public social media posts about the scam tokens are not enough. Even a study claiming a high rate of scam token launches does not prove Uniswap knew about any specific token during the relevant period.
What’s interesting is how the judge compared this to traditional exchanges. Failla wrote that merely providing access to a market—even a market where bad actors operate—does not mean participating in the scam. The identity of the token issuers remains unknown, and the complaint itself admits that the scams were perpetrated by issuers causing the losses. For consumer protection claims, the court found no material misstatements from Uniswap Labs. Public blog posts and terms of service already warned users about the risks of scam tokens.
Regarding unjust enrichment, the plaintiffs failed to show that Uniswap Labs directly profited from the relevant transactions. The protocol’s fee switch was never activated, and the interface fees implemented in October 2023 are outside the period in question. This is a review of a clear court decision: building decentralized infrastructure is not inherently the same as facilitating scams.
Hayden Adams responded on X that this sets a new legal precedent. He wrote that if you write open-source smart contract code and scammers use that code, the scammers are responsible, not the open-source developer. Brian Nistler, General Counsel of the Uniswap Foundation, also commented that this is another historic decision for DeFi. The previous federal claims had already been dismissed, and now multi-state claims are also rejected.
This decision shows the ongoing reluctance of federal courts to extend liability to open-source protocol developers without direct involvement in wrongdoing. The court seems to suggest that regulatory issues in decentralized finance might be better addressed by Congress rather than through broad judicial interpretations. For the ecosystem, this means developers and builders have clearer legal protection when they are not actively facilitating scams. Whether the plaintiffs will appeal again remains uncertain, but after several rounds of amendments and appellate reviews, the legal path looks very narrow.