A federal judge in Manhattan has dismissed with prejudice all remaining claims against Uniswap Labs and CEO Hayden Adams, bringing a nearly four-year class action to an end. The case centered on losses tied to so-called scam tokens traded through the Uniswap protocol, and whether the protocol’s developers could be held liable for conduct carried out by anonymous third parties.
Case over after multiple rounds of litigation
In a March 2, 2026 ruling, 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. The lawsuit 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 were Uniswap Labs, formally known as Universal Navigation Inc., and founder and CEO Hayden Adams.
Plaintiffs argued that by designing and promoting the decentralized exchange and collecting fees, the company enabled unregistered securities sales and widespread fraud. Earlier versions of the complaint also named venture backers, though those defendants were later dismissed from the case.
Court found no actual knowledge and no substantial assistance
The federal securities claims had already been dismissed in August 2023. At that stage, Failla held that Uniswap’s developers were not statutory sellers under federal law and that the protocol’s smart contracts were lawful tools that could facilitate both commodity and token trades. In February 2025, the U.S. Court of Appeals for the Second Circuit affirmed that dismissal, while sending the case back for review of the remaining state-law claims.
After remand, plaintiffs reshaped their complaint around aiding and abetting fraud, negligent misrepresentation, consumer protection statutes in New York, North Carolina, and Idaho, and unjust enrichment. Failla ruled that even after three chances to amend, the plaintiffs still failed to state plausible claims.
The opinion turned on two points. Under New York law, an aiding-and-abetting fraud claim required plaintiffs to show that defendants had actual knowledge of the underlying fraud and gave substantial assistance. The court said the complaint did neither. Allegations that Uniswap received complaints after losses occurred did not establish contemporaneous knowledge. General warnings on social media about scam tokens were also not enough. A March 2022 study discussing high rates of fraudulent token launches did not show that Uniswap knew about the specific tokens involved during the relevant period.
Providing market access was not treated as fraud participation
The court also rejected the theory that operating a platform, by itself, counted as substantial assistance. Failla compared the issue to traditional exchanges and financial institutions, writing that creating access to a marketplace does not become fraud simply because bad actors use that market. In this case, the identities of the token issuers remained unknown, and the complaint itself repeatedly acknowledged that the issuers’ own misrepresentations caused the losses.
Consumer protection claims failed as well. The court found no materially misleading statements by Uniswap Labs and pointed to public blog posts and terms of service that warned users about the risks of scam tokens. The alleged omissions were not framed as information uniquely held by the company and unavailable to users.
On unjust enrichment, the court said plaintiffs did not 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 introduced in October 2023 fell outside the timeframe covered by the suit.
Decision sharpens the liability line for DeFi developers
The ruling adds to a growing body of court decisions declining to extend liability to open-source protocol developers without direct involvement in misconduct. The opinion also said that complaints about regulatory gaps in decentralized finance may be better handled by Congress than by stretching judicial interpretation.
After the decision, Adams wrote on X that if open-source smart contract code is used by scammers, the scammers are liable, not the developers, calling the ruling a “good, sensible outcome.” Uniswap Foundation General Counsel Brian Nistler described it as another precedent-setting decision for DeFi and noted that the federal claims had already been dismissed before the state-law claims were thrown out.