Original | Odaily Planet Daily (@OdailyChina)

Author｜jk

On March 3, 2026, Judge Katherine Polk Failla of the Southern District of New York officially dismissed the second amended class action lawsuit against Uniswap Labs and its founder Hayden Adams, with the dismissal being "dismissal with prejudice," meaning that the plaintiffs cannot bring the same claims again. This legal tug-of-war that began in 2022 has come to an end.

Origins of the Case: Victims of Scam Tokens Unable to Locate Defendants

In April 2022, a group of investors led by Nessa Risley filed a class action lawsuit in court. They claimed to have suffered losses trading tokens on the Uniswap protocol, which were involved in typical crypto scams such as rug pulls and pump-and-dumps, meaning that project teams inflated prices in a short time period and then sold off, leaving ordinary investors with significant losses.

The problem was that the issuers of these scam tokens were mostly anonymous and difficult to pursue legally. Consequently, the investors shifted their focus to targets they could identify: Uniswap Labs, founder Adams, the Uniswap Foundation, and three well-known venture capital firms: Paradigm, Andreessen Horowitz (a16z), and Union Square Ventures.

The core logic of the plaintiffs was: Uniswap provided a market that facilitated transactions between buyers and sellers, thus enabling the occurrence of scams and should therefore bear joint liability.

Three-Year Tug of War: Federal Claims First Dismissed, Then State Claims Fail

The lawsuit progressed in two phases.

First Phase (2023): The court dismissed all claims brought by the plaintiffs under federal securities law, reasoning that the plaintiffs could not prove that Uniswap acted unlawfully as an unregistered securities exchange or broker. The judge wrote a line in the ruling that became widely quoted: It "defies logic" to hold smart contract authors accountable for third-party misuse of decentralized platforms. In February 2025, the Second Circuit Court of Appeals upheld this ruling but sent the remaining state-level claims back to the district court for reconsideration.

Second Phase (March 2026): The plaintiffs adjusted their strategy and concentrated six state-level claims in the second amended complaint, including: aiding and abetting fraud, aiding in negligent misrepresentation, violating consumer protection laws of New York, North Carolina, and Idaho, and unjust enrichment. However, all six claims were dismissed again.

The court found:

• The plaintiffs could not prove that Uniswap Labs had actual knowledge of specific fraudulent acts at the time the scams occurred: user complaint emails were only received after purchases were made, and social media warnings were directed at other investors, not the defendants;
• Uniswap Labs did not activate the protocol's fee switch during the period in question, did not profit directly from the trades, and therefore unjust enrichment could not be established;
• Uniswap had publicly acknowledged in a 2020 blog post that distinguishing between scam tokens and legitimate tokens was becoming increasingly difficult, and these constituted public warnings to users, not deception.

Judgment: Providing Infrastructure Does Not Equate to Actively Aiding Fraud

Judge Failla explicitly stated in her ruling that the plaintiffs' liability theory was always based on one premise: Uniswap "facilitated" fraudulent transactions by providing a market. However, the court did not accept this logic.

The ruling stated: "Merely creating an environment in which fraud may occur does not equate to actively facilitating fraud." Developers writing open-source smart contract code and deploying it on a decentralized network, which can be freely used by anyone, differs fundamentally from the role of traditional financial intermediaries, who control user assets and scrutinize transactions.

Brian Nistler, the head of legal at Uniswap Labs, called this ruling another "precedent-setting" decision in the DeFi space. Adams himself briefly stated: "If open-source smart contract code is exploited by scammers, the ones who should bear the responsibility are the scammers, not the developers who wrote the code. This is a good and reasonable outcome."

Subsequent Impact: Legal Shield for DeFi Protocols and Launchpads

The implications of this judgment extend far beyond just Uniswap.

In the crypto industry, many DeFi protocols and Launchpads have long faced similar potential legal risks: users trading scam projects on the protocol, then suing the protocol itself after suffering losses. This ruling establishes a key principle: as long as protocol developers are not the active orchestrators of the fraud and cannot prove they had actual knowledge of specific scams and provided substantial assistance, the platform is not liable for third-party fraudulent actions.

Borrowing protocols like Aave and Compound, liquidity platforms like Curve Finance, and various token issuance and trading launchpads all rely on similar open-source, permissionless structures as Uniswap. If the court had taken an opposite stance equating deployment of code with acting as a broker, the entire DeFi industry would face an existential legal crisis. This ruling significantly reduces that risk.

However, legal professionals also caution against excessive optimism. Judge Failla herself acknowledged in the ruling that the plaintiffs' damages were "real and palpable," but the current legal system does not allow for holding protocol developers accountable. She clearly stated that the relevant policy issues fall within the purview of Congress, not the judiciary. This means that if Congress legislates to specifically regulate DeFi platform liability in the future, the protective effect of the current ruling will no longer be effective.

Additionally, the criminal case involving Tornado Cash, which also concerns responsibility for open-source code, will remain a significant point of focus for the industry.

In terms of market sentiment, after the ruling was announced, Uniswap's native token UNI rose approximately 6% on the same day, reaching a high of $3.97.

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