Julian R. Calder, individually and as Chair of Keep Stocks Off Chain v. Bondcurve Labs, Inc., Dawnbridge Markets, Inc., and Ledgerlane Securities, Inc. (1:26-cv-07412)

COMPLAINT against Bondcurve Labs, Inc., Dawnbridge Markets, Inc., and Ledgerlane Securities, Inc. (Filing fee $ 405, receipt number ANYSDC-44190218.). Jury trial demanded. Filed by Julian R. Calder, individually and as Chair of Keep Stocks Off Chain (“K.S.O.C.”). Plaintiff is founder, chairman, and controlling shareholder of Calder & Whitlock LLC, a designated market maker in listed U.S. equities. He alleges that memecoin launchpads and tokenized-equity issuers have begun pairing newly launched tokens against tokenized versions of listed stocks and indexes (including NVIDIA, Tesla, and the S&P 500), attaching 24/7 gambling-style volume to listed names, generating unnatural off-exchange prints, and promoting a casino culture around public companies that never consented to be quote assets for memecoins. Plaintiff seeks declaratory and injunctive relief under the K.S.O.C. standard: Keep Stocks Off Chain as pairing assets for unregistered token launches. (Holt, Miriam) (Filed on 9/19/2026) (Entered: 09/19/2026)

CIVIL COVER SHEET. Nature of suit 850 Securities/Commodities. Jury demand: Plaintiff. (Holt, Miriam) (Filed on 9/19/2026) (Entered: 09/19/2026)

EMERGENCY MOTION for Temporary Restraining Order and Preliminary Injunction filed by Julian R. Calder and Keep Stocks Off Chain. Plaintiff seeks an order enjoining defendants from listing, promoting, or settling new token launches paired against tokenized U.S. listed equities or equity indexes pending a hearing. (Attachments: # 1 Proposed Order)(Holt, Miriam) (Filed on 9/19/2026) (Entered: 09/19/2026)

REQUEST FOR JUDICIAL NOTICE in Support of 1 Complaint and 5 Emergency Motion. Plaintiff asks the Court to notice public product announcements describing Custom Pairs, a roster of roughly 93 tokenized stock and index pairs, and widely reported figures on tokenized-equity wallet growth and off-exchange volume in tokenized listed names. (Holt, Miriam) (Filed on 9/19/2026) (Entered: 09/19/2026)

Summons Issued as to Bondcurve Labs, Inc., Dawnbridge Markets, Inc., Ledgerlane Securities, Inc. (sjo, COURT STAFF) (Filed on 9/20/2026) (Entered: 09/20/2026)