Complaint

Plaintiff Julian R. Calder, an adult resident of New York, New York, brings this action individually and as Chair of Keep Stocks Off Chain (“K.S.O.C.”), an unincorporated association of market professionals formed to keep listed equities off memecoin rails.

Calder is founder, chairman, and controlling shareholder of Calder & Whitlock LLC, a New York specialist and designated market maker that has made markets in listed U.S. common stock since 1934. His firm is paid to maintain fair and orderly markets in names that now appear, without issuer consent, as quote assets on 24/7 token launchpads.

On or about September 9–10, 2026, Bondcurve Labs, Inc. opened a “Custom Pairs” product that lets anyone launching a new token price that token not against a dollar stablecoin, but against a tokenized stock or index — NVIDIA, Tesla, Boeing, the S&P 500, and dozens of other listed names. Dawnbridge Markets, Inc. supplied additional equity pairs. Ledgerlane Securities, Inc. issued or bridged the tokenized stock units used as those quote assets. Public reports put the menu at roughly 93 pairs.

That is not capital formation for issuers. It is a memecoin bonding curve wearing a ticker. Trading fees on some pairs settle in the stock token itself, so wallets that never bought a share receive fractional “equity” as a side effect of gambling on a new coin. Addresses holding tokenized equities on public chains jumped tens of percent in days. In at least one reported instance, a tokenized version of a listed name printed more volume in a few hours than the actual New York listing moved in the same window.

Calder alleges this volume is unnatural. It is not an auction reflecting issuer news, earnings, or a specialist’s book. It is 24/7, uncleared, without short-sale rules, without market-wide circuit breakers, and without the National Market System. Retail sees the ticker and assumes a stock. What they get is a casino chip labeled with someone else’s company.

The harm, he alleges, is not theoretical. Pairing memecoins to household names fuds listed markets: it teaches a generation that NVIDIA is a liquidity toy, that Tesla is a quote asset for a joke coin, and that “stocks” are something you spin against a bonding curve. It attaches a gambling culture to names Calder is obligated to make fair and orderly. It creates a shadow tape that reporters and social feeds treat as stock volume. Issuers did not list for this.

K.S.O.C. — Keep Stocks Off Chain — is the relief he wants recognized. Tokenized exposure to a listed company, if it exists at all, should not be a pairing asset for unregistered memecoin launches. Stocks belong on the exchange that listed them, under the rules that govern them. They do not belong on a launchpad as fuel for a new ticker.

Plaintiff demands a jury trial and seeks damages, a declaration adopting the K.S.O.C. standard, and a preliminary and permanent injunction enjoining defendants from offering, promoting, or settling memecoin launches paired to tokenized U.S. listed equities or equity indexes.

Fictional demo filing. Not a real court document. No real exchanges, parties, or copied complaint text.