Julian R. Calder, individually and as Chair of Keep Stocks Off Chain v. Bondcurve Labs, Inc., Dawnbridge Markets, Inc., and Ledgerlane Securities, Inc. — District Court, S.D. New York (1:26-cv-07412)
Plaintiff moves on an emergency basis to freeze the Custom Pairs product insofar as it uses tokenized listed stocks or indexes as quote assets for new token launches.
Irreparable harm: each hour of pairing prints a tape that looks like stock volume, distributes fractional stock tokens as memecoin fees, and teaches retail that listed names are gambling chips. Calder cannot unwind that education after the fact, and his specialist book cannot compete with a 24/7 shadow market that has no halt.
Likelihood of success: the complaint alleges false association with listed tickers, a shadow market that evades Exchange Act trading rules, and unfair competition against the listed market Calder is paid to make.
The proposed order would Keep Stocks Off Chain as pairing assets. It would not enjoin ordinary listed trading, authorized ETFs, or a registered offering. It would enjoin using tokenized NVDA, TSLA, SPX, and similar names as the other side of a memecoin bonding curve.
Fictional demo filing. Not a real court document. No real exchanges, parties, or copied complaint text.