Commodity Futures Trading Commission v. Ooki DAO

CourtDistrict Court, N.D. California
DecidedDecember 20, 2022
Docket3:22-cv-05416
StatusUnknown

This text of Commodity Futures Trading Commission v. Ooki DAO (Commodity Futures Trading Commission v. Ooki DAO) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commodity Futures Trading Commission v. Ooki DAO, (N.D. Cal. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 COMMODITY FUTURES TRADING Case No. 3:22-cv-05416-WHO COMMISSION, 8 Plaintiff, ORDER CONCLUDING THAT 9 SERVICE HAS BEEN ACHIEVED v. 10 Re: Dkt. Nos. 16, 22, 31, 36 OOKI DAO, 11 Defendant.

12 13 The Commodity Futures Trading Commission (“CFTC”) is a federal regulatory agency 14 that administers and enforces the Commodity Exchange Act (“CEA”) and related regulations. 15 Complaint (“Compl.”) [Dkt. No. 1] ¶ 10. The CFTC filed the underlying complaint in this action 16 against Ooki DAO, a decentralized autonomous organization (“DAO”) that the CFTC alleges 17 violated the CEA by enabling users to engage in retail commodity transactions without abiding by 18 CEA requirements, including registering its “platform” and conducting certain customer due 19 diligence. See id. ¶ 1. The CFTC contends that Ooki DAO was structured intentionally to render 20 its activities “enforcement proof,” including by erecting significant obstacles to traditional service 21 of process. 22 This appears to be a case of first impression, and it begins with questions of sufficiency of 23 service. Several amici represented by national law firms claim that the CFTC cannot serve Ooki 24 DAO, and if it can, has not done so properly. I disagree. Ooki DAO has received both actual 25 notice and the best notice practicable under the circumstances. As explained below, I reject the 26 arguments of the amici. Ooki DAO is deemed to be served as of the date of this Order. 27 BACKGROUND 1 is essential to understand the underlying technology. This Order outlines some of the factual 2 background from the complaint and some relevant information from amicus briefs. 3 I. Factual Background 4 According to the complaint, bZeroX, LLC, operated a blockchain-based software called 5 the “bZx Protocol” from June 1, 2019 until August 23, 2021. Compl. ¶ 1. The bZx Protocol 6 operated on the Ethereum blockchain through the use of “smart contracts”1 that permitted anyone 7 with “an Ethereum wallet” to, essentially, make investments and bet on the relative rise and fall of 8 particular virtual currencies. See id. ¶¶ 25-28, 31. As the CFTC explains it, these investments and 9 bets allowed users to “contribute margin (collateral) to open leveraged positions whose ultimate 10 value was determined by the price difference between two digital assets from the time the position 11 was established to the time it was closed.”2 Id. ¶ 28. This technology is functionally the same as 12 using a trading platform and, according to the CFTC, constitutes an “exchange” for commodity 13 derivative transactions. See id. ¶¶ 1, 13-15, 52-60. 14 bZeroX LLC had a website to market its technology to prospective users, solicit orders, 15 and facilitate access to the software Protocol. Id. ¶ 32. bZeroX LLC also charged and collected 16 fees for access to its technology. Id. ¶ 33. Additionally, bZeroX LLC had a “liquidity pool” that 17 contained assets supplied by “liquidity providers.” Id. ¶ 28(b). In exchange for supplying 18 liquidity, these providers received both “interest-generating tokens” and “BZRX Tokens,” the 19 latter of which conferred voting rights on the holders (“Token Holders”) for certain questions 20 related to governance of the Protocol. Id. Finally, bZeroX LLC had “Administrator Keys” which 21 allowed bZeroX to “access and control” the operation of the smart contracts (pieces of software 22 code) and the funds held in those smart contracts, including by updating code, pausing or 23

24 1 “Smart contracts” are pieces of computer code or software code, not necessarily contracts as understood in the legal sense. Compl. ¶ 25; see also LeXpunK (“LeXpunK Mot.”) [Dkt. No. 16] 3 25 n.9.

26 2 For related context, see U.S. Commodity Futures Trading Comm’n v. Monex Credit Co., 931 F.3d 966, 969 (9th Cir. 2019) (“Through [the defendant company], investors can purchase 27 commodities on ‘margin.’ Also known as ‘leverage,’ the concept is simple: A customer buys [the 1 suspending trading, and directing deposits of funds to users. Id. ¶ 34. 2 According to a CFTC regulatory settlement against the founders of bZeroX, the LLC never 3 registered with the CFTC nor conducted the customer due diligence required to protect against 4 fraud, money-laundering, and terrorist activity, as required by the CEA for most exchanges that 5 enable commodity derivative transactions. See In the Matter of: Bzerox, LLC; Tom Bean; and 6 Kyle Kistner, Respondents, CFTC No. 22-31, 2022 WL 4597664, at *1 (September 22, 2022). 7 In August 2021, bZeroX LLC “transferred control” of the software Protocol3 to “the bZx 8 DAO,” which was subsequently renamed “Ooki DAO.” Compl. ¶¶ 38, 46. A DAO is a 9 “decentralized autonomous organization” which is “a way to organize people, a social- 10 coordination technology that relies on blockchain-based smart contracts and incentives” to 11 facilitate collaboration and collective action. Paradigm Operations LP (“Para. Mot.”) [Dkt. No. 12 31] 2:16-18. Put differently, DAOs allow “unrelated parties” to use software code on a blockchain 13 without needing a “centralized coordinating authority,” and permit users “to take actions to edit 14 open-source software.” DeFi Education Fund (“DEF Mot.”) [Dkt. No. 22] 3:24-4:1, 7:7-8. The 15 CFTC alleges that “the bZx Founders believed that transition to a DAO would insulate the bZx 16 Protocol from regulatory oversight and accountability for compliance with U.S. law” due to its 17 structure and built-in anonymity of users. Compl. ¶ 40. 18 The DAO continued operating the underlying Protocol software in the same way as the 19 LLC had, permitting users to engage in the same retail commodity transactions and continuing the 20 collection of user fees. See id. ¶ 41. Those fees and revenue were collected in a central DAO 21 Treasury. See id. ¶¶ 44-45. 22 In the transition, the bZeroX founders also transferred control of their Administrator Keys 23 to the DAO, which allowed the DAO to access and operate the Protocol and control the funds held 24 in the smart contracts.4 Id. ¶¶ 38, 41(d). How those Keys were used was determined by votes of 25 3 The “bZx Protocol” was later renamed the “Ooki Protocol.” Compl. ¶ 46. 26

4 The funds held in the smart contracts are separate from the funds held in the liquidity pool or 27 central DAO Treasury. The former consists of the virtual currency bets and investments made by 1 Token Holders. Id. ¶ 42. Token Holders could propose any changes to the Protocol or to “the 2 direction of the . . . DAO’s business,” usually after discussion on the DAO’s online Community 3 Forum, and usually after conducting a “non-binding ‘snapshot vote’” of anyone on the Forum. Id. 4 ¶¶ 42-43. If a Token Holder believed there was sufficient community support, the Token Holders 5 would “vote” their tokens in a binding vote which occurred “directly on” the Protocol (blockchain 6 software). Id. 7 The CFTC contends that Ooki DAO is an unincorporated association comprised of Token 8 Holders that used (“voted”) their tokens to “govern” the Protocol. Id. ¶¶ 11, 47. For example, the 9 CFTC alleged that the DAO Token Holders voted to change the DAO name to Ooki DAO, id. 10 ¶ 46, and to use funds from the central DAO Treasury to compensate DAO users that lost funds 11 due to security breaches and theft, id. ¶ 45. 12 But the CFTC asserts that Ooki DAO never registered with the CFTC, as required by the 13 CEA for most exchanges that enable commodity derivative transactions. See id. ¶¶ 52-67. Ooki 14 DAO also did not implement a Customer Information Program (“CIP”) or conduct Know Your 15 Customer (“KYC”) or anti-money laundering procedures, all allegedly in violation of the CEA. 16 See id. ¶¶ 68-72. 17 II. Procedural Background 18 The CFTC filed its complaint on September 22, 2022. Dkt. No. 1.

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Commodity Futures Trading Commission v. Ooki DAO, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commodity-futures-trading-commission-v-ooki-dao-cand-2022.