Mango Labs, LLC v. Kramer

CourtDistrict Court, D. Puerto Rico
DecidedSeptember 29, 2025
Docket3:24-cv-01469
StatusUnknown

This text of Mango Labs, LLC v. Kramer (Mango Labs, LLC v. Kramer) is published on Counsel Stack Legal Research, covering District Court, D. Puerto Rico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mango Labs, LLC v. Kramer, (prd 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

MANGO LABS, LLC, a Wyoming limited liability company,

Plaintiff,

v. Civil No. 24-01469 (GMM)

JOHN KRAMER, an individual, MAXIMILIAN SCHNEIDER, an individual, and Does 1-10, et al.,

Defendants.

OPINION AND ORDER Pending before the Court is Defendant John Kramer’s (“Kramer”) Omnibus Motion to Dismiss (“Motion to Dismiss”). (Docket No. 19). The Motion to Dismiss is GRANTED for lack of standing. I. FACTUAL AND PROCEDURAL BACKGROUND This is a diversity jurisdiction action for damages filed by Plaintiff Mango Labs, LLC (“Plaintiff”) against individual Defendants Kramer, Maximilian Schneider (“Schneider”), as well as any unknown defendant under the pseudonym Does 1-10, et al. (collectively, “Defendants”). Plaintiff commenced this action on October 7, 2024. (Docket No. 1). In its Complaint, Plaintiff alleged Defendants: breached their fiduciary duties of loyalty, good faith, and due care (Id. ¶¶ 76-82); violated Article 1536 of Puerto Rico’s Civil Code of 20201 (Id. ¶¶ 83-86); engaged in fraud and misrepresentation (Id. ¶¶ 87-90); and participated in unjust enrichment (Id. ¶¶ 91-95), all in violation of Puerto Rico law. Plaintiff seeks declaratory relief, compensatory damages, punitive damages, equitable relief, attorney’s fees, and costs and expenses. (Id. at 34-35). A. Cryptocurrency transactions Relevant to the nature of the parties’ allegations is cryptocurrency and its technologies. Cryptocurrency transactions are performed using decentralized finance, or “DeFi,” applications that act as platforms for the exchange of assets. Chris Brummer, Disclosure, Dapps and DeFi, 5 Stan. J. Blockchain L. & Pol’y 137, 138-40 (2022). DeFi relies on computerized systems that allow users to engage in the multilateral transactions without the interference of traditional financial institutions or Government regulatory agencies. Id. DeFi protocols can be controlled through

a Decentralized Autonomous Organization (“DAO”) that mimics a corporate governance structure. Id. DAOs distribute governance rights among individuals (“tokenholders”) who hold virtual tokens that serve as cryptocurrency assets and represent a share of the tokenholder’s governance rights over the DAO. Id. Tokenholders

1 In their Complaint, Plaintiffs cite Article 1802 § 5141 of the Puerto Rico Civil Code. (Docket No. 1 ¶ 1). The Court notes that Article 1802 is Puerto Rico’s previous tort statute and was replaced by Article 1536, when the most recent Puerto Rico Civil Code came into effect in 2020. Article 1536, however, contains the same elements as its predecessor. propose and hold votes on actions which, if approved and adopted, are executed by the DAO. Id. B. Plaintiff’s Complaint Plaintiff Mango Labs, LLC, a Wyoming limited liability company, has been the software developer of Mango Markets, a cryptocurrency exchange platform through which individuals engage in the trade of MNGO tokens, since February 2021. (Id. ¶¶ 2, 17, 23-24). Defendant Kramer, a resident of Puerto Rico, acted as a treasurer for the Mango DAO. (Id. ¶¶ 18, 31). Schneider acted as an administrator of Mango Market’s communication channels, allocated funding for the platform’s development, and was one of the Mango Market’s top tokenholders (Id. ¶¶ 19, 32). The controversy at hand can be traced back to November 2022, when the cryptocurrency exchange platform FTX filed for bankruptcy in the State of Delaware. (Id. ¶¶ 3, 33). Because of this

bankruptcy, on October 2023 the Delaware Bankruptcy Court ordered FTX to sell the MNGO tokens that were being traded on the platform. (Id.). At this point, Defendants——whom Plaintiffs qualify as “core Mango DAO personnel” that “work in trusted positions for the Mango DAO and are charged with handling highly sensitive and confidential tasks” ——allegedly profited from FTX’s sale of MNGO tokens, by misappropriating $2,500,000 for themselves, at the expense of MNGO tokenholders. (Id. ¶¶ 4-13). Specifically, as alleged by Plaintiff in its Complaint, on or around April 1, 2024, Kramer and Schneider fraudulently purchased approximately 330 million MNGO tokens from the FTX platform without disclosing their identity. (Id. ¶ 34-39).2 Subsequently, Defendants allegedly continued purchasing other unspecified quantities of MNGO tokens, thus artificially incrementing the market value of the MNGO tokens from 1.6¢ to 3.8¢. (Id. ¶¶ 40-41). On April 7, 2024, apparently, Kramer——acting under a pseudonym and alongside Schneider——presented a proposal to the Mango DAO whereby the Mango DAO would repurchase MNGO tokens at the inflated price of 3.8¢, despite also stating to the members of the Mango DAO that such tokens were bought for over 2¢ instead of the actual purchase price of 1.6¢.(Id. ¶¶ 42-47). Kramer and Schneider, exercising the governance rights they acquired through the purchase of the MNGO tokens from the FTX sale,

forced a voted on the proposal on April 11, 2024. (Id. ¶¶ 50-53). The proposal failed. (Id.). Nonetheless, Defendants presented a second proposal under which the Mango DAO would repurchase the MNGO tokens for 3.4¢ per token. This second proposal was approved by the Mango DAO on April 17, 2024. (Id.). According to Plaintiff, Defendants challenged action of ‘flipping’ the market for MNGO tokens took place while the Mango

2 Kramer acknowledges such a purchase, specifying the exact quantity of 333,450,822 MNGO tokens. (Docket No. 19-1 ¶ 6). DAO was in a vulnerable position. (Id. ¶¶ 48-49). This occurred while certain members of the Mango DAO were serving as Department of Justice witness in the criminal trial of Avraham Eisenberg (“Mr. Eisenberg”) ——a cryptocurrency trader convicted in the United States District Court for the Southern District of New York of market manipulation for fraudulently obtaining about $110,000,000 worth of cryptocurrency from Mango Markets. (Id.). Plaintiffs allege this deprived them from a meaningful opportunity to evaluate and effectively challenge the transaction. (Id.). In its Complaint, Plaintiff asserts that Mango Labs, LLC enjoys standing to bring this suit on behalf of MNGO tokenholders for two reasons. (Id. ¶¶ 17, 70-74). First, prior to filing the current civil action, MNGO tokenholders who comprise the Mango DAO voted on whether Mango Labs, LLC should be assigned as their legal representative for this lawsuit. (Id.). Although this proposal was

rejected by a 0.5% margin,3 Plaintiff contends that the result of the vote was invalid, because Defendants allegedly tampered with the outcome by using the MNGO tokens they fraudulently acquired from FTX, to sway the vote. (Id.). But-for such an intervention by Defendants, the vote would have been approved by MNGO tokenholders; hence, Plaintiff alleges that the Court should consider that

3 The proposal was rejected on a 50.5% to 49.5% vote, with a total of 901,601,133 MNGO tokens being voted. (Docket No. 19-2). A total of 446,502,389 MNGO tokens were voted in favor of the proposal, and 455,098,744 tokens were voted against the proposal. (Id.). Plaintiff was properly assigned as the tokenholders’ legal representative for this action. (Id.). Second, Plaintiff contends that it enjoys standing to sue on behalf of MNGO tokenholders in the form of a derivative action. (Id.). As pleaded, Plaintiff served as a de facto representative of MNGO tokenholders during Mr. Eisenberg’s criminal trial and has previously received grants from the Mango DAO to enforce tokenholder’s legal rights——which situates Mango Labs, LLC as an appropriate representative of the tokenholders’ legal claims. (Id.). C. Kramer’s Motion to Dismiss On January 27, 2025, Kramer filed a Motion to Dismiss, in accordance with Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6) (Docket No.

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