Mohsin Y. Meghji v. Compound Labs, Inc.

CourtDistrict Court, S.D. New York
DecidedApril 8, 2025
Docket1:25-cv-00926
StatusUnknown

This text of Mohsin Y. Meghji v. Compound Labs, Inc. (Mohsin Y. Meghji v. Compound Labs, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mohsin Y. Meghji v. Compound Labs, Inc., (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Chapter 11 In re: CELSIUS NETWORK LLC, et al., Reorganized Debtors. Case No. 22-10964 (MG)

(Jointly Administered) MOHSIN Y. MEGHJI, Litigation Administrator, as Representative for the Post-Effective Date Debtors, Adversary Proceeding Plaintiff, Adv. Proc. No. 24-03989 (MG) -against- Civil No. 1:25-cv-00926 (JLR) COMPOUND LABS, INC., COMPOUND DAO, ROBERT LESHNER, and GEOFFREY HAYES, OPINION AND ORDER Defendants. JENNIFER L. ROCHON, United States District Judge: This Adversary Proceeding was commenced in the Southern District of New York Bankruptcy Court by Plaintiff Mohsin Y. Meghji, the Litigation Administrator for Celsius Network LLC and its affiliated Debtors (collectively, “Celsius” or the “Debtors”), against Defendants Compound Labs, Inc. (“Compound Labs”), Compound Dao, Robert Leshner (“Leshner”), and Geoffrey Hayes (“Hayes,” and, together with Leshner, “Individual Defendants”). See Meghji v. Compound Labs, Inc., No. 24-03989 (MG) (Bankr. S.D.N.Y. filed July 12, 2024) (the “Adversary Proceeding”). The Adversary Proceeding is part of a larger bankruptcy case, In re Celsius Network LLC, No. 22-10964 (MG) (Bankr. S.D.N.Y. filed July 13, 2022), pending in the Southern District of New York Bankruptcy Court before Judge Martin Glenn. In this Adversary Proceeding, Celsius asserts federal securities law and various common-law claims in connection with trading losses it suffered while loaning and borrowing cryptocurrency assets on a software protocol system developed by Compound Labs. See generally Dkt. 4-1 (“First Amended Complaint” or “FAC”). Now before the Court is Defendants’ Motion to Withdraw the Bankruptcy Reference pursuant to 28 U.S.C. § 157(d). Dkt. 1 (“Mot.”). BACKGROUND I. Factual History Celsius is “one of the largest cryptocurrency-based finance platforms and Bitcoin mining companies in the world,” and provides “financial services to institutional, corporate and retail clients across more than 100 countries.” FAC ¶ 19. Leshner and Hayes cofounded

Compound Labs in 2017 with the objective of “establishing properly functioning money markets for blockchain assets.” FAC ¶ 25. The company developed the Compound Protocol (the “Protocol”), a publicly available software protocol system designed to allow users to borrow cryptocurrency assets by using their own cryptocurrency assets as collateral. FAC ¶¶ 20-21, 25-27; Dkt. 4-2 (“MTD”) at 1. Through the Protocol, users can “lock” their cryptocurrency “assets into a community pool from which other users can borrow after posting collateral.” FAC ¶ 29. “When users deposit their money into a liquidating pool, they are issued ‘cTokens,’” which denote their investment ownership rights and track their earned interest. FAC ¶ 30. Moreover, “[t]o further induce borrowing on the platform, users receive COMP tokens for borrowing on the platform.” FAC ¶ 31. The platform requires users to

“maintain a certain ratio of collateral” to partake in lending and borrowing on the platform. FAC ¶ 2. The value of a user’s posted collateral must exceed the value of their borrowed assets, such that the user is not “undercollateralized.” See FAC ¶ 37; MTD at 1. Failure to maintain the requisite ratio could result in automatic liquidation of the user’s borrowing position. FAC ¶¶ 2, 37. As of November 2020, Celsius had entered into borrowing positions on the Protocol for two cryptocurrency stablecoins, or cryptocurrency “pegged to fiat currencies like the U.S. dollar”: DAI and USDT. FAC ¶¶ 21, 55. Celsius’s claims in the Adversary Proceedings arise from an alleged misrepresentation by Defendants in a 2019 Whitepaper discussing the Protocol: according to Celsius, the Whitepaper “falsely represented to potential investors, borrowers, and users of the [Protocol] that the price of assets traded on the [Protocol] would be tied to ten sources of pricing information.” FAC ¶ 3. Celsius contends that “at the time of the conduct underlying this action, the price of assets on the [Protocol] was actually linked to one, and only one,” source

for pricing data: Coinbase Pro. FAC ¶ 5; see also FAC at ¶¶ 39-40. In November 2020, due to a reported price increase in the value of Celsius’s borrowed assets on the Protocol, Celsius’s position was deemed undercollateralized, and Celsius’s tokens were therefore liquidated. FAC ¶ 6. Specifically, Plaintiff alleges that the Coinbase Pro exchange “mistakenly and falsely” indicated a price increase in the DAI cryptocurrency, “caus[ing] the wrongful liquidation of valuable collateral associated with loan positions on [the Protocol],” including Celsius’s collateral. FAC ¶ 57. Celsius brings this Adversary Proceeding to recover damages it allegedly sustained as a result of the liquidation of its position on the Protocol.

II. Procedural History On July 13, 2022, the Debtors filed a voluntary Chapter 11 Petition with the Southern District of New York Bankruptcy Court. Chapter 11 Voluntary Petition for Non-Individual, In re Celsius Network LLC, No. 22-10964 (Bankr. S.D.N.Y. July 13, 2022), ECF No. 1. On November 9, 2023, the parties finalized a confirmed plan of reorganization. Modified Joint Chapter 11 Plan of Reorganization of Celsius Network LLC & Its Debtor Affiliates, In re Celsius Network LLC, No. 22-10964 (Bankr. S.D.N.Y. Nov. 9, 2023), ECF No. 3972-1. Plaintiff initially commenced this Adversary Proceeding on July 12, 2023 in the Southern District of New York Bankruptcy Court before Judge Martin Glenn, asserting negligence, negligent misrepresentation, and professional malpractice claims against Compound Labs. See generally Complaint, Meghji, No. 24-03989 (Bankr. S.D.N.Y. July 12, 2024), ECF No. 1. On November 1, 2024, in response to Defendants’ motion to dismiss, Plaintiff filed an Amended Complaint, adding Compound Dao, Leshner, and Hayes as Defendants. See generally FAC. The FAC also added a securities fraud claim under SEC Rule 10b-5 and a breach of fiduciary duty claim. Id. at 19-20.

On December 20, 2024, Defendants filed a motion to dismiss Plaintiff’s FAC. Motion to Dismiss, Meghji, No. 24-03989 (Bankr. S.D.N.Y. Dec. 20, 2024), ECF. No. 32. Plaintiff filed its opposition on January 31, 2025, Response to Motion, Meghji, No. 24-03989 (Bankr. S.D.N.Y. Jan. 31, 2025), ECF No. 42, and Defendants filed their reply on February 21, 2025, Reply to Motion, Meghji, No. 24-03989 (Bankr. S.D.N.Y. Feb. 21, 2025), ECF No. 44. The parties’ motion to dismiss briefing is currently pending before the Bankruptcy Court. On January 31, 2025, Defendants filed the motion presently before this Court to withdraw the bankruptcy reference. Mot. On February 10, 2025, Plaintiff filed its opposition, Dkt. 6 (“Opp.”), and on February 24, 2025, Defendants filed their reply, Dkt. 11 (“Reply”).

LEGAL STANDARDS Federal district courts have original jurisdiction over all civil proceedings “arising under,” “arising in,” or “related to” cases under Title 11, the United States Bankruptcy Code. 28 U.S.C. § 1334(b). In the Southern District of New York, these cases are automatically referred to the Bankruptcy Court. See In re Standing Order of Reference Re: Title 11, No. 12- mc-00032 (S.D.N.Y. Feb. 1, 2012). This automatic reference is, however, subject to withdrawal by the federal district courts pursuant to 28 U.S.C. § 157(d). Specifically, 28 U.S.C. § 157(d) provides that the district court “may withdraw, in whole or in part, any case or proceeding referred under this section . . . for cause shown.” 28 U.S.C.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Granfinanciera, S.A. v. Nordberg
492 U.S. 33 (Supreme Court, 1989)
Stern v. Marshall
131 S. Ct. 2594 (Supreme Court, 2011)
Mishkin v. Ageloff
220 B.R. 784 (S.D. New York, 1998)
Revak v. SEC Realty Corp.
18 F.3d 81 (Second Circuit, 1994)
Lehman Bros. Holdings Inc. v. Intel Corp.
18 F. Supp. 3d 553 (S.D. New York, 2014)
Balestra v. ATBCOIN LLC
380 F. Supp. 3d 340 (S.D. Illinois, 2019)
Kirschner v. Agoglia
476 B.R. 75 (S.D. New York, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
Mohsin Y. Meghji v. Compound Labs, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/mohsin-y-meghji-v-compound-labs-inc-nysd-2025.