RICO

Where each fee dollar went

Of every dollar users have paid in trading fees, about 60 cents went to the platform, 27 cents to coin creators, 12 cents into pools and 2 cents back to traders and referrers.

The record month was last month

Users paid $157.7m in fees in September 2026, the most in any month. The platform's own slice peaked in January 2025 at $149.8m and was $49.4m in September, because after a coin graduates most of the fee goes to its creator and the pool.

What nobody has measured

Total trader losses. The complaint estimates $4bn to $5.5bn by multiplying wallet counts by assumed averages. That is an allegation built on an estimate, and the court held trading losses are not recoverable in the case anyway. No dataset measures the lifetime figure.

The table is internally consistent

“that's $128M extracted just by 25 devs”

The 25 rows sum to $128,182,602 and 760,970 launches, which the post rounds up to 770,000. 7,340 are marked graduated, 0.96%. Six best-ever coins passed a $20m market cap, as stated. The post publishes no method or dataset.

pump.fun's own numbers for the same wallets

665,031 launches and $84.7m of realised trading profit on $510.7m of buys. That is 87% of the post's launch count and 66% of its profit figure. pump.fun's figure covers trading only. It leaves out the creator fees these wallets earn on every trade of their coins, which may be part of the gap; the fee endpoint was returning errors, so that is untested.

Still running

19 of the 25 had launched a coin in the 48 hours before the reading. Together they realised $12.3m in the last 30 days, $2.67m in the last seven and $369,000 in the last 24 hours.

The largest one

165,236 launches. Its profile was created on 15 July 2025; if every launch dates from then, that is one every four minutes. In the last 30 days it traded 12,117 coins, bought $20.4m, realised $5.28m, and by pump.fun's measure never had more than $2,563 deployed at once. All-time realised profit: $21.5m.

What a launch looks like

Across 1,750 recent launches: the median coin's last trade came 5.2 minutes after creation, and 75% never traded after their first hour. Median peak market cap $5,940; 87% never passed $10,000; 33 graduated. 91% carry a link to a specific X post in their metadata, which is where the name comes from.

The newest coins in the sample could still trade, so lifespans are a floor.

How the platform treats them

None of the 25 is marked banned. Each has a profile; together they have 56,097 followers. The fee schedule pays each a creator fee on every trade of its coins. The Terms prohibit conduct that “in Pump's sole opinion” is market manipulation, “including, without limitation, pump and dump schemes, wash trading, spoofing.”

Who they are

A widely viewed reply guessed the wallets belong to platform employees. Nothing in the post or in pump.fun's API data supports that, and it is not a claim made here. A wallet is not a person. Research on 15.2m pump.fun coins found the top 1% of creator addresses made 38.89% of all coins, and over 57% once addresses that fund each other are grouped, so 25 wallets may be fewer operators.

What this does and does not show

It shows scale and timing: coins minted by the thousand, most of which stop trading within minutes, with the deployer realising a profit across them and the platform paying a fee on top. It does not show intent, and launching a coin and selling your own allocation is not unlawful in itself. No authority is known to have acted against any of these wallets. The same researchers wrote that their data “cannot assert malicious intent.”

The three statements

25 Sep 2024: “unruggable fair launch platform.” 4 Oct: “pump fun is as much of an even playing field as it gets IMO.” 12 Oct: “the playing field is as fair as ever.” The court: “sufficiently concrete to be actionable at the pleading stage.”

Marketing, as alleged

Launches marketed as “fair,” with “no presales,” “no insider allocations,” and “rug-pull proof launches.”

Pre-positioning

“Each tier acquired COPE before the tier below received the contract address needed to transact.”

Selected participants allegedly received a token's address before public promotion and bought first.

“Size him down”

Telegram, 6 April 2024, reproduced in the complaint: Cohen instructs Tweedale to reduce a promoter's early position after he bought more than “Leadership” had authorised. The court found it pleaded with date, participants, medium and subject.

“Pump would inject capital to fuel it”

“They'd launch memecoins to rally around the hate and humiliation of a target — and pump would inject capital to fuel it.”

Different vocabulary, same allegation as the complaint's pre-positioning tiers.

Why it matters legally

The fairness statements are the wire-fraud predicate. The court held that someone who allegedly controlled early token-address distribution “necessarily knew facts inconsistent with his representations that the platform afforded retail participants an ‘even playing field.’”

The promoter agreements

Posts made “organically utilizing the pump fun app” while prohibiting disclosure of the arrangement.

A thread and a separate post each week. The court described arrangements “designed to make paid promotion appear independent and organic.”

The hierarchy

“Leadership” decides which tokens to promote. “Operations Command” runs campaigns and manages promoters. “Operational Cells” and “Friends and Family” networks receive information as a campaign progresses. “Strategic decisions flowed downward. Profits flowed upward.”

“Plants in nearly every major FNF”

“Pump has plants in nearly every major FNF, TG, and community. To establish a belief they echo it across channels.”

Same vocabulary as the complaint's lowest tier. The thread offers no group, message or name; the complaint pleads a structure.

Alt-account clusters

“1 operator approves a stream of AI content → runs 20 accounts off it → 5–6 people under them → 100–120 accounts.”

No published research, filing or platform action identifies a pump.fun-linked persona network. The complaint pleads humans under written agreements.

Twenty-five unnamed promoters

“Lead KOL Doe Defendants 1–25” were pleaded but never identified or served. Plaintiffs were ordered to show cause by 10 September 2026 why those claims should not be dismissed.

What X did

16 June 2025: X suspended pump.fun's official account and its co-founder's account without stated explanation. Relevant to the thread's claim that the platform “owns the rails of virality.”

Referral links

A pump.fun/join/<handle> URL is a referral code; the page renders “<handle> invited you to pump.fun.” pump.fun's own code documents referrer payments including a first-deposit match and a cut of referees' Callout Rewards. Until 8 October 2026 the fee page also described a mobile fee increment that “may be paid back to the user or the referrer of the user”; that footnote is gone from the current page. Reported revenue is “net of referral fees.” No terms, rates or caps are published anywhere.

Callout Rewards

Launched 13 August 2026: daily USDC for trading volume attributed to a user's in-app callouts, “funded from our own pocket.” The programme operator is Green Pill Holdings, a British Virgin Islands company the terms call “a separate legal entity from the operator of the Pump Platform.” The terms require callers to “clearly disclose” any compensation or token allocation in the callout itself.

“Verified (KOL/influencer badge)”

The in-app checkmark is labelled that way in pump.fun's own API. It is granted and hidden by administrators. No criteria, application process or list is published.

Creator revenue share

Since May 2025 deployers receive a share of trading fees on-chain, at first 0.05% of post-graduation trades. Since September 2025 it is 0.30% on the curve and tiered up to 0.95% after graduation. Creators have been paid $607.7m in total. The terms say pump.fun does not control how creators share those fees with “promoters, referrers, or other third parties.”

The disclosure standard

“When there exists a connection between the endorser and the seller of the advertised product that might materially affect the weight or credibility of the endorsement … such connection must be disclosed clearly and conspicuously.”

The FTC's guidance adds that a disclosure only on a profile or about page “is likely to be missed” and belongs with the endorsement.

Equity investors

Three firms list pump.fun on their own portfolio pages: Alliance DAO (“Pump — Oxford, UK”), 6th Man Ventures (“Fastest growing crypto company to $1bn of revenue”), and Big Brain Holdings. A Delphi Digital episode on the 6MV investment is titled “Pump.Fun, One of the Greatest Seed Investments Ever.”

Undisclosed money

The PUMP tokenomics allocate 13% to “existing investors” and 18% to a private sale of roughly $720m. Neither group is named. A 1% equity stake was listed on a secondary market at a $1.5bn valuation in November 2024; seller and outcome unreported.

Money out

Acquisitions: Kolscan (Jul 2025), Padre, now Terminal (Oct 2025), Vyper (Feb 2026), prices undisclosed. An in-house “Pump Fund” of $3m (Jan 2026) and a $1m pre-seed into Pumpcade (Apr 2026).

“The spark”

“COPE, tied to a creator who'd posted about it for 1–2 years, was the spark: a catalyst to send people looking for these specific coins.”

The peak

All-time high 29 August 2025 at roughly an $18m market cap. The thread's 27 August was breakout day, at about a fifth of the eventual high. During its dormant period the coin's market cap sat around $5,000–12,000.

Why the court cared

The COPE allegations “place the same alleged ‘playbook’ in operation many months after” the 2024 statements. That continuity is what carried the pattern element.

The agent is real

“An autonomous AI trading agent” that mints an extra 1,000,000,000 tokens and trades them for a coin's first 24 hours, intended “as a replacement for market makers,” with buy/sell skew “determined on a discretionary basis.”

Mayhem Mode. Opt-in, on-chain, launched 12 Nov 2025, “part of Project Ascend.”

Ladder bots that read your wallet

“One of their people buys → they auto-buy; a target buys → they auto-sell.”

Trivially feasible on Solana. No dataset, paper or filing shows it. The agent's wallet is public; the test has not been run.

“Buy 100 times and lose 100 times”

The complaint itself concedes about 60% of wallets ended net negative. The court: “That necessarily means that approximately forty percent did not.”

Insider-first execution

Against the chief technology officer: metrics “used for insider-first execution,” transaction “land rate,” and “priority pathways relied upon by insiders.” If true, the court held, it is reasonable to infer he knew why he was building them.

“Wallet-synced control”

The thread's mechanism is targeting. The record's is priority. Adjacent claims, different things.

Bundling is commodity

Public code offering pump.fun bundlers and snipers runs to hundreds of repositories. One month's data: 4,600+ sniper wallets across 10,400+ distinct deployers. Concentration is endemic, decentralised, and detected by scanners, one of which is built into pump.fun's own interface.

Who gets the money

Bracket Company, Ltd. “owns the Pump Platform and the Pump IP and receives the fees described on the Fees Page.”

Bracket is a British Virgin Islands company at a registered-agent address in Tortola. Baton, the English company sued in New York, “develops and operates the Pump Platform on behalf of Bracket.” A BVI company's accounts are not public. In court, Baton “denies that it uses a trade name of Pump.fun.”

No duty to tell you its interests

The Terms say no fiduciary duty arises, that Pump entities “may from time to time act in more than one capacity,” and that they “will not be required to” have regard to, disclose, or use for your benefit any information that “is or may be a material interest.”

One at a time, in Tortola, within a year

Disputes go to binding arbitration seated in Tortola. “Class arbitrations, class actions, and representative actions are strictly prohibited.” A claim must be started within one year. A user may opt out of arbitration within 30 days of first accepting. In the New York case Baton has reserved, not yet exercised, the right to compel arbitration.

The forum moved offshore

The Terms dated 22 October 2024 and 3 April 2025, the latter still live on 8 July 2025, were governed by “the laws of England” with arbitration at the London Court of International Arbitration. The current Terms seat arbitration in the British Virgin Islands.

The UK, 22 months later

The FCA warning is dated 3 December 2024 and pump.fun blocked UK visitors days later. The Terms of October 2024 and April 2025 contain no UK restriction. The version dated 8 October 2026 lists “the United Kingdom” first among prohibited jurisdictions. The United States is not on the list.

Age is a click

The entry screen asks a visitor to “certify that you are over 18 years old” by pressing Continue. The Terms describe no check. The archived Terms of 2024 and April 2025 contain no minimum-age wording at all. Apple lists the app under Entertainment, rated 17+. Its seller is Maius Imperium Limited, which the privacy notice places in Limerick, Ireland.

What the screen says a trade costs

The fee page lists 1.25% on every bonding-curve trade and adds that “there is no guarantee that the transaction fee(s) listed in the web or mobile app will exactly match those charged by the smart contract.” Until this week it carried a footnote that “some mobile users” may see “fee increases of up to .1%”; the 8 October version drops it without explanation.

What it still tells newcomers

“Pump lets anyone create coins, giving everyone equal access to buy and sell from the start.”

That is the first thing a visitor reads, on 9 October 2026, five weeks after a court held earlier “even playing field” statements “sufficiently concrete to be actionable at the pleading stage.”

May 2024: $1.9m taken by a new hire

pump.fun said a former employee used a “privileged position” to take about 12,300 SOL from the bonding-curve contracts. He had been a senior developer for six weeks. He pleaded guilty in London to fraud by abuse of position and transferring criminal property and was sentenced to six years on 18 December 2025. He said he acted as a whistleblower; Decrypt reported the judge was unsympathetic. No court has commented on pump.fun's controls; here it was the victim.

November 2024: livestreams paused

After reports of disturbing streams circulated, pump.fun paused the feature “for an indefinite time period.” Its co-founder said hundreds of videos had been removed and that moderation “hasn't been great.” DL News could not verify the worst clips, and later reported that the incident which triggered the pause was staged.

April 2025: livestreams return

Streaming came back with a written policy banning violence, self-harm promotion and harassment. It is “enforced at the sole discretion of pump.fun,” which “may not discover every violation.” It describes no age check and publishes no enforcement figures. In October 2025 a streamer whose firework injured a girl was banned the same day.

June 2026: a bounty marketplace

pump.fun launched GO on 4 June 2026, paying crypto for completed tasks. Within days Unchained reported listings that included one tied to suicide, one to track down and film a convicted killer's family, and forehead tattoos, one of which a man in India carried out. The article reports no statement from pump.fun. New York's governor called it a “dystopian nightmare”; a bill on meme-coin bounty sites, which does not name pump.fun, was introduced in the Assembly on 29 July. GO's terms say it “is not the creator, sponsor, or guarantor of user activity” and “has final say” over every payout.

September 2026: off the App Store, then back

The app disappeared from Apple's US and India stores on 10 September, the day after pump.fun launched coins paired with tokenised stocks. Apple gave no reason. On 9 October it is listed again in both, at version 29.0.0 dated 7 October, and absent from the UK store.

September 2026: a second regulator

On 25 September 2026 Québec's Autorité des marchés financiers put Pump.fun on its warning list, naming Baton Corporation LTD as another business name. It says the firm is not registered with the AMF and is not authorised to solicit Québec investors. Like the FCA's entry, it is a warning, not an order or a finding.

What Project Ascend was

A publicly announced creator-fee programme: tiered fees by market cap, published on-chain, reported across the trade press. Its one AI component is the disclosed trading agent above. Nothing connects it to social accounts.

The 29 September deployments

A sweep of 45 classic altcoin names across Solana found one token created on that date. The meta's largest coin was minted in March 2025 and peaked two months later.

The idea that survives

“The market ran on one unspoken rule: value equals labor. AI closed that gap.”

True of the whole sector, whoever is doing the faking. Attribution to one company is the part never evidenced.

What the case does not contain

The 79-page opinion has no “artificial intelligence,” “sniper,” “market maker,” “wash trading” or “Ascend.” “Bot” appears only for third parties paying priority fees. The pleaded scheme is people, contracts and messages.

“3% tax on every transfer,” including wallet-to-wallet

Coins launched in StonkFun's reward mode are Token-2022 mints with a 1% or 3% fee on every transfer. Verified on-chain: a pool sent 2,712,899 tokens and the buyer received 2,685,770, exactly 99%. A self-transfer of 7,372 GP arrived as 7,150, exactly 97%. Disclosed on stonkfun.xyz/rewards since at least 6 September: “a transfer tax on every transfer (1% or 3%, set at launch).” The STONK governance token itself is a legacy SPL mint and cannot carry a tax, which is a footnote, not a rebuttal.

“2.5%–4% fees on both sides”

True for reward-mode coins: 1% curve fee plus the 1% or 3% tax, so 2–4% per side; older reward pools charged 4%. Not true of standard launches, which cost 1.25% per side, the same as pump.fun's curve. No StonkFun configuration produces exactly 2.5% on a trade; the 2.5% figure is the operating cut taken from each reward pot.

“The pumpfun app having 0% fees”

This repeats pump.fun's own marketing. Its official account posted “Trade with ZERO fees” on 7 August 2026. The app adds no interface fee, but pump.fun's fee page still charges 1.25% per curve trade. Until 8 October 2026 it also carried a footnote adding “up to .1%” on some mobile transactions, with fees that “may not be separately stated in the total transaction cost.”

An “auto sell bot”

The tax is withheld in the launched coin; to pay holders in the paired stock, the platform's authority harvests it and sells it. On 22 September that authority ran roughly 3,000 transactions in 44 minutes. StonkFun's rewards disclaimer says so: “Collection, sale, and distribution run on automated systems.” It sells only the 1–3% tax, which is how every reflection token has worked since 2021. “Kills coins” is opinion. pump.fun's Mayhem Mode is a different, opt-in mechanism that mints and trades its own supply.

“Does exactly what his platform did for two years”

Prior art is real: a tax-token launchpad with reflection rewards existed from March 2025, about 16 months earlier, not two years. Its pages document fee-sharing in SOL, USDC or “any tradeable token”; nothing found there pairs launches against tokenized stocks, which is StonkFun's differentiator. Prior art is not wrongdoing in either direction.

“They got free supply or inside the bundle”

No dev bundle and no team allocation: one billion STONK minted, mint authority revoked in the same transaction, all of it deposited to the pool, and the creating wallet placed no buys. In the next 52 seconds, 28 wallets bought 38% of supply in same-block clusters of near-identical size, the signature of sniper bots. All 28 hold zero today. Whether they were third parties or insiders cannot be determined from the chain, and nothing links them to any promoter.

The platform can change the tax after launch

The rewards page says the rate is “set permanently at launch.” On reward mints the platform key that harvests the tax is also the transfer-fee authority, which under Token-2022 is the entity that can modify the rate. No evidence it has ever been used. The capability contradicts the wording.

Rewards are discretionary by contract

“StonkFun collects some of these amounts as platform revenue and may, at its sole discretion and from time to time, use some of them to make distributions.”

Mechanisms “may be changed, paused, or ended at any time without notice.” A 2.5% operating cost comes off each pot, and only wallets holding $20 or more are paid.

A misconfigured launch taxes holders with no payout

“If it is not [adopted] — wrong curve, wrong config, an unpublished tax rate — the tax accrues and is never distributed to anyone.”

Only the platform key can withdraw that withheld amount.

Who runs it

The team is pseudonymous. The terms say the operator is “a corporation” whose legal name and address are “available on request.” They disclose that StonkFun is “not registered, designated, or licensed by the U.S. CFTC or any other regulatory authority,” and make US, Canadian and UK persons “Restricted Users” by contract only; the client blocks sanctioned jurisdictions, not those. Solana's official account replied to a StonkFun post on 5 September: “We stand behind Stonk Tokens.”

Baton

The complaint “offers only speculation, unsupported hypotheses, alleged parallel commercial conduct, and inactionable puffery.”

Baton argues a New York court has no jurisdiction over a UK company, that users “transacted directly with the ‘bonding curve’” so it is no money transmitter, and that any losses were caused by independent traders. The founders say the suit repackages failed securities claims.

What they have won

The securities counts, the gambling theory, unjust enrichment, every claim against the Solana defendants, the lead plaintiff's own claims, and recovery of trading losses were all dismissed. The SEC's staff said in February 2025 that typical meme-coin sales “do not involve the offer and sale of securities.”

What nobody has done

No charge, enforcement action, subpoena or settlement by the SEC, CFTC, DOJ, FinCEN, OFAC, the FTC, a state attorney-general, the FCA or any EU regulator has been made public. Investigations that are not public would not show here. The defendants' answer in New York is due 15 October 2026.

Racketeering, substantive and conspiracy

Against Baton, Cohen, Kerler and Tweedale. Predicates: wire fraud and unlicensed money transmission. Injuries: the 1% fee on induced trades, and execution losses.

Securities, gambling, unjust enrichment, Solana

Memecoins here were not investment contracts. Buying one is not a wager. All claims against Solana Labs, the Solana Foundation and five executives dismissed with prejudice.

Trading losses are not damages

“The bonding curve dictated how a trade affected price, but it did not dictate whether that trade would occur.”

Too indirect to recover. Only fees and execution losses survive.