Johnson v. Maker Ecosystem Growth Holdings, Inc.

BACKGROUND

21 Defendants are “two affiliated foreign companies” that, according to plaintiff, 22 “collectively operate, run, and manage the Maker Ecosystem, a cryptocurrency platform” 23 (see Second Amended Class Action Complaint (“SAC”) at 1, Dkt. No. 69), and, in the 24 course thereof, committed acts constituting “neglect and malfeasance” (see SAC ¶ 3). In 25 particular, plaintiff alleges the following events occurred. 26 27 Defendants2 “developed a digital currency” called DAI (see SAC ¶ 13) and, in connection therewith, a “protocol and various applications necessary for minting, collateralizing, and transacting the DAI[,]” namely, the “Maker Protocol” (see SAC ¶ 13). The Maker Protocol “involves the collateralization of digital assets” to “create a stable coin—DAI—which is a decentralized, unbiased, collateral-backed cryptocurrency soft- pegged to the US Dollar.” (See SAC ¶ 14 (internal quotations omitted).) Once created, DAI “is a store of value, a medium of exchange, a unit of account and a standard of deferred payment” that is “meant to be exchanged digitally between peers in exchange for other digital assets or services, just…