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SEC v. Coinbase, Inc.

investment contractsecondary-market salesstakingunregistered exchange
Forum
U.S. District Court, Southern District of New York
Docket
No. 1:23-cv-04738-KPF
Decided
2024-03-27
Judge
Judge Katherine Polk Failla
Posture
Motion for judgment on the pleadings
Agency
SEC
Status
Dismissed. The SEC voluntarily dismissed the case in February 2025. The 2024 ruling is no longer being litigated, but its Howey reasoning is widely cited.

Summary

The court denied Coinbase's motion on nearly all claims, holding the SEC adequately alleged that 13 listed tokens were investment-contract securities, that Coinbase's staking program was an unregistered securities offering, and that Coinbase operated as an unregistered broker, exchange, and clearing agency. Only the "Wallet" software claim was dismissed.

Holdings

Can secondary-market token sales be investment contracts without a contractual undertaking by the issuer?

Yes. The court rejected drawing a line between primary and secondary-market buyers, directly opposite to Ripple's programmatic-sales holding.

Quote as reported (operator-verify): “there is little logic to the distinction Defendants attempt to draw between the reasonable expectations of investors who buy directly from an issuer and those who buy on the secondary market.”

Source: Goodwin Fintech & Digital Assets blog (quoting the opinion) · fetched 2026-06-04

Does Howey require a post-sale contractual undertaking?

No. The court declined to read a contractual-undertaking requirement into Howey.

Quote as reported (operator-verify): “since Howey, no court has adopted a contractual undertaking requirement. . . This Court declines to be the first.”

Source: Goodwin Fintech & Digital Assets blog (quoting the opinion) · fetched 2026-06-04

Why it matters

Coinbase is the counterweight to Ripple: a different SDNY judge held secondary sales can be securities and that no contractual undertaking is required. The SEC's 2025 dismissal reflects the post-2024 policy shift, not a court reversal.

Mortgage relevance

Low directly. Bears on whether the exchanges holding a borrower's crypto are operating lawfully as registered venues: part of "U.S.-regulated exchange" diligence.

Operator-verify. This is a point-in-time summary, not legal advice. Quotes are sourced to the URLs above and have not yet been mechanically confirmed against the official opinion. Confirm any quote and holding against the court’s published opinion before relying on it.