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SEC v. Ripple Labs, Inc.

investment contractHowey testsecondary-market salesXRP
Forum
U.S. District Court, Southern District of New York
Citation
682 F. Supp. 3d 308 (S.D.N.Y. 2023)
Docket
No. 1:20-cv-10832
Decided
2023-07-13
Judge
Judge Analisa Torres
Posture
Cross-motions for summary judgment
Agency
SEC
Status
Settled. The parties resolved the matter in 2025 (a reduced civil penalty) and the SEC's appeal was wound down. The reasoning is widely cited but is a district-court decision, not binding precedent.

Summary

The first major split-decision on token sales. Judge Torres distinguished among three ways XRP was distributed: "Institutional Sales" to sophisticated buyers under written contracts WERE unregistered securities; "Programmatic Sales" to anonymous buyers on exchanges were NOT; and certain other distributions were not investment contracts.

Holdings

Is XRP itself a security?

The token by itself is not a security; the analysis turns on the circumstances of each offer and sale, not on the asset.

Quote as reported (operator-verify): “XRP, as a digital token, is not in and of itself a "contract, transaction[,] or scheme" that embodies the Howey requirements”

Source: Mayer Brown (quoting the opinion) · fetched 2026-06-04

Were Programmatic (exchange) sales investment contracts?

No. Anonymous buyers on exchanges could not know they were buying from Ripple and did not reasonably expect profits from Ripple's efforts, so programmatic sales failed Howey's expectation-of-profits prong. Institutional sales under written contract, by contrast, were unregistered securities.

Source: Mayer Brown · fetched 2026-06-04

Why it matters

Ripple created the "manner of sale matters" theory: the same token can be a security in one transaction and not in another. The SEC and other judges (see Terraform) rejected the institutional/programmatic distinction, creating the split the 2026 SEC-CFTC interpretation and the CLARITY Act try to resolve.

Mortgage relevance

Low directly, but it underlies which crypto exchanges count as "regulated" and how a borrower's tokens are classified: relevant to GSE crypto-reserve eligibility once that guidance publishes.

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.