{"investigation":{"slug":"baton-corporation-pump-fun-parent","entity_name":"Baton Corporation (Pump.fun parent)","trust_score":12,"severity_base":null,"score_modifier":0,"confidence":0.72,"status":"draft","content_type":"investigation","summary":"Baton Corporation Ltd. is the corporate parent of Pump.fun, a Solana-based memecoin launchpad founded in January 2024 by Noah Tweedale, Alon Cohen, and Dylan Kerler. The platform has generated hundreds of millions of dollars in transaction fees while independent research has repeatedly found that the overwhelming majority of tokens launched on it end in total loss for buyers. Baton Corporation and its three named founders are current RICO defendants in a federal class action in the Southern District of New York, where a judge allowed wire fraud, illegal gambling, and unlicensed money-transmission racketeering claims to survive a motion to dismiss on August 31, 2026, while dismissing related securities and unjust-enrichment claims and dropping Solana Labs and the Solana Foundation from the case entirely.","sections":[{"content":"Baton Corporation Ltd. (d/b/a Pump.fun) and its three co-founders — CEO Noah Tweedale, COO Alon Cohen, and CTO Dylan Kerler — are defendants in a consolidated federal class action, Aguilar v. Baton Corporation Ltd., Case No. 1:25-cv-00880, pending in the U.S. District Court for the Southern District of New York before Judge Colleen McMahon. The suit originated from a January 30, 2025 complaint led by plaintiff Diego Aguilar alleging Pump.fun operated as an unregistered securities exchange and 'joint issuer' of memecoins, and was later consolidated with a related PNUT token case and amended to add racketeering allegations. Plaintiffs allege Baton Corporation and its founders ran a 'coordinated racketeering enterprise' that used automated tools to let anyone create low-value tokens, allowed insiders to accumulate tokens pre-launch, and coordinated paid promoters to manufacture retail demand before timed exits. On August 31, 2026, Judge McMahon ruled on the pending motions to dismiss: she dismissed the Securities Act claims (finding the two remaining memecoins at issue, FRED and GRIFFAIN, did not satisfy the Howey test's 'common enterprise' element), dismissed unjust-enrichment claims, dismissed all claims against Solana Labs Inc., the Solana Foundation, and named Solana executives (Anatoly Yakovenko, Raj Gokal, Dan Albert, Austin Federa, and Lily Liu), and dismissed the RICO claims brought specifically by plaintiff Aguilar. However, she allowed the RICO and RICO-conspiracy claims (18 U.S.C. §§ 1962(c) and (d)) brought by plaintiffs Okafor and Carnahan to proceed against Baton Corporation and its three founders, based on predicate acts of wire fraud (tied in part to Cohen's public statements describing the platform as an 'unruggable fair launch'), illegal gambling operation, and unlicensed money transmission. Sources differ slightly on whether a standalone New York-law gambling claim was also dismissed while the RICO illegal-gambling predicate survived; multiple outlets confirm illegal gambling is among the surviving RICO predicates against Baton Corp specifically. Plaintiffs allege aggregate retail losses of $4 billion to $5.5 billion, with reporting indicating that if RICO liability is established, the treble-damages provision could theoretically expose defendants to guardrails in the range of $16.5 billion, though this figure is a plaintiff-side estimate reported by industry press rather than a court-adopted figure, and the court's August 2026 order specifically noted that trading losses face proximate-causation problems while execution losses and transaction fees survived as a narrower damages theory. As of September 2026, 25 anonymous 'Key Opinion Leader' promoter defendants named in the complaint reportedly remain unserved, and Judge McMahon required plaintiffs' counsel to explain the delay by September 10, 2026.","heading":"Active RICO Litigation — Aguilar v. Baton Corporation","sources":[{"url":"https://www.cryptotimes.io/2026/09/01/judge-dismisses-pump-fun-securities-claims-clears-solana-labs-and-foundation/","name":"Judge Dismisses Pump.fun Securities Claims and Clears Solana Labs and Foundation. RICO Against Founders Survives. — CryptoTimes","type":"news_article","credibility":2},{"url":"https://thecurrencyanalytics.com/altcoins/solana-labs-dropped-from-pump-fun-suit-as-rico-claims-survive-against-baton-corp-289427","name":"Solana Labs Dropped from Pump Fun Suit as RICO Claims Survive Against Baton Corp — The Currency Analytics","type":"news_article","credibility":2},{"url":"https://protos.com/solana-labs-dropped-from-burwick-laws-pump-fun-lawsuit/","name":"Solana Labs dropped from Burwick Law's Pump Fun lawsuit — Protos","type":"news_article","credibility":2},{"url":"https://www.burwick.law/active-cases/pump-fun-and-solana-rico-lawsuit-aguilar-v-baton-corporation","name":"Pump.fun and Solana RICO Lawsuit: Aguilar v. Baton Corporation — Burwick Law","type":"court_filing","credibility":1},{"url":"https://www.courtlistener.com/docket/69593359/aguilar-v-baton-corporation-ltd-dba-pumpfun/","name":"Aguilar v. Baton Corporation Ltd. d/b/a Pump.Fun — CourtListener docket","type":"court_filing","credibility":1},{"url":"https://www.coindesk.com/policy/2025/01/30/pump-fun-hit-with-proposed-class-action-lawsuit-alleging-securities-violations","name":"Pump.Fun Hit With Proposed Class Action Lawsuit Alleging Securities Violations — CoinDesk","type":"news_article","credibility":1},{"url":"https://cryptovalleyjournal.com/focus/legal-and-compliance/pump-fun-and-solana-5-5-billion-usd-rico-class-action-lawsuit-over-memecoin-platform/","name":"Pump.fun and Solana: USD 5.5 Billion RICO Class Action Lawsuit Over Memecoin Platform — Crypto Valley Journal","type":"news_article","credibility":2}],"severity":"critical"},{"content":"Plaintiffs' counsel (Burwick Law, representing lead plaintiff Michael Okafor and others) obtained more than 5,000 internal chat messages from a confidential informant who allegedly resurfaced around September 2025. Attorney Max Burwick has stated the logs contain 'multiple direct communications' between engineers at Solana Labs and Pump.fun/Baton Corporation employees discussing the 'integration of key software components,' which plaintiffs characterize as evidence of coordinated back-end favoritism inconsistent with Pump.fun's public 'fair launch' marketing. The complaint also alleges that Jito Labs' transaction-ordering ('tipping') infrastructure allowed favored traders to jump transaction queues, undermining claims of fair, random ordering. Judge McMahon permitted plaintiffs to file a second amended complaint incorporating this material, finding it was not previously available and that plaintiffs had acted diligently, with the amended pleading filed on or around January 7, 2026. Despite this evidentiary basis being sufficient to survive dismissal against Baton Corporation and its founders, the same underlying theory did not save the claims against Solana Labs and its executives, which the court dismissed in the August 31, 2026 order — indicating the court found the chat-log allegations insufficient to establish the Solana-side defendants' liability even though they sufficed against Baton Corp. This distinction has not been fully explained in public reporting and independent verification of the chat logs' authenticity and content has not been possible from public sources; the allegations should be treated as unproven claims pending further discovery or trial.","heading":"Whistleblower Chat Logs and Alleged Coordination","sources":[{"url":"https://www.dlnews.com/articles/defi/solana-execs-sued-over-memecoin-trades/","name":"Solana, Pump.fun execs sued. Lawsuit claims 5,000 private messages prove 'insider-rigged casino' — DL News","type":"news_article","credibility":2},{"url":"https://finance.yahoo.com/news/whistleblower-drops-5-000-secret-210125260.html","name":"Whistleblower Drops 5,000+ Secret Chats in Pump.fun MEV Scandal — Lawsuit Intensifies — Yahoo Finance","type":"news_article","credibility":2},{"url":"https://yellow.com/news/judge-approves-expansion-of-solana-pumpfun-lawsuit-after-5000-internal-chats-surface","name":"Judge Approves Expansion Of Solana 'Pump.fun' Lawsuit After 5,000 Internal Chats Surface — Yellow.com","type":"news_article","credibility":2}],"severity":"high"},{"content":"Pump.fun charges a 1% swap fee on trades executed through its bonding-curve mechanism and an additional fee (historically around 1.5 SOL) when a token 'graduates' to a decentralized exchange after reaching roughly a $90,000 market cap. Reported cumulative platform fee revenue has been estimated at different points at approximately $500 million (February 2025, per Forbes), roughly $700 million (April 2026, per market-data aggregators), and nearly $800 million since launch (per Wikipedia, citing on-chain data), while a separate analysis of on-chain fee flow in August 2026 implied an annualized run rate of roughly $460–500 million based on then-current monthly fee volume — a figure that appears to be the likely source of the '$460 million+' figure attributed to the platform in some secondary reporting, though it should not be read as a court-verified damages figure specific to the RICO case. Independent research is starkly negative on outcomes for platform users: a widely cited Solidus Labs report found that approximately 98.6% of tokens launched on Pump.fun have characteristics consistent with rug pulls or pump-and-dump schemes, with only roughly 97,000 of more than 7 million launched tokens maintaining even $1,000 in liquidity. Separate reporting citing the underlying litigation states that more than 4.25 million wallets traded on the platform in 2024 and that more than 60% of them incurred net losses. Pump.fun has publicly disputed the Solidus Labs framing, with a spokesperson arguing that most memecoins, 'like NFTs, tweets, IG posts, trading cards, and most art,' are 'worth little in the long run' — a characterization that does not dispute the underlying loss statistics.","heading":"Platform Economics: Fee Extraction vs. User Outcomes","sources":[{"url":"https://www.coindesk.com/business/2025/05/07/98-of-tokens-on-pump-fun-have-been-rug-pulls-or-an-act-of-fraud-new-report-says","name":"Pump.Fun Hits Back at Report That Claimed 98% of Memecoins on the Platform Are Fraudulent — CoinDesk","type":"news_article","credibility":1},{"url":"https://news.bitcoin.com/report-exposes-98-6-of-solana-meme-coins-on-pump-fun-as-fraudulent/","name":"Report Exposes 98.6% of Solana Meme Coins on Pump.fun as Fraudulent — Bitcoin.com News","type":"news_article","credibility":2},{"url":"https://defillama.com/protocol/pump.fun","name":"pump.fun Fees, Revenue & Volume — DefiLlama","type":"on_chain","credibility":2},{"url":"https://www.forbes.com/sites/boazsobrado/2025/02/22/from-memes-to-500-million-in-revenue-the-pumpfun-phenomenon/","name":"From Memes To $500 Million In Revenue: The Pump.Fun Phenomenon — Forbes","type":"news_article","credibility":1},{"url":"https://en.wikipedia.org/wiki/Pump.fun","name":"pump.fun — Wikipedia","type":"other","credibility":2},{"url":"https://www.dlnews.com/articles/defi/solana-execs-sued-over-memecoin-trades/","name":"Solana, Pump.fun execs sued. Lawsuit claims 5,000 private messages prove 'insider-rigged casino' — DL News","type":"news_article","credibility":2}],"severity":"high"},{"content":"In December 2025, the UK Financial Conduct Authority (FCA) issued a public consumer warning stating that Pump.fun is not authorised or registered to conduct regulated activities in the United Kingdom, and that UK users trading through it would not have access to protections from the Financial Ombudsman Service or the Financial Services Compensation Scheme. Within days, Pump.fun updated its terms of service to exclude UK users, blocking access from the country. This is a confirmed regulatory action by a Tier 1 government financial regulator, though it is a warning/access-restriction rather than an enforcement or penalty action.","heading":"UK FCA Warning and Access Restrictions","sources":[{"url":"https://www.fca.org.uk/news/warnings/pumpfun","name":"Pump.fun — FCA official warning","type":"regulatory","credibility":1},{"url":"https://www.theblock.co/post/329804/uk-top-financial-regulator-says-pump-fun-doesnt-have-its-permission-to-do-business-in-the-country","name":"UK top financial regulator says Pump.fun doesn't have its permission to do business in the country — The Block","type":"news_article","credibility":1},{"url":"https://cryptoslate.com/pump-fun-updates-terms-to-block-uk-users-days-after-fca-warning/","name":"Pump Fun updates terms to block UK users days after FCA warning — CryptoSlate","type":"news_article","credibility":2}],"severity":"medium"},{"content":"Pump.fun's iOS app was removed from Apple's U.S. and India App Stores in September 2026, one day after the platform launched 'Custom Pairs,' a feature allowing users to create memecoins quoted against tokenized versions of publicly traded stocks (reportedly including names such as Boeing and Costco), covering roughly 93 asset pairs. Neither Apple nor Pump.fun has publicly disclosed the specific reason for the removal as of this writing. Pump.fun stated existing app users' funds remained accessible and unaffected, and that the web platform and Android/Google Play access were unaffected. The company's PUMP token declined roughly 12% in the 24 hours following the delisting, trading below its original ICO debut price. The near-simultaneous timing of a stock-pair product launch and an unexplained app store removal is suggestive of a compliance concern (e.g., unregistered securities-linked products) but this is inference from timing, not a confirmed causal statement from either company.","heading":"Apple App Store Delisting (September 2026)","sources":[{"url":"https://protos.com/one-day-after-launching-stock-pairs-apple-delists-pump-fun-app/","name":"One day after launching stock pairs, Apple delists Pump Fun app — Protos","type":"news_article","credibility":2},{"url":"https://www.cryptotimes.io/2026/09/11/pump-fun-app-vanishes-from-apples-us-and-india-stores-funds-remain-safe/","name":"Pump.fun App Vanishes From Apple's US and India Stores. Funds Are Safe and No Cause Has Been Given. — CryptoTimes","type":"news_article","credibility":2},{"url":"https://moneycheck.com/pump-fun-pump-token-plunges-12-as-ios-app-gets-removed-from-app-stores/","name":"Pump.Fun (PUMP) Token Plunges 12% as iOS App Gets Removed from App Stores — MoneyCheck","type":"news_article","credibility":2}],"severity":"medium"},{"content":"In November 2024, Pump.fun's livestreaming feature was linked to a series of alleged harmful and dangerous incidents, including a user allegedly threatening suicide on camera if a token's price target was not reached, faked self-harm, threats to harm pets and family members, and other extreme content used to manipulate token prices. Pump.fun suspended livestreaming platform-wide on November 25, 2024, stating it needed to build out moderation infrastructure before restoring the feature, and later relaunched it with a published moderation policy banning violence, harassment, sexual exploitation, and illegal activity. This episode is documented primarily in crypto-industry press (Decrypt, CryptoBriefing, DL News); no regulatory or law-enforcement action specific to the livestream incidents has been identified in available sources.","heading":"Livestream Safety Failures","sources":[{"url":"https://decrypt.co/293365/animal-cruelty-self-harm-livestream-allegations-the-dark-side-of-pump-fun","name":"Animal Cruelty, Self-Harm Livestream Allegations: The Dark Side of Pump.fun — Decrypt","type":"news_article","credibility":2},{"url":"https://cryptobriefing.com/pump-fun-livestream-halt/","name":"Pump.fun halts livestreams indefinitely after community backlash — CryptoBriefing","type":"news_article","credibility":2},{"url":"https://www.dlnews.com/articles/defi/pump-fun-revives-livestreams-after-chaos-cratering-volume/","name":"Pump.Fun quietly revives livestreams after pet threats, on-air chaos, and cratering volumes — DL News","type":"news_article","credibility":2}],"severity":"medium"},{"content":"Pump.fun's parent entity is identified across sources as Baton Corporation Ltd. Court filings and legal-firm case pages describe Baton Corporation as pump.fun's registered parent company, though sources are inconsistent about the exact jurisdiction of incorporation — some describe it as UK-registered, while the entity's litigation is styled with an address consistent with an offshore (British Virgin Islands-linked) structure common to crypto platforms; this investigation could not independently confirm the precise incorporation jurisdiction from a primary corporate registry source, so this detail carries lower confidence than the litigation facts above. The platform was founded in January 2024 by three UK-based entrepreneurs — Noah Tweedale (CEO), Alon Cohen (COO, operating publicly under the handle 'alon'), and Dylan Kerler (CTO) — who reportedly met at Oxford and had prior experience building an NFT perpetuals trading platform (Nftperp) before founding Pump.fun. In July 2025, the company conducted a PUMP token ICO that reportedly raised roughly $1.3 billion combined across public and private sales (with the public portion, around $600 million, selling out in approximately 12 minutes), excluding US and UK participants. All three founders are named as individual RICO defendants in the ongoing SDNY litigation described above.","heading":"Corporate Structure and Founders","sources":[{"url":"https://en.wikipedia.org/wiki/Pump.fun","name":"pump.fun — Wikipedia","type":"other","credibility":2},{"url":"https://www.burwick.law/active-cases/pump-fun-and-solana-rico-lawsuit-aguilar-v-baton-corporation","name":"Pump.fun and Solana RICO Lawsuit: Aguilar v. Baton Corporation — Burwick Law","type":"court_filing","credibility":1},{"url":"https://www.coindesk.com/policy/2025/01/30/pump-fun-hit-with-proposed-class-action-lawsuit-alleging-securities-violations","name":"Pump.Fun Hit With Proposed Class Action Lawsuit Alleging Securities Violations — CoinDesk","type":"news_article","credibility":1}],"severity":"medium"}],"timeline":[{"date":"2024-01-19","event":"Pump.fun platform launches on Solana.","source":"Wikipedia (pump.fun)","source_url":"https://en.wikipedia.org/wiki/Pump.fun","date_evidence":"the platform launching January 19, 2024"},{"date":"2024-11","event":"Pump.fun suspends livestreaming platform-wide following reports of self-harm threats and other extreme content used to manipulate token prices.","source":"CryptoBriefing / Decrypt","source_url":"https://cryptobriefing.com/pump-fun-livestream-halt/","date_evidence":"On November 25, Pump.Fun pulled the plug amid mounting criticism","date_original":"2024-11-25"},{"date":"2025-01-30","event":"Lead plaintiff Diego Aguilar files initial class action against Baton Corporation and founders alleging Pump.fun operated as an unregistered securities exchange (Aguilar v. Baton Corporation Ltd., SDNY).","source":"CoinDesk","source_url":"https://www.coindesk.com/policy/2025/01/30/pump-fun-hit-with-proposed-class-action-lawsuit-alleging-securities-violations","date_evidence":"Filing Date: January 30, 2025"},{"date":"2025-07","event":"Consolidated amended complaint filed adding RICO, illegal-gambling, and additional defendants (including Solana Labs, Solana Foundation, and Jito entities), alleging aggregate retail losses of $4-5.5 billion.","source":"Crypto Valley Journal / Hodder Law","source_url":"https://cryptovalleyjournal.com/focus/legal-and-compliance/pump-fun-and-solana-5-5-billion-usd-rico-class-action-lawsuit-over-memecoin-platform/"},{"date":"2025-07","event":"Pump.fun conducts PUMP token public ICO, reportedly raising roughly $1.3 billion combined across public and private sales, with the public sale selling out in about 12 minutes.","source":"Wikipedia (pump.fun)","source_url":"https://en.wikipedia.org/wiki/Pump.fun"},{"date":"2025-12","event":"UK Financial Conduct Authority issues a public warning that Pump.fun is not authorised to conduct regulated activity in the UK; Pump.fun updates terms of service to exclude UK users days later.","source":"FCA / The Block","source_url":"https://www.fca.org.uk/news/warnings/pumpfun"},{"date":"2025-12","event":"Judge McMahon permits plaintiffs to file a second amended complaint incorporating over 5,000 internal chat logs obtained from a confidential informant alleging coordination between Solana Labs and Pump.fun engineers.","source":"Yellow.com / DL News","source_url":"https://yellow.com/news/judge-approves-expansion-of-solana-pumpfun-lawsuit-after-5000-internal-chats-surface"},{"date":"2026-01","event":"Second amended consolidated complaint filed in Aguilar v. Baton Corporation, incorporating the chat-log allegations and RICO claims.","source":"Burwick Law case page","source_url":"https://www.burwick.law/active-cases/pump-fun-and-solana-rico-lawsuit-aguilar-v-baton-corporation","date_original":"2026-01-07"},{"date":"2026-08","event":"Judge Colleen McMahon (SDNY) rules on motions to dismiss: dismisses Securities Act and unjust-enrichment claims and drops Solana Labs, the Solana Foundation, and named Solana executives from the case entirely; allows RICO wire fraud, illegal gambling, and unlicensed money transmission claims to proceed against Baton Corporation and founders Tweedale, Cohen, and Kerler.","source":"CryptoTimes / Protos / The Currency Analytics","source_url":"https://www.cryptotimes.io/2026/09/01/judge-dismisses-pump-fun-securities-claims-clears-solana-labs-and-foundation/","date_original":"2026-08-31"},{"date":"2026-09","event":"Pump.fun launches 'Custom Pairs' feature allowing memecoins to be quoted against tokenized versions of publicly traded stocks; Apple removes the Pump.fun iOS app from the US and India App Stores approximately one day later without disclosed cause.","source":"Protos / CryptoTimes","source_url":"https://protos.com/one-day-after-launching-stock-pairs-apple-delists-pump-fun-app/"}],"sources_used":[{"url":"https://www.cryptotimes.io/2026/09/01/judge-dismisses-pump-fun-securities-claims-clears-solana-labs-and-foundation/","name":"Judge Dismisses Pump.fun Securities Claims and Clears Solana Labs and Foundation. RICO Against Founders Survives. — CryptoTimes","type":"news_article","archive_url":"http://web.archive.org/web/20260914211623/https://www.cryptotimes.io/2026/09/01/judge-dismisses-pump-fun-securities-claims-clears-solana-labs-and-foundation/","credibility":2,"archive_timestamp":"2026-09-14T21:16:23+00:00"},{"url":"https://thecurrencyanalytics.com/altcoins/solana-labs-dropped-from-pump-fun-suit-as-rico-claims-survive-against-baton-corp-289427","name":"Solana Labs Dropped from Pump Fun Suit as RICO Claims Survive Against Baton Corp — The Currency Analytics","type":"news_article","archive_url":"http://web.archive.org/web/20260914211442/https://thecurrencyanalytics.com/altcoins/solana-labs-dropped-from-pump-fun-suit-as-rico-claims-survive-against-baton-corp-289427","credibility":2,"archive_timestamp":"2026-09-14T21:14:42+00:00"},{"url":"https://protos.com/solana-labs-dropped-from-burwick-laws-pump-fun-lawsuit/","name":"Solana Labs dropped from Burwick Law's Pump Fun lawsuit — Protos","type":"news_article","archive_url":"https://web.archive.org/web/20260915041130/https://protos.com/solana-labs-dropped-from-burwick-laws-pump-fun-lawsuit/","credibility":2,"archive_timestamp":"2026-09-15T04:11:30+00:00"},{"url":"https://www.burwick.law/active-cases/pump-fun-and-solana-rico-lawsuit-aguilar-v-baton-corporation","name":"Pump.fun and Solana RICO Lawsuit: Aguilar v. 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