According to the Complaint, TerraForm Labs Ptd Ltd. is a company that operates the Terra blockchain and its related protocol, which hosts, supports, and funds a community of decentralized financial applications and products known collectively as the Terra ecosystem.

The Complaint alleges that, even though the Terra Tokens bear all the hallmarks of being investment contracts and, thus, securities under the Howey test, no registration statements have been filed with the SEC with respect to the various Terra Tokens. The Complaint further alleges that, in addition to selling unregistered securities with the Terra Tokens, Defendants made a series of false and misleading statements regarding the largest Terra ecosystem digital assets by market cap, UST and LUNA, in order to induce investors into purchasing these digital assets at inflated rates. In addition to the federal securities and other states' claims, the Complaint also alleges that Defendants conducted and participated in the conduct of the affairs of the Terra Token Enterprise through a pattern of racketeering activity, including acts relating to mail fraud and wire fraud.

On December 13, 2022, the Court issued an Order appointing Lead Plaintiff and Counsel. Lead Plaintiff filed an amended Complaint on January 13, 2023. Lead Plaintiff filed a second amended Complaint on February 23.

Lead Plaintiff voluntarily dismissed four of the Defendants on September 8, 2023. Lead Plaintiff voluntarily dismissed the Terraform Labs Defendants on September 28.

On January 4, 2024, the Court issued an Order granting the Jump Trading LLC Defendants' Motion to Dismiss the second amended Complaint. Plaintiff was given leave to amend the Complaint.

Lead Plaintiff filed a third amended Complaint on January 25, 2024.