Jeremy Ryan v. Best In Slot, LLC, et al.

Summary

The United States District Court for the Southern District of California partially dismissed Jeremy Ryan’s second amended complaint against Best In Slot, LLC and related defendants following mandatory screening under 28 U.S.C. § 1915(e)(2). The court allowed contract, promissory-estoppel, and unjust-enrichment claims to proceed, but dismissed fraud-based claims for failure to satisfy pleading requirements. Ryan was granted leave to file a third amended complaint or elect to proceed on the surviving claims by November 14, 2025.

Holdings

1. The allegations that defendants promised to distribute 100% of tokens to stakers, that Ryan accepted and relied on the promise by staking, and that defendants breached the promise through overselling or overallocating tokens were sufficient to allow the breach-of-contract claim to proceed past screening. The same allegations also sufficiently supported alternative promissory-estoppel and unjust-enrichment theories.
2. The intentional-misrepresentation, negligent-misrepresentation, unfair-business-practices, and false-advertising claims were insufficient because the complaint did not identify each defendant's role, did not specify when the alleged representations were made, and did not plausibly allege fraudulent intent at the time of the promise.
3. The court granted Ryan one final opportunity to amend the dismissed claims or elect to proceed on the surviving claims.

Questions Presented

1. Whether the contract, promissory-estoppel, and unjust-enrichment claims were sufficiently pleaded to survive mandatory in forma pauperis screening.
2. Whether the fraud-based claims satisfied Federal Rule of Civil Procedure 9(b)'s particularity requirement and the plausibility standard.
3. Whether the plaintiff should receive leave to amend the dismissed claims.

Disposition

other