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Dkt. #271 — Defendants' Memo of Law in Support of MTD
Defendants' memorandum of law in support of their motion to dismiss. Provides detailed legal analysis of why CFTC lacks jurisdiction over Ethereum SPOT transactions.
Document Details
Date Filed
October 17, 2023
Agency
Court Filing
Recipient
U.S. District Court, N.D. Illinois
File
Defendants_Memo_Law_MTD_Dkt271.pdf
272 KB
Page 1 / 24
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IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
COMMODITY FUTURES TRADING
COMMISSION,
Plaintiff,
v.
SAM IKKURTY A/K/A SREENIV ASI
RAO, RAVISHANKAR AVADHANAM,
AND JAFIA LLC,
Defendants,
IKKURTY CAPITAL, LLC D/B/A ROSE
CITY INCOME FUND, ROSE CITY
INCOME FUND II LLP, AND SENECA
VENTURES, LLC,
Relief Defendants.
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Case No. 1-22-CV-02465
Hon. Mary M. Rowland
Magistrate Judge Jeffrey Cummings
MEMORANDUM OF LAW IN SUPPORT OF DEFENDANTS SAM IKKURTY AND
JAFIA, LLC’S MOTION FOR SUMMARY JUDGMENT, MOTION TO DISMISS, AND
MOTION FOR JUDGMENT ON THE PLEADINGS
Defendants Sam Ikkurty (“Mr. Ikkurty”) and Jafia LLC (“Jafia”) (together, “Defendants”)
respectfully submit this memorandum of law in support of their Motion for Summary Judgment,
Motion to Dismiss Plaintiff Commodity Futures Trading Commission’s (the “CFTC’s” or the
“Commission’s”) Complaint for Injunctive Relief, Civil Monetary Penalties, and Other Equitable
Relief [Dkt. #1] (the “Complaint”), and Motion for Judgment on the Pleadings pursuant to Federal
Rules of Civil Procedure 56, 12(b)(1) and 12(c). This Motion cites to the contemporaneously filed
Defendants’ Sam Ikkurty and Jafia, LLC’s Statement of Material Facts Pursuant to Local Rule
56.1(A)(2), referred to hereinafter as “Def. Stmt.”
Case: 1:22-cv-02465 Document #: 271 Filed: 10/16/23 Page 1 of 24 PageID #:4291
IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
COMMODITY FUTURES TRADING
COMMISSION,
Plaintiff,
v.
SAM IKKURTY A/K/A SREENIV ASI
RAO, RAVISHANKAR AVADHANAM,
AND JAFIA LLC,
Defendants,
IKKURTY CAPITAL, LLC D/B/A ROSE
CITY INCOME FUND, ROSE CITY
INCOME FUND II LLP, AND SENECA
VENTURES, LLC,
Relief Defendants.
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
Case No. 1-22-CV-02465
Hon. Mary M. Rowland
Magistrate Judge Jeffrey Cummings
MEMORANDUM OF LAW IN SUPPORT OF DEFENDANTS SAM IKKURTY AND
JAFIA, LLC’S MOTION FOR SUMMARY JUDGMENT, MOTION TO DISMISS, AND
MOTION FOR JUDGMENT ON THE PLEADINGS
Defendants Sam Ikkurty (“Mr. Ikkurty”) and Jafia LLC (“Jafia”) (together, “Defendants”)
respectfully submit this memorandum of law in support of their Motion for Summary Judgment,
Motion to Dismiss Plaintiff Commodity Futures Trading Commission’s (the “CFTC’s” or the
“Commission’s”) Complaint for Injunctive Relief, Civil Monetary Penalties, and Other Equitable
Relief [Dkt. #1] (the “Complaint”), and Motion for Judgment on the Pleadings pursuant to Federal
Rules of Civil Procedure 56, 12(b)(1) and 12(c). This Motion cites to the contemporaneously filed
Defendants’ Sam Ikkurty and Jafia, LLC’s Statement of Material Facts Pursuant to Local Rule
56.1(A)(2), referred to hereinafter as “Def. Stmt.”
Case: 1:22-cv-02465 Document #: 271 Filed: 10/16/23 Page 1 of 24 PageID #:4291
Key Points
Detailed constitutional and statutory analysis
Argues Commodities Exchange Act does not cover Ethereum SPOT
Cites lack of Congressional authorization for CFTC's claimed authority