“Hawk Tuah” influencer Haliey Welch is set to be named as a defendant in an amended lawsuit that will accuse her of making more than $325,000 from the allegedly fraudulent launch of the $HAWK memecoin.
Crypto legal firm Burwick Law told Protos that it has filed a motion for leave so that it can submit an amended complaint in the Eastern District of New York.
Welch’s manager, Johnnie Forster, who also owns management firm 16 Minutes LLC, is another new addition to the amended lawsuit.
Forster allegedly set up Welch with various crypto promoters in an effort to capitalize on her sudden fame. He also signed a “Meme Token Creation and Monetization Agreement,” which required her to promote $HAWK.
Read more: Haliey Welch has ‘woken up’ weeks after Hawk Tuah crypto crash
As part of this contract, Welch was entitled to an immediate $125,000 payout and a further $200,000 upon completion of various promotional milestones tied to the token’s allegedly “fraudulent marketing campaign.”
The complaint claims that these payments “turned Welch from a passive celebrity into a critical component of a coordinated marketing funnel designed to draw in retail purchasers who trusted her.”
While Welch, along with all of her fellow named defendants, is accused of unjust enrichment, she isn’t included in any other allegations, including breach of contract, securities violations, false advertising, common law fraud, or violating New York general business law.
The suit does claim, however, that defendants Larson, Sweeper, Memetic Labs, So, overHere, Tuah Foundation, Chow, Meteora, DLL, Forster, 16 Minutes, Welch, and the Doe wallet clusters “formed an integrated enterprise capable of executing a highly orchestrated pump-and-dump scheme targeting non-sophisticated retail investors.”
Amended complaint includes fraud allegations
The reworked complaint will also include various fraud allegations relating to the creation, promotion, and further trading of $HAWK.
It accuses defendants (not including Welch) of making “material misrepresentations and omissions concerning the nature, safety, value, distribution, liquidity, and promised utilities of the $HAWK token.”
Various alleged misrepresentations included:
- claims that liquidity was permanently locked
- claims that utilities such as podcast integration, gaming, and subscription tiers were under development
- claims that the token would have fair and community-driven distribution
- claims that the project was structured with compliance and investor protection in mind
- claims that the token was not part of a fraudulent scheme
The complaint also states that, “Every technical component — pre-sale allocation, float restriction, sniper configuration, liquidity provisioning, Meteora infrastructure, and wallet-cluster coordination — functioned together to create a carefully constructed on-chain roadmap for fraud.”