On June 11, 2025, the Ninth Circuit Court of Appeals affirmed the dismissal of an intellectual property suit brought by Jaime Rogozinski, the founder of Reddit, Inc.’s r/WallStreetBets message board.
According to his complaint against Reddit, Mr. Rogozinski started the forum in 2012 to help those recovering from the 2008 financial crisis. In early 2020, Mr. Rogozinski published a book titled, WallStreetBets: How Boomers Made the World’s Biggest Casino for Millennials, and shortly thereafter the subreddit reached 1 million subscribers. The forum was thrust into the spotlight during the 2021 “meme-stock” craze. “Meme-stocks” are stocks whose trading activity is pumped up by social media. One of the best examples of this was the frenzy over GameStop, Inc., whose stock soared after retail traders, fueled by r/WallStreetBets and other platforms, bought the video game retailer’s shares in an effort to “squeeze” hedge funds that bet the stock’s value would fall. The New York Times reported that this led GameStop’s market value to rise “to over $24 billion from $2 billion in a matter of days,” and led to heavy losses among hedge funds who bet against the company. For example, Melvin Capital, a hedge fund known to be shorting GameStop and a subject of r/WallStreetBets’ ire, needed a $2.75 billion cash injection because of the short squeeze, and exited its position. The saga led to a Congressional hearing and a 2023 movie titled Dumb Money.
Mr. Rogozinski’s lawsuit claimed that shortly after he filed a trademark application for WallStreetBets in March 2020, Reddit terminated him as the forum’s moderator, accusing him of “attempting to monetize a community,” and opposed his trademark application.
The issue before the Ninth Circuit was whether Mr. Rogozinski owns the name “WallStreetBets” or if it belongs to Reddit. According to the Court, “[t]o acquire ownership of a trademark[,] it is not enough to have invented the mark first or even to have registered it first; the party claiming ownership must have been the first to actually use the mark in the sale of goods or services.” Rogozinski v. Reddit, Inc., Docket No. 24-735, Doc. No. 63.1 (9th Cir. June 11, 2025). “Here, the core of the services at issue are the provision and hosting of r/WallStreetBets[.]” The Court reasoned that because Reddit “created and provided the services that enabled Reddit’s many users to contribute to the discussion” on the subreddit, it agreed with the District Court that Mr. Rogozinksi failed to adequately plead ownership over the mark.
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About Katherine M. Lenahan
Katherine M. Lenahan is a Partner in the New York office of Faruqi & Faruqi, LLP and focuses her practice on securities litigation.
Katherine M. Lenahan
Partner at Faruqi & Faruqi, LLP
New York office
Tel: (212) 983-9330
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E-mail: klenahan@faruqilaw.com
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