Allen v. Tenev, 1:21-cv-04119

Pro se plaintiff Kent A. Allen filed an IFP civil complaint alleging that, as a child, he conceived the idea for the Robinhood stock‑trading website and several well‑known internet domain names (Google, Instagram, Postmates, Visio, “Kangeroo,” Amazon).
Defendants named are Robinhood co‑founders Vladimir Tenev and Baiju Bhatt, and recording artist Radric Davis (aka Gucci Mane), whom plaintiff alleges disclosed his Robinhood idea.
Plaintiff sought $57 million and credit/compensation for those alleged ideas.
The court reviewed the complaint under the screening provisions of 28 U.S.C. § 1915(e)(2)(B) (plaintiff was proceeding IFP) and found the factual allegations implausible and legally meritless.
The court dismissed the action as frivolous, declined to grant leave to amend as futile, and certified that any appeal would not be taken in good faith (denying IFP for appeal).
The court noted plaintiff’s history of vexatious filings and reminded him of an existing filing restriction limiting future IFP filings without leave.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether complaint states a non‑frivolous claim under § 1915(e)(2)(B)	Allen alleges appropriation of his ideas for Robinhood and multiple domain names and seeks damages and credit	No substantive defense presented; court treated allegations as baseless and without legal merit	Dismissed as frivolous: factual contentions are delusional/wholly incredible and not legally protectable
Whether leave to amend should be permitted	Allen implicitly seeks relief and could clarify allegations	N/A (no cure shown)	Amendment denied as futile; complaint frivolous on its face
Whether the court should certify IFP status for appeal	Allen is proceeding IFP and might appeal	N/A	Court certifies appeal not in good faith and denies IFP for appeal
Jurisdictional basis (diversity)	Allen invoked 28 U.S.C. § 1332 as grounds for jurisdiction	N/A	Court did not reach merits of jurisdictional contest because claim dismissed as frivolous

Denton v. Hernandez, 504 U.S. 25 (establishes standard for dismissing factually frivolous claims)
Neitzke v. Williams, 490 U.S. 319 (indisputably meritless legal theories and legally baseless claims)
Livingston v. Adirondack Beverage Co., 141 F.3d 434 (dismissal standard for IFP complaints)
Gallop v. Cheney, 642 F.3d 364 (examples of fanciful, baseless allegations)
Hill v. Curcione, 657 F.3d 116 (no leave to amend where amendment would be futile)
Salahuddin v. Cuomo, 861 F.2d 40 (sua sponte dismissal and amendment principles)
Coppedge v. United States, 369 U.S. 438 (standard for certification that an appeal is not in good faith)
Gioconda Law Grp. PLLC v. Kenzie, 941 F. Supp. 2d 424 (description of cybersquatting concept)