Akin And GXD Labs Announce $85 Million-plus SAFE Claim Victory In Rhodium Enterprises Bankruptcy

Precedent-setting win delivers tens of millions to creditors; Bankruptcy Court authorizes one of the largest-reported 'substantial contribution' awards.

Published on Feb. 13, 2026

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Akin and GXD Labs, a subsidiary of Atlas Grove Partners, announced a pivotal win for early investors in the now-defunct Bitcoin miner Rhodium Enterprises Inc. The bankruptcy court ruled that SAFE (Simple Agreements for Future Equity) holders have debt claims, not mere equity interests, and are entitled to recover over $85 million, more than 98% of the aggregate SAFE claims. The court also authorized an $8.5 million 'substantial contribution' payment to Akin and GXD Labs, one of the largest such awards ever reported.

Why it matters

This case sets an important legal precedent around the status of SAFE agreements, which have become a common fundraising tool for early-stage startups. The ruling ensures SAFE investors can recover a substantial portion of their investments, even in a bankruptcy scenario, rather than being treated as mere equity holders. This will provide more certainty and protection for SAFE investors going forward.

The details

Rhodium Enterprises filed for bankruptcy in August 2024 with nearly $87 million in SAFE obligations. Key Rhodium stakeholders argued the SAFEs were only worth pennies on the dollar, but Akin and GXD Labs successfully argued the SAFE holders had debt claims with priority over common stock. This resulted in SAFE holders recovering over 98% of their aggregate claims, a much higher recovery than the near-zero amount initially sought by Rhodium.

  • Rhodium Enterprises filed for bankruptcy in August 2024.
  • The bankruptcy court ruling was issued on February 13, 2026.

The players

Akin, Gump, Strauss, Hauer, & Feld LLP

A prominent international law firm that represented the SAFE holders in the Rhodium Enterprises bankruptcy case.

GXD Labs

A wholly-owned subsidiary of Atlas Grove Partners that collaborated with Akin on the Rhodium Enterprises case, specializing in digital asset and blockchain operations, investments, and advisory services.

Rhodium Enterprises Inc.

A now-defunct Bitcoin mining company that filed for bankruptcy in August 2024 with nearly $87 million in SAFE obligations.

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What they’re saying

“We are pleased that our efforts, in collaboration with Akin, have resulted not only in a significant monetary award for the creditors in this case, but also in a matter-of-first-impression ruling that will impact other current and future SAFE holders.”

— R Christian Wyatt, Co-Founder and Managing Partner, GXD Labs

“Our work with the GXD Labs team on this matter enabled us to find a way to compensate those who invested with Rhodium. In many cases, a bankruptcy asset valued at zero would remain uncollectable, but here, SAFE holders may get close to a full recovery.”

— Mitch Hurley, Partner, Akin

What’s next

The precedent set by this ruling around the legal status of SAFE agreements is expected to benefit future investors in startups that utilize this fundraising tool.

The takeaway

This case highlights the importance of clear legal frameworks for emerging financial instruments like SAFEs, which have become increasingly common in the startup funding landscape. The Rhodium Enterprises bankruptcy demonstrates how proactive legal strategies can protect investor interests, even in complex bankruptcy scenarios.