I’m not a lawyer and this is not legal advice. It’s pretty clear I’m just offering my opinion about the law, which in the US is open to interpretation and based on precedent. In other words, the whole point of the law is it should be debated. I am looking forward to a new and updated version of Howey from the Supreme Court as it relates to digital assets. But for now, we are using a dull knife to deal with some very specific instances. But it is all that we have in the cupboard.

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