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JB
@thecryptolawyer.eth
My written input to the SEC Crypto Task Force is now live on their website (third from the bottom) https://www.sec.gov/about/crypto-task-force/crypto-task-force-written-input In this letter, I propose a three-step test to analyze the "efforts of others" prong of Howey, consistent with caselaw.
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JB
@thecryptolawyer.eth
This is based on (1) control of a blockchain, (2) control of a protocol, and (3) ownership rights in an enterprise or object. Although there may be flaws, it would offer improved interpretive guidance for issuers considering the distribution of a token.
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