Epicenter - Learn about Crypto, Blockchain, Ethereum, Bitcoin and Distributed Technologies - Andy Bromberg: CoinList – Capital Formation for the Crypto Industry

Episode Date: January 1, 2019

When token sales and ICOs took off in 2017, most projects chose to push ahead despite large regulatory risks. One of the few that went the other direction and put compliance first was CoinList. The platform made its debut by running the massive Filecoin token sales in which $205m was raised from accredited investors. CoinList also played a major role in popularizing the SAFT and creating tools to efficiently and legally raise in the US. We were joined by CoinList President and Co-founder Andy Bromberg to discuss the history of CoinList, token sales, securities regulation and the potential of security tokens. Topics covered in this episode: How Andy became interested in Bitcoin and co-founded the Stanford Bitcoin Club The Filecoin token sale and CoinList’s genesis story CoinList’s due diligence for listing projects Why they created a whitelabel token sale offering The regulatory framework under which CoinList token sales take place The logic behind the SAFT (Simple Agreement for Future Tokens) How a token could transition from security to non-security The recent SEC crackdown on projects that did ICOs CoinList’s stance on security tokens Episode links: CoinList Website Introducing CoinList The Current State of Initial Coin Offerings Introducing Airdrops by CoinList The SEC reiterates their stance on crypto Andy Bromberg on Twitter Thank you to our sponsors for their support: Deploy enterprise-ready consortium blockchain networks that scale in just a few clicks. More at aka.ms/epicenter. This episode is hosted by Brian Fabian Crain and Friederike Ernst. Show notes and listening options: epicenter.tv/268

This is Epicenter, Episode 268 with guest Andy Bromberg. This episode of Epicenter is brought you by Microsoft Azure. Configure and deploy a consortium blockchain network in just a few clicks with pre-built configurations and enterprise grade infrastructure. Spend less time on blockchain scaffolding and more time building your application. To learn more, visit aka.m.m.S.L.E.C. Hello and welcome to Epicenter. My name is Brian Parman-Krain. And my name is Frederica Ernst.

Yeah, so we're going to go to our conversation with Andy Bromberg in a minute. He's the co-founder and president of CoinList, which has done, you know, massive amount of token sales and been kind of at the forefront of regulated token projects in the US. We'll talk about the ICOs that they facilitated and what they've done for them as well as the regulatory environment and how it's changed with the recent SEC crackdown on several ICO projects. And we'll also talk about where he sees tokens and token regulation go in the future. But before we get to this conversation, we do have a small announcement to make,

or a big announcement, well, small amounts. So Mayer had his first child just about a month ago. And so he's taking some time off from hosting podcasts. He's focused fully on the baby family as well as course one. So he's going to be back a few months from now hosting episodes, but if you miss him, that's why. And yeah, so congratulations to Meher. And with that, let's go to our conversation with Andy.

We're here today with Andy Bromberg. Andy is the co-founder and president of CoinList. Of course, many people will have heard of CoinList. CoinList is token platform or token sale platform in the U.S. that took a very kind of approach, focused on compliance, and they were behind some massive token sales, including the FileCoin one. So I've been very much on the forefront of figuring out, okay, what does it mean to do like a compliant token sale in the American framework?

So, yeah, thanks so much for joining us today, Andy. Thanks for having me. So I guess to start off, I saw that you were, so you went to Stanford as an undergrad and then you started the Bitcoin Club there. How did you originally become interested in crypto? Yeah. Yeah, so it's an interesting story. I was at Stanford setting math and computer science and took this class. taught by a professor named Bologis for Nirvasan, which is named some people might recognize.

He's now the CTO of Coinbase and was the CEO of Earn.com and before that a partner at Dracen Horwitz. But before that, he was teaching at Stanford, and he taught this amazing class called startup engineering. And a bunch of us took it through these hackathons, you built really cool things. And then after the class, a small group of us kept spending time together, including with Bology, because we were just really interested in some of the topics that we were talking about. And he ended up saying to us, Bitcoin is going to be important. You guys should be paying attention. You should buy one.

Sadly, not enough, but you should buy one. And we should get involved. And so that group of people spending time together after that class ended up becoming the Stanford Bitcoin group. And there were seven of us students that started at Invology and Vijay, who was another professor and another partner at Andreessen Horowitz. and we spent a bunch of time over the next couple of years doing research into Bitcoin. It was really, you know, around the same time Epicenter started, really around that time it was only Bitcoin.

People weren't talking about blockchain technology or tokens or anything like that. And so we spent a bunch of time doing research on Bitcoin, its applications, building cool little toys, you know, doing some evangelism, running around, pitching people on the importance of crypto. So that was a really fun experience back. in, yeah, 2012, 2013, 2014. And then you went on to found Coinlist with Graham Jenkins, right? Yes, yeah. So there's five of us founders at CoinList. And the story with CoinList getting started is that Protocol Labs, who builds FileCoin, wanted to run the FileCoin token sale. They knew it was going to be big and important

and kind of a milestone for the space. And so they started putting together this place to to sell their token. And in the process, they realized they needed some help on the compliance front. So they brought in AngelList, you know, prominent private fundraising platform here in the U.S., and brought an angelist, and they worked together to do the FileCoin token sale. And midway through that process, they stepped back and said, wow, this is really hard. It's costing us a lot of money to develop the product, to do the legal, and every single token sale is going to need to do this exact same thing. This should probably be a new independent company. And so, So CoinList ended up spinning out of AngelList as an independent company last year, a little over a year ago, to do exactly that, to be a platform for the best digital asset companies to manage their token sales.

And the kind of five founders of CoinList myself and then four folks, Graham, Paul, Brian and Josh from AngelList came over and got this thing started. But you mentioned you became interested in Bitcoin, right? early on and had this involvement in the Bitcoin Club. But then, you know, coin list was pretty recent. So how you decided at the time you didn't want to go fully in the crypto space? What was the reason for that? No, it's a good question. I left school in 2014 and started a company totally unrelated to crypto called Sidewire

in the media space, political media space. And I maintain my obsession with crypto throughout that time. But the reason I didn't go into crypto full time, was that I felt like it was a coin flip at that point. This is 2014. I felt like it was a coin flip, whether or not there was going to be one cryptocurrency, crypto asset, cybercoin, whatever we want to call it, whether there was going to be only one, you know, Bitcoin was going to be it,

or if there were going to be a ton of tokens, coins, digital assets. And at that point, I just couldn't tell. I thought it was 50-50. And I was looking at it and saying, startups are already hard enough. They have a massive failure. I don't want to add an additional 50% attrition rate onto that because anything I could think of doing relied on one of those two outcomes, relied on one of those two theses being true. And I just felt like I couldn't tell and I didn't want to add a 50% failure rate onto what is already a very hard thing to do.

And so I said, you know what, I'm going to come back to the space when I feel like that question has been answered. I now feel like that question has been answered. there's going to be more than one cryptocurrency out there. And obviously, coin list is predicated on that assumption. And so that's what kind of emboldened me to come back into the space and work on it full-time now that I feel like that decision has been made. So you were the CEO until earlier this year and then stepped down and became the president. What's the story behind that?

Yeah, it's a great story. So an interesting thing about crypto that differentiates it from a lot of other industries is that because it's so early, you guys know this well, it's global and the value of being out there publicly is really high because there's just a lot of uncertainty, there's a lot of confusion out there. And so having a message that's out there is way more important than in most startups where you should go in and just focus on kind of building a compelling initial product and shipping that. It's important that we spend time kind of out in the world and evangelizing where this space is going. And so earlier,

this year, I was spending all my time doing that. I was working on sales, working with issuers, trying to guide people in the right direction. I was traveling, I was doing all of this. And we're such an early stage company, you know, 10 or 15 people at that point, that I just wasn't spending the time I needed to be spending back home at the company. And so we said, you know, myself at the board, we said, we should really bring someone into run this company. So I can do what I do best, which is getting out there and kind of interfacing with all these external parties that are critical in the crypto-eco-eco. system and we found the perfect person. So Paul Davison, now the CEO of CoinList, came over.

He was running a big chunk of product of Pinterest. He had sold his last company to Pinterest. He had worked at Google on MetaWeb, done a whole bunch of amazing things. And it was just the perfect person to come in and really lead CoinList the company, which freed me up to go and focus on all the external facing things that I think are really important in this industry. Among these external things, what are the ones that you spent most? time focusing on. Yeah, it's a pretty wide variety, but I think the highest leverage piece is sitting down with really high quality token issuers that maybe don't have it all figured out. So it's interesting when you start a startup. There are now years, decades of kind of case

studies built up on how to start a startup, what you should be doing, what the best practices are, how you should structure things, what does a seed fundraise look like? What does a series A fundraise look like. In the crypto space, we're so early, and especially within tokens in particular, we're so early that there's just not a lot of data points. And so these amazing teams are coming in and saying, well, we know how to do our thing, which is, you know, building this product, building this platform, you know, supporting this token network. But we don't really know how to structure our sale. We don't know how to, you know, market it. We don't know how to build a community. We don't know how to do all these extra pieces.

And it's something that we're in a unique position. We've seen now thousands of these token sales and can figure out how to help them. So I think the highest leverage thing I do is sitting down with high quality teams, this isn't something that we charge for. It's not a service of ours. But if we think it's a really high potential project and we might want to work with them in the future, I'll spend hours sitting down with them going through. How should you structure your sale?

How should you think about strategy going forward? How should you think about the different dynamics in this network, building a community, and helping them make sure that they have the best chance of being successful. And that then is what leads to really successful token sales, really successful air drops, really successful community building efforts. And so that time that we spend with those issuers trying to get them on the right path, I think is probably the most valuable thing that we do. So once you've onboarded these projects, what kind of services do you offer to them?

Yeah, so Coinlist today offers four services, and I'll sprint, through them. The first is the service that we're kind of most known for, which is the full sale product. And this is what we did for Filecoin, Blockstack, Props, Origin, Trust Token, but only those five. And I say that just to note that it's a really high bar. We've worked with five in the last year or so out of about 2,500 that have approached us. And so super selective on that. When we do that, we host the sale on our platform. So we handle the compliance, KYC, AML, accreditation, if that's relevant, the transaction process, the document signing, the token distribution, really the whole nine yards of logistically running the sale. And then we market the sale to our community of investors.

And we've got many, many accredited investors in the platform ranging from, you know, your average accredited investor all the way up to institutions, funds, endowments, you know, family offices. And so we work on both logistics of the sale and also potentially helping to bring capital in. So that's one service. The second one is CoinList's token sale manager. which is effectively the same, but just without the marketing and endorsement. So it's just the infrastructure to run the token sale. Again, compliance, transaction processing, document, sign, token distribution, but without us kind of endorsing the project or pushing it to our investor base.

And so that's the Coenless Token Sale Manager product. Our third product is the Coimless Air Drops product, where we help issuers give away tokens. We built a structure that's compliant in the U.S. and internationally to give away tokens, even if they might be securities. And we have a big community to send those to the first one we ran was the DFINITY Airdrop, which is really exciting. They gave away $35 million worth of tokens to tens of thousands of users. And we have some more exciting ones coming up soon on that.

And that Airdroft product will also include things like developer bounties and kind of proof of care systems. We can talk more about the future of that. But we're really focused on effective targeting there. And the last product, they actually just announced yesterday, is coinless build. which is our product to help token networks host online hackathons to build their developer communities. We think online hackathons are an amazing concept, really fit in with the crypto ethos of being global and distributed

and open, democratic, where people can go and build on top of these platforms. Our first hackathon we're hosting for X, which is really exciting, awesome team. That'll happen in January. And every participant that submits a project gets $100 in X tokens. There are awesome grand prizes that X has donated, $10,000 in X tokens for the winner. And it's focused around bringing decentralized markets to the masses. And how can you build compliance on these decentralized markets?

How can you do interesting things with NFTs and gaming on these decentralized markets? How can you build an ecosystem of decentralized finance? And so we're really excited about that hackathon. And then we have a bunch of other ones in the pipeline to keep the support going and keep building these developer communities. So those are the kind of four coinless products, full sale, token sale manager, airdrops, and coinless build, and of course, more in the pipeline as well. I'm curious regarding the full sale versus the token sale manager. Why didn't you guys just choose to have, you know, an open platform where you have like a wide variety of projects that can do token sales through that? Yeah.

I think a big piece of it for us is that the space is so filled with. noise, right? It's really hard to separate the signal from the noise. And because it's so young, most investors don't have an ability to really effectively do diligence on these projects. And it's getting better every day. But especially if you look last year, investors just didn't know how to determine if a project was good or not. And we said, well, we think we have that competency in house. Let's make this a little bit easier for them. We're not going to say that every one of our coinless full sales is going to be massively successful, but we've at least done our diligence and gotten comfortable with the idea of the token accruing value in the long term,

it being useful, the team being good, the product being good, the market being big. And I just think that's a really useful service in this space. We, of course, want anyone to be able to run a token sale, and that's what our token sale manage our product is for, but being able to separate out the signal from the noise a little bit so that investors can come and say, okay, I have confidence that at least a minimum bar of diligence has been done here. Now I can do my own diligence, make my own decisions,

but I can feel comfortable with the projects listed on this platform. I think it's a really valuable service to be providing to the space. And just, you know, having that aura of high-quality projects, especially in a time when there are so many low-quality ones, I think it's really important for us and building the company of the future. Interesting. So when you say you do your due diligence on these projects, do you mean in a legal sense,

in the sense that you determine that they're not scummy and they're not a security? so on, or do you mean that you also look at their token model and see whether you think that's going to work in the future? Yeah. And whether it makes sense from a crypto-economic point of view. Yeah, all of the above. So it's generally kind of six things that we look at when we dig into one of these projects.

The first four are things that I would say you should do for any startup you're investing, whether it's a token or not. Look at the team, the product, the market, and the deal terms, right? So is it a strong team? Do they have a compelling product? Is it a big market they're going after? And do the deal terms make sense? Are the terms terms that you should think about investing at?

So we do that. And then once we get past that, there's two things that are kind of unique to token diligence instead of startup diligence. One is what you were saying, the legal diligence. If you're investing in a normal startup at their seed round, no one's really innovating on the legal structure there, the financing or the company. And so you don't really need to do that much legal diligence.

But in the token world, obviously people are innovating left and right on legal structures. And so we have to get comfortable with how they're operating from a legal perspective. And the last piece is the token economic piece. And that means us getting confident that the token needs to exist, that the token will accrue value in the long term, that all the parties in the network are properly incentivized or disincentivized to behave in the way that's desired by the network. And I'm really nailing down the token economic model, I think, is that's a place where a lot

of teams we talk to fall short. There's obviously a massive class of scammy, low-quality projects that we see and we can, you know, kind of throw away out of hand. But the hardest conversations are ones where we sit down across from a really good team with a compelling product and a big market they're going after. And we look at them and say, listen, we just, we don't think, and we could be wrong, but we don't think your token needs to exist. Or we don't think it's going to accrue value in a long run.

Or we think that there's some flaw in the token economic model that will cause. you know, an incentive for the network to be attacked or, you know, a disincentive for a key party to act in the right way. And a lot of projects, because this kind of field of token economics is so new, don't, you know, don't really have the ability to put that together. And that's where they fall short. So you mentioned the five token sales that you guys did, which tended to be, you know, large and well-known projects. But I think those were all last year, you know, have you guys done token sales this year? Yeah, origin and trust token were this year, but they, you know, and few and far between. So one thing that our token sale manager product is used for, the

white label one, is private sales. And some of those are really high quality projects that would absolutely pass our diligence for the first category, but they don't need the marketing because they're choosing to run a private sale and do they just want the infrastructure. So what we saw was a lot of the high quality projects in 2018 decided to run private sales instead of public sales. And so we still help them, of course, but just not in that public manner because that wasn't the service that they were looking for. There was a recent post announcing that Coinlist is now 100% free for investors and all the money raised goes to the project itself. So how does Coinlist make money? Yeah, so we moved pretty simply from charging investors to charging projects.

And I think what we're seeing was that, you know, investors don't want to pay. they're already paying for their investment. And projects don't really want their investors to pay. They'd much rather pay themselves out of their own kind of treasury management and financial budgeting than making their investors pay. And so we just changed, kind of flipped our model around. And we think it's going to result in dramatically happier investors and issuers. So pretty simple change, to be totally honest.

But I think the optics of that matter a lot to investors and we want to make sure we're serving everyone in the best way possible. And can you speak about, you know, what are the fees that you charge, you know, that charge both through the token sale platform and then the manager? Yeah. So it really varies depending on the deal. I think for the full sale product, it tends to be a percentage of the funds raised because we're actively participating in, you know, kind of pushing the deal out there and getting capital

into the deal. So we take some percentage of the funds raised on the token sale manager product. That's priced with kind of a flat fee, very low tens of thousands. of dollars and then above a certain number of investors a per investor fee of processing costs. Again, it varies on the exact details of the sale, but that one's more of kind of like a SaaS model. Well, the full sale business has a percentage-based model. If you've listened to previous episodes with Marley Gray and Matt Kerner, you know that Microsoft is committed to providing enterprise grade tools and infrastructure for blockchain developers.

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So you can't really talk about token sales without talking about regulation. So what's the regulatory framework which Coinlist has used so far? Yeah. So our view is that, and we're generally focused on people that touch the U.S. in some way. So whether it's a U.S. issuer or it's an international issuer, but they're hitting U.S. investors, that's the place where it makes kind of the most sense to start. We can talk about international pieces as well. From the U.S. perspective, SEC Chairman Jay Clayton has said a number of times he hasn't yet seen an ICO that wasn't an offering of securities.

So we take that same stance. We think it's possible. And there's actually some coming up next year that we're excited about potentially being non-security's offerings. But thus far, we think that functionally every ICO has been, or token offering, has been an offering of securities. Now, very important there is that that does not imply that the tokens will always be securities. It just means that at the time of the initial offering, when the issuer is selling them to a first set of investors, the SEC thinks that those have been securities. So most often, projects that work with CoinList use something like the SAFT framework. And now there's a bunch of different names for different documents, but they all are kind of get back to the same core idea, which is we're going to sell you a piece of paper.

It's called the SAFT, simple agreement for future tokens, and this piece of paper is a security. So you're participating in a regulated securities offering and it has to be registered or exempted appropriately and we can talk about the different options there. At some point, we think that the underlying token will no longer be a security. And at that point, this piece of paper will turn into or output those non-security tokens

and then you'll have this wonderful non-security token in your hands as a result. And so that kind of is the overall framework that most issuances that have worked with coin lists have used. and it's something we still believe in at a high level, that concept of we're going to sell you a piece of paper, a security, and eventually it's going to turn into something else. I think the big open question is, where's that line? How do you draw that line? How do you decide when something is no longer a security? We have lots of thoughts on that. But that's kind of the big outstanding question I think people have for the SEC. It's become clear that it is possible to have that line, and now it's just a matter of drawing. it and where exactly it falls. And one note on that, I think the clearest encapsulation of why that transition is possible

comes when you put two senior SEC official statements together. SEC Chairman Jay Clayton saying, I haven't yet seen an ICO that wasn't offering of securities. And then SEC Director of Corporation Finance, Bill Hinman, saying he doesn't think Ethereum is a security. And so you put those two together. Jay Clayton has almost certainly seen the Ethereum ICO. it would be kind of absurd for him to have missed that one.

And so if those two officials' statements represent the final position of the SEC, which of course is in question, but we think is likely, then you hear effectively the Ethereum ICO was an offering of securities, and then you hear Ethereum is not a security, and that means that that line is possible to cross at some point, and it's just a matter of when and how, and those are questions that we are actively trying to get good answers to. So what are your thoughts so far?

What do you think are, I guess, on the one hand, likely stance that you'll see the SEC take on this question? And what do you think would be a good way to actually answer that? Yeah. The two clearest paths I have seen so far for criteria that would mean something is not a security. One is a pretty simple one, which is that you hear a lot about the Howie test, which is this, test of whether or not something in the U.S. an investment contract, which would mean it's a security. And

it satisfies these four prongs of the Howie test. So there's an investment of capital in a common enterprise, made by the efforts of others, and with an expectation of profits. And that last prong is an interesting

one because we have this wave of stable coins. I feel like the last six months have been the half year of stable coins. Everyone's talking about them. But an interesting kind of foot-in-the-door strategy here is that stable coins, by definition, if you sell the stable coin itself, not some associated token that changes in value based on the success of the stable coin, but the stable coin itself, by definition doesn't have an expectation of profits. If we have a stable coin that tracks the U.S. dollar and someone invests with U.S. dollars, I can pretty definitionally say that they are not expecting profits from buying that stable coin. And so that would be a really interesting thing to go and say, we're selling the stable coin. We think it is a good one because it fails the Howie test.

It's not an investment contract because there's no expectation of profits. And so then all of a sudden we would have a token out in the world where it's not a security. And that I think is a really effective foot in the door strategy. It doesn't help most tokens that do kind of have floating prices and vary, but it would be a way to get a token out there that's not a security. So that's one. I think the more interesting one, and that's still a little bit up in the air, is what Bill Hinman, again, the director of corporation finance who talked about Ethereum not being a security, said, which is that it's sufficiently decentralized. You'll hear this phrase tossed around a lot, sufficiently decentralized. What does that mean?

Great question. We have no idea. But that concept, he is kind of implied, would mean that something is no longer security because it's kind of not dependent on the efforts. of others. It's not dependent on the efforts of this kind of issuing party. And so I think a lot of attention is going to be focused around what does it mean to be sufficiently decentralized? How do we kind of set some sort of quantitative or semi-quantitative criteria for that? And then how can token networks fight to get there? And I think that's the really interesting next frontier in terms of securities regulation of the U.S. on these assets.

That's very interesting that you say it can depend on the efforts of others as long as the others are not centralized. I think that's a super interesting point. People have also been giving out a lot of what's been called utility tokens, right? So that in principle are designed not to be securities in a way, but you think they're being perceived as security. So how, what kind of uses these utility tokens actually have to have in order to not be a security? Yeah. So it's an interesting point. Again, I'm speaking largely from kind of a U.S. perspective here. So, you know, obviously laws are different in every country, every state, province, everywhere has a different set of criteria. I don't like the term utility token. And the reason

I don't like it is because it carries with this implication that if your token can be used for something, it's not a security. That is not our belief. There are many securities that can be used for things and just calling something utility token and saying you can use it, to us does not mean that the asset is not a security. And so we don't like that term. I prefer the kind of convoluted and painful to say, but, you know, slightly more clear term, non-securities token, right? So you've got securities tokens and things that are non-securities, and it's a matter of figuring out a way to get them there. And so I believe in the concept of non-securities tokens, utility tokens, you know, it turns out that according to Bill Hinman, the Ethereum is one of those. But the question is,

of how do you get there and what is that criteria? And so I don't think that, I think people have kind of had a reductive approach to that and said if you can use it for something, it's fine. And I don't think that is true, at least in the U.S. But I also think more broadly, the utility token securities token or securities token, non-securities token divide is actually not a terribly helpful divide because it's purely a regulatory classification. It's a little bit to me like saying, you know,

dividing all websites in the world into regulated and non-regulated websites, that's not a helpful division of websites. You know, regulated websites could sell tokens or guns or alcohol or any, you know, thing. And those are all wildly different businesses that don't have a lot in common with each other other than the fact they happen to be regulated. And in the same way, securities tokens can represent a whole bunch of different things and have wildly different characteristics and not have a lot of similarities. And non-securities tokens can look totally different from each other

in the same way that Facebook and Google and Amazon are very different businesses. These non-securities tokens are going to be very different too. So I think it's kind of the next conceptual step for the industry is going to be giving more critical thought to what are the actual categories of tokens? In the same way we divide websites into social media networks and search engines and e-commerce sites and have this kind of taxonomy of types of websites. I think we need that same thing for tokens.

And I think so far we've taken this kind of simplistic approach of saying utilities, token, security's token, and I don't think that gives us enough detail to really, you know, classify these assets. I wanted to ask another question on your point regarding, you know, tokens being, you know, the thing around being sufficiently decentralized, you know, let's say, you have something like a maker where it, I mean, I think originally it was called shares, right? And in a way, you have this token, which is this kind of governance token, and you have a revenue from the success of the system. So if I'm just going out and I'm buying this token,

I mean, in some way I am, you know, doing it probably with the expectation of profit and probably from the effort of others. Yet at some level, it's decentralized, right? There's no like central foundation necessarily that has a decision-making power. So do you think in general this is going to be an approach that, you know, that works and that you have like corporation-like things? And I guess you could even think of Ethereum in some way as like, you know, there's some similarity or even Bitcoin, right? You could say, hey, there is this decentralized organization corporation-like thing,

but you don't have the central party. So you think like removing the central party is going to be the key thing. factor? Yeah, it's an interesting question. So first of all, I think just to inject the necessary legalese here, first of all, I'm not a lawyer. And second of all, you know, determining whether or not something's a security is in the U.S. what's called the facts and circumstances based analysis, which means it's, you have to look at the facts of the situation and the circumstances under which you're evaluating it. And so it's a really nuanced thing. And reasonable people will disagree on whether or not something's a security over and over again.

There are not really lots of bright lines about whether or not something fits into that category. So it's tough to say. I do think that going to the sufficiently decentralized point, even just thinking about that phrase colloquially, I think that it implies two things. One, it implies a lack of a central party, right? So if something's sufficiently decentralized, almost definitionly that means there is no central party that can control the system. So to that part of your question, yes, I think removing the central party is part of the strategy that people will use. But I also think that even beyond that, it implies a certain degree of decentralization.

And again, defining that phrase is really hard. And I don't think we have clarity on what that means yet. But if you remove the central party, but it's now a duopoly. And let's imagine a system that's governed, proof of stake governed. and there are two parties that each have 45% of the network, right? And then a variety of people have the remaining 10%. And those two parties are effectively governing. Is that sufficiently decentralized?

It is kind of decentralized and that there's no central, single centaur party. But now all of a sudden there's two kind of poles in that system. And, you know, where's the last, you know. So that then becomes a question of, again, facts and circumstances and where you fall on that spectrum. So I guess I would say removing the central party seems necessary, but not sufficient to reach that level of sufficient decentralization. It's hard for me to imagine a system with a central party that is sufficiently decentralized, but it's easy for me to imagine a system without a central party that still doesn't feel like

it would be sufficiently decentralized. Does that make sense? Yeah, absolutely. Of course, the tricky thing comes in, you know, a while ago we did this podcast with Angela Walsh. I'm if you familiar with her, but she's been, you know, writing she, I guess she has this, like, you know, extremist position in some way in that she's been arguing that, you know, the responsibility is somewhere and you should think of even like Bitcoin core developers as this sort of centralizing element that has this responsibility. Again, it's one of these things where it's so hard because, because, because, Because of the nature of these determinations, there's no objective truth here.

You know, part of what is appealing to me about a Bitcoin-esque system is, sure, most people rely on kind of this core developer set, but not necessarily, right? The miners have to adopt these changes. And so there is a system of checks and balances there where it's not like that code is just pushed out to everyone and they don't have control over it. So that's, I think, the obvious counterpoint of the position that she's heard that a million times. It's well incorporated into her arguments. But my position is I feel comfortable with that one because it feels kind of sufficiently without a central party that, you know, each, they're all checked and balanced across the board. And there's no kind of entity that's, you know, driving it forward solo. And so that, I think, is kind of the interesting nuance there.

but again, facts and circumstances, really hard to come to a hard determination on that. Do you think it makes sense to actually have this provision about the issuer not being a centralized party? So basically, if you turn it around, that basically says if you're a DAO, you can't issue a security, right?

So anything that a DAO issues can't be a security by definition. Is that correct? And do you think that makes sense? No, I think that goes back to the no central party being necessary but not sufficient. sufficient decentralization, they could issue something that is still a security if it is not

sufficiently decentralized. But just a lack of a central party does not imply that it is, does not directly imply that it is not able to issue a security. So I think a Dow is way further along the road to having a non-security token than a central party is that's issuing a token, but I don't think it's definitionally not a security if a Dow issues it. And in fact, in fact, you know, of course, the famous the Dow opinion, the SEC said that those tokens were securities. And so that's obviously a fact that we have to consider in that evaluation. We mentioned now, you know, tokens being securities and then also this security tokens. So let's speak a bit about security tokens.

First of all, what are security tokens and what's interesting about that? No, I think it's the right question. And it goes back to what we're saying earlier, that. I think it's a pretty silly term that people have gotten very attached to because it's a regulatory classification. There's a million things that are securities that are totally dissimilar to each other. And you never really talk about them in the same breath, right? Like in the real world, you know, people don't talk about investing in, you know, some sort

of debt security, like some municipal debt security and startup equity as the same thing. Those are both securities and totally different. Very few entities would invest in both of those two things. And the same way talking about investing in securities tokens, feels a little silly because the security tokens can represent very different things. So I think, again, important to start to break down kind of what are these assets and what are kind of the better subcategories. So if you don't mind maybe a brief, I wish I had like a diagram here,

but a very beginning taxonomy of tokens that I've started to use that I think breaks it down a little bit more and tells us a little story about the space. I think there will be way more categories in this, but I have kind of a two-by-two matrix in mind that yields four token categories that are a little bit more defined than securities token and utility token.

And if you think about these two axes, and I've been meaning to write this up, so maybe this is the impetus I need to go and do that, where one axis is the intended regulatory status of the token, which is either security or non-security. So that roughly corresponds to utility token and security token, right? Tokens can fall into one of those two categories. And then on the other axis, you have the source of value for that token,

which is either real-world value or token network value. So you put those two axes together and you get four tokens in those boxes. security that gets its value from real world, security that gets its value from a token network, non-security that gets its value from a token network. So let's talk about each of those four, and I think it tells a story about how this space could develop. We started in the space with non-securities tokens that got their value from the real world. So I would call those store of value tokens, right? Bitcoin, which I consider to be a store of value token, is valued based on real world inflows and trust in the system.

it's not value based on the level of activity on the Bitcoin network. It's not value based on any actual thing happening on Bitcoin. It's value based on the value that people imbue it with. And that's where this whole space started was in that store of value token category. So non-security getting its value from the real world. Where I think we went next, and this is kind of the story of the last couple of years, is still non-security but getting its value from token network activity. And that's what a lot of us call network tokens or protocol token.

And FileCoin would be an example of this when it launches where it is intended to be a non-security when it's kind of in its ultimate state. But it gets its value from the work being done on the network, not from just being a real-world store of value. And so that's kind of the second category that we have gone to is from still in the non-securities category but going up to the token network providing the value rather than the real world. I think what's next is the adjacency to that, which is getting its value from a token network, just like those protocol network tokens, but instead being a security. So I call these profit tokens. And these are tokens that represent some sort of on-chain cash flow. I think the most common example that we have seen of this so far is the tokens associated with stable coins.

So whether it's something like trust token or the kind of recently. wound down kind of basis shares token, things like that where the token is intended to be a security and it gets its value from what's happening on chain, right? It gets its value from the token network's activity and the value being put into those stable coins. So that is an interesting transition that I think we're going to go to next. And when we transition between these categories, it's not like the old ones die. I think it's just adding on it a new set. So we're going to go from just having these protocol tokens, which are intended to be non-securities, to having these profit tokens where they get their value from a token network, but they're intended to be

securities, they're intended to be investments. And so that's going to be the next category in my eyes. And that will encourage a lot of the infrastructure around securities tokens, because that is a securities token. It is a token that is always intended to be a security. That infrastructure will get built out. And only once that's been developed, will we go to the last category, which is a securities token that gets its value from the real world, which is kind of the asset-backed token category. So that's when people talk about equity-backed tokens or real estate-backed tokens or these kind of tokens that have an asset behind them, I don't think those are going to emerge in force until we've had a bunch of infrastructure built out to support the

profit token category. And so that's kind of a four-part taxonomy, store value token, protocol token, profit token, asset-back token that breaks down a little bit more than the utility token, securities token. Those last two categories are both securities tokens, but clearly very different. Trust tokens token versus a token backed by a building really could not look more different. They just happen to share this securities token regulatory classification. And so I think that there will need to be infrastructure built out to support that. But that's the sort of thing that I think, you know, whether or not that taxonomy is right, I think we need to start thinking a little bit deeper about what are these actual types of tokens rather than just dividing it as utility token

and securities token. So let's say you have one of these profit tokens. So let's say you have one of these profit where the token derives its value from some on-chain DAP or protocol or something like that. Then, and, you know, you mentioned base coin and the shares, the basis shares, as an example. And they now shut down their project, right? Because they basically said, okay, this looks like a security, but the whole protocol is sort of, you know, not feasible if it is a security. So like, now let's say you have these things that are securities. what does that they mean? I mean, does it mean you'll have to restrict transferred between

just like white listed addresses that are like only accredited investors? Or what are the implications of that? Yeah, I think it really varies based on how they decide to treat it. But there, you know, securities trade very liquidly in markets all across the world. Equities, obviously, the equities markets are massive and liquid. And so it's just a matter of figuring out the right kind of structure and the work that you have to put in to make it happen. I don't think that it I think it makes it harder to have the liquid markets and if something's a non-security, but not impossible. And so I think whether it means people registering publicly,

like effectively having an IPO for a token, or trading among accredited investors, or trading in certain international markets, I think there's a lot of ways to handle it. But, yeah, I think at the end of the day, those profit tokens, by definition, and kind of the taxonomy I outlined, are securities and need to be treated as such

and traded in a regulatory way. So where does that leave retail investors? Yeah, so first of all, I think at some point we'll be in a world where retail investors access those tokens. Retail investors certainly access public equities in every stock market around the world. And so that's, I think, a natural ending point. A lot of issuers are exploring reg 8 plus in the U.S., which is a way to sell to undercredit investors. Lots of issuers use reg CF, equity crowdfunding. So I don't think this means, you know, those investors will be left in the lurch.

I just think it means there's a bunch of infrastructure that needs to be built out to support them and best practices that need to be developed. And I think that's all happening. So you mentioned the exemption here. Now, what are the different types of exemptions? And I guess coinless so far is mostly used to one where basically if you sell to a credited investor, you can sell a security and you're basically fine. Yeah.

But can you talk about the different types of exemptions? Yeah, so there's a lot of them. I'll run through, I guess, the four that are most commonly used in the U.S. to sell securities or to sell tokens. There are more. So this is not an exhaustive list, but the four that are most commonly used are reg D, which is what you mentioned, which is involving selling to accredited investors. There's a couple kind of sub-specific versions of this, 506B, 506C.

But effectively, it means you're selling to accredited investors. you can sell the security under 506C. You can also solicit it publicly. Under 506B, you can't. But it means you're only selling to accredited investors. So that's one. The second one that's used often is reg S. So reg S is a way for a U.S. issuer to sell a security to non-U.S. investors.

I think there's a common misconception in the crypto space that it means, reg S means, don't worry about securities laws, which is not what it means. What it means is, what it says is, don't worry. worry about the U.S. securities laws because you're not selling to U.S. investors, but do worry about the securities laws of the jurisdictions you're selling to. So if you're selling to a German investor or a Singaporean investor or South African investor, follow that country's securities laws. And so that's kind of the second exemption that people use. Coinless is built out, support for dozens of these countries' local securities laws. So you can run over, I guess, offering and

follow those countries' laws instead of the U.S.'s laws, which are often more stringent. The third is reg CF, which is crowdfunding regulation. And this is a way to sell securities to unaccredited investors. There's a bunch of work you have to do to do it, filing a form with the SEC, doing a whole bunch of things. And there's a cap of $1.07 million that you can fund raise. But a bunch of issuers have done this very successfully. And then the last, which has not yet been really effectively done, but I think will happen next year, is a reg A-plus offering, which is kind of called a mini IPO.

And this is a way to sell to accredited or non-accredited investors up to a certain amount, but the maximum was way higher of $50 or $75 million, depending on the type of offering you're doing, with a bunch of requirements around ongoing reporting and forms you need to file, but can effectively serve as kind of a mini IPO. So those are the four most common that we hear talk about,

reg D, reg S, reg CF, and reg A-plus. So if you look at ICOs, that have taken part in the last couple of years. Most of them went in compliance with these regulations, and given that many of them would be seen as a securities offering, they are in breach of many laws. And the SEC, until earlier this year, it seemed the SEC was going mostly after projects that were scummy

and were obviously scummy. This changed in November when the SEC made it public that they were going after, Airfox in Paragon for issuing unregistered securities. What's your take on this recent development? Yeah, I think it's kind of a, it's a natural evolution of the space. Nothing in terms of what the SEC was saying they had a right to, they had a right to do changed when they did that. It was all consistent with what they've been saying for the last year. But what did change for the first time, which you pointed out accurately, is that they pursued what seems to be a non-fraud case

for the first time, right? They pursued kind of someone that they didn't accuse a fraud. They just accused of selling unregistered security. So that was the change that happened. But they've maintained that they've been allowed to do that for the past year or so. They just hadn't really exercised that authority yet. And so I think that, you know, what they're now saying is, okay, we now understand this space a little bit better.

I think they, part of it is you have to consider their position, which is the SEC's job is to protect investors. and they want capital formation to happen. They want fundraising to happen in the U.S. So they're not trying to kill the industry by any stretch of the imagination, but they do want to make sure that things happen legally and that investors are protected. And so what they did initially was,

while they were getting to understand the space, they just knocked out a bunch of really bad, obvious fraudsters and people that were putting investor money at risk. And then once they understood the space better, they were able to evaluate and say, okay, now we want to go after a few people that aren't fraudsters but are not following the laws and start to go after them. And I think that's just a kind of natural progression and that'll force more and more issuers to operate compliantly. Now they realize that it's not just the fraudsters that the SEC is going after.

And I think that was a big part of their objective there was to kind of put a flag in the ground and say, we're now enforcing against non-fraudsters. You've got to make sure you're doing stuff under relevant securities laws and regulations. Yeah, I mean, on this topic, so we did do an episode a while ago with somebody who used to be at the SEC and do cases like that. And the point he made also that's what the SEC does is they tend to go after cases that are, you know, very clear, right, that they're going to win. And where they also have other things like fraud that they can accuse people off. So then when they're in so much trouble, they don't really mind. fight, you know, they won't really fight the, yeah, the accusation of, of having done an unlicensed

securities offering and they can build like precedent with that and then they can go to, to bigger projects that, you know, maybe haven't done such, all these things illegally and then have these cases to rely on. Yeah, yeah, exactly. I think that's, that's the, a typical pattern for them is kind of starting at the bottom end and then going right to the middle of the, the spectrum of legality and planting a flag there and starting to knock people down. So once you're caught up in that as a project, can you take us through what happens? What do you actually have to do? Do you have to give back investments or what's the process?

Yeah, it's a good question. I think a little bit unclear right now, but you can read the Air Fox and Paragon enforcement actions and settlements and see what they have to do. So one of the things they have to do is, yeah, offer rescission to investors. They can get their money back out. They have to file disclosures on a regular basis about their token, treat their token like a security. And so it's just kind of like a bunch of cleanup steps that you have to do if that happens. And I expect a lot of teams to start doing that proactively to avoid this.

I think a scary thing for a lot of these projects is that you really have two risks. You've got the risk that the SEC comes after you and does something like this and files an enforcement. and you have to settle and follow a bunch of things that they set out for you. But you also are at risk of a class action lawsuit by the investors, right? And actually, once the SEC does one of these enforcement actions, it sets up really nicely for investors to sue you, who are following on to what the SEC said. And so I do think that there's kind of a dual risk here for these issuers that did things poorly,

and they have to think about addressing both of those concerns, addressing the regulator's concerns, but also making sure that they won't get in trouble with investor lawsuits. And cleaning both sides of that up, I think, is critical if you want to make sure you're going to have a smooth ride from there on out. So do you think these actions will kill many projects, or do you think this is something that, you know, okay, there's some cost, there's some hassle, but it's possible to actually, you know, come clean and comply with that? It's a good question. I think a lot of projects that could be subject to these types of actions, their systems are actually predicated on it being a non-security. And if they have to treat it like a security, the system might just not work.

And so it could kill a lot of projects. But there are projects that were doomed to fail from the beginning. If they were issuing something that was a security and treating it like a non-security, they were going to get caught at some point. someone was going to file a lawsuit, the SEC was going to come after them. And so I think a lot of projects will struggle and fail in the next couple of years. But I also, you know, again, I think there's so many bad projects in the space and bad actors and people that, you know, didn't think these things through. I think that's natural.

It's a kind of natural selection process that the projects that we're doing things the right way are going to succeed. And, you know, some of these projects, their premises were just impossible from the beginning. and fate is catching up to them at this point. One of the consequences from this SEC crackdown is that a lot of people who've been in the space a long time are proclaiming at least that the ICO is dead. Would you concur with that?

I wouldn't. I would not concur with that. I think the kind of heyday of everyone selling a utility token, you know, send me some eath, they'll send you some tokens, my token does this, that, and the other thing is over. I think the people have to act compliantly. And there may be cases where you can sell a non-security

where the token is able to be sold as a non-security and that's awesome. I think a lot of them are going to be securities offerings. But at the end of the day, I think maybe this kind of like casual understanding of what an ICO is, which was that like heyday, you know,

just unregulated, sending money back and forth is over. But the idea of a coin offering or a token sale that's not over. That's sticking around for forever. And it's just that the rules are being enforced a little bit more strongly now. The issuers have to follow that. So I do not think the ICO is dead, but I do think what a lot of people understood to be an ICO is perhaps dead. And we've got to shift our perspective a little bit. On the one hand, right, certainly these unregulated ICOs have disappeared to a large

extent or diminished greatly. And I think the regulatory thing has a lot to do with it. But even it seems more compliant offerings are, you know, I mean, the market overall seems to have deflated completely. What do you think it will take for that to come back? I think in the early days of any market, it's cyclical. I'm kind of a broken record on this. But I mean, even just look at Bitcoin, If you've been in the space for a while, this is now our fourth or fifth, like 80% retracement of Bitcoin's price. And that's, it's going to happen. You know, I think there was this ICO boom and then the bottom kind of dropped out. What we saw is that all these bad projects stopped fundraising.

But the good ones are still going. They're still raising money and running token sales, public or private. And we expect that to continue. So, you know, I think a lot of the numbers that we saw in the past year or so associated with the ICO market were inflated. by the number of low-quality projects that we're able to just drag capital in. But the good project is still going, and I expect that to continue.

So, you know, I think I'm expecting 2019 to be a pretty calm year. I think we have this every couple of years in crypto where, you know, there's not a massive boom, there's not a massive bust, but people put their heads down and build. And that's what I'm expecting, hoping 2019 will be.

And then I think at some point, we'll see kind of the next run-up when something happens, when there's a catalyst. And I'm not expecting that in the next few months, but I certainly think it'll happen at some point. And it might be the rise of these profit tokens. It might be something totally unrelated

that we haven't talked about yet. But there will be something that will drive kind of another hype cycle, as we've seen over and over again in the crypto space at large. I would love to ask you to speculate about that a little bit more. So basically, until now, you've drawn the distinction between good ICOs

and bad ICOs. And that's, that's not super specific. So are there certain areas in which you actually see the ICO coming back with much more force than in other areas? Yeah, you know, there's a bunch of ways to draw that line. A big one that I would draw is, does the system need its own token or not? And it feels like, you know, a massive percentage of the projects that we saw in the last

couple of years just didn't need their own token. and so I would put that in the bad ICO category where it just wasn't necessary for the system to be successful. Then in the good ICO category, I think this is really important to note, just like startups, most good ICOs, in my opinion, are still going to fail. It's really hard to build these things successfully,

and it's not a sure thing that once you have kind of a good concept, it's going to be successful. So even within the good ICO category, that's like a really hard. market. It's going to be really challenging. A lot of them are going to fail. Some of them will be massively successful. Some will have middling success. It look just like startups. There are a lot of great startup ideas that fail for a variety of reasons. That'll happen within the good ICO category. But the bad I see them as just these two totally separate markets where the bad category

was people saying, I've got an opportunity to go and try and run away with some cash here. Let me make up a reason for a token to exist and sell it to people and move on with my life. And that's the part that I think has really, really disappeared. And so how do you see coin lists role evolving in the larger crypto space over the next, you know, decade? Yeah. Our goal is to support this ecosystem. We are picks and shovels for this ecosystem. And so you can even see that with the products we have today, that our first two products,

that full sale and that token sale manager product are about sales. They're about capital formation, whether that's for sort of value tokens or protocol tokens or profit tokens or asset back tokens, we're going to help these issuers run successful sales. Then our second two products, coinless airdrops and coinless build, are about building communities, either kind of general communities with airdrops or, you know, developer-focused communities with coinless build. And that's kind of the natural progression for us. Once you've run a sale, you need to build out your community and support your network.

And that's something we're going to help with too. And then we're building out a secondary trading venue where there'll be secondary liquidity. And so we just want to be, you know, start to finish the place where issuers and investors go to do anything with a token network, buying, selling, primary, secondary, building community, participating community, and be the one-stop shop for all of that. So whatever the space needs, it feels like what it needed in the past year or so was help running effective compliance sales. What it feels like it needs now is help building community. Whatever it needs in the next year is what we'll do. But we are here to support the ecosystem. So just one question on that.

You mentioned secondary markets. I presume you don't mean like create a crypto exchange. Do you have in mind creating markets for, let's say, SAFs before, like, while there's still security and before the actual token is issued? Or like what kind of markets are you thinking of creating? I effectively do actually mean a crypto exchange to support the projects that run primary offerings on our platforms, that they can have secondary liquidity on a secondary marketplace, on our platform supporting other tokens that want another compliant venue to trade on.

So we're working on building that out that'll launch next year. I think safts are an interesting case. Almost every saft, if you really dig into it, does not allow for secondary trading of the saft. And there's lots of it kind of happening out there, but it's technically without permission of the company in almost every case. And so unless companies open up to that and are willing to have their SAFs traded on the secondary market, I think that's something we're unlikely to support until those issuers are actually willing to open that out. Can I look back into one of the things you said earlier?

So you said you'll help projects build a community. Building community is actually super hard. And if you think about how many communities each of us are going to belong to in the future, How do you envisage that? Do you think we'll belong to a community more or less for every token we hold or will we hold a lot of tokens that we'll use for interaction with different DAPS, but not really be an active member of the community? Do you think tokens are going to merge with each other or take over?

So basically in three years time, how many tokens will I have in my Meta Mask or browser extension for whatever usage with DAPS? Yeah, that's a very, very interesting, very hard question. I'm going to answer the simpler part of that first, which is what communities will I belong to? I think I will belong to, deeply belong to a few communities for tokens I hold, and then kind of incidentally be in communities for other tokens I hold. So some of them, you know, I'll want to be building, you know, reference applications on their network and being really, really involved, and I'll, you know, commit to being involved in that.

And others I won't. I think it's going to be a lot in terms of the community side, like products I own today. I own this microphone I'm speaking into right now, but I'm not a big audio file. I wouldn't consider myself to be in the kind of microphone and audio equipment community, even though I do own this product. But there are a bunch of other products I own a soccer ball where I'm definitely in the soccer community, and I'm really committed to that. So I think it's going to be the same thing for tokens where I'll have tokens and some of them

I'll be really committed to the community. Others of them I'll just happen to have because I want to have it or need to have it. I don't have a great answer for how many tokens we're going to hold. I do think in the next few years, it's likely that each person will be holding more tokens rather than less. And it may be kind of abstracted away from me that I don't necessarily have to worry about having those tokens. I think there's a bunch of interesting products that are doing things around kind of automatically exchanging tokens when I try and pay for something on a certain network. and so that's interesting to me but I think

many of the kind of cross-chain or interoperability solutions won't have reached kind of massive adoption in the next few years and so it's more likely that we'll have a bunch of individual tokens in our wallets to pay for things but some of that may be abstracted away

and I may not need to think about keeping a supply of it it might be that for example I just need to have a bunch of ETH and when I try and use a service then it automatically there's kind of an eth exchange rate is displayed to me and it automatically swaps it out for that token and I pay with that

and I'm not actually holding that token. I think there's a bunch of different options for how that can play out. But I think these interfaces and user experiences are wildly underdeveloped right now and I'm really, really excited to see what that ends up looking like in the next couple of years. If you're saying that basically

my wallet is just going to exchange the ether I own automatically for whatever token I need, Do you think in principle that token is then needed? Because if it is easily abstracted away by just owning ether and paying in ether, what good is a token that only does that? Yeah. Well, first of all, I should say that is just one of many worlds that we could find ourselves in.

So I'm not, I don't have high conviction that that is the right answer. But I think it goes to different types of users on the system. So when I'm talking about the automatic exchange, I see that as like a very casual user on the system. system. There will be people in the system that want to be dealing with kind of the bare metal all the time. And I would use maybe like a file storage analogy of, you know, I use Dropbox to store my files. And Dropbox gives me a nice interface and, you know, abstracts away a lot of the stuff that I have to deal with. But Dropbox might use Amazon S3 on the back end or their own servers.

And just because I am using Dropbox as a user doesn't mean that Amazon S3 doesn't have to exist and doesn't have a purpose. There are lots of people that get value from using that really down to the metal or not quite metal at the S3 level, but kind of more deeply valuable and configurable service. And so I think in a lot of these cases,

for certain types of users, the token might be abstracted a way in a meaningful way, but for a certain set of, whether it's power users or industrial-level users, professional-level users, the token will be really important for the functioning of the system. So I think just because end users aren't using a token intentionally doesn't mean that that token doesn't have a value on the system.

Cool. Well, thanks so much for joining us today, Andy. It was great to catch out with you and hear about CoinList. So, yeah, thanks so much for joining us. Thanks for having me. Really appreciate it. Yeah, super interesting talk. And yeah, of course, we'll have links to lots of the things we talked about.

There's also lots of interesting blog posts on the CoinList blog. And unfortunately, we didn't get to speak this. time about you wrote some interesting posts about, you know, hostile network, takeovers, which is pretty fun. So hopefully we can get, revisit that at some point in the future. Anytime. Thank you for joining us on this week's episode. We release new episodes every week. You can find and subscribe to the show on iTunes, Spotify, YouTube, SoundCloud, or wherever you listen to podcasts. And if you have a Google home or Alexa device, you can tell it to listen to the latest episode

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