What Bitcoin Did - SAMOURAI WALLET & THE FIGHT FOR BITCOIN PRIVACY w/ Roger Burlingame & Zack Shapiro

Episode Date: December 10, 2024

Roger Burlingame is the defense attorney for William Hill, co-founder and CTO of Samourai Wallet, a privacy-focused Bitcoin wallet. Zack Shapiro is the head of Policy at the Bitcoin Policy Institute. In this interview, we discuss the legal case against Samourai Wallet and the implications for Bitcoin privacy and non-custodial tools. We also get into the historical context of the Bank Secrecy Act, comparisons to cases like PGP and Tornado Cash, and the impact of discovery challenges and legislative advocacy on the outcome of this pivotal case. SUPPORT THE CASE: https://p2prights.org/ MASSIVE THANKS TO OUR SPONSORS: IREN: https://www.iren.com/ RIVER: https://river.com/wbd CASA: https://casa.io/

It's an unmanageable amount of information to get through. And the stakes were getting through it and finding everything that you need to find in there, you know, couldn't be higher. They're attempting to send both these guys to jail for the rest of their lives. Hello there and welcome to What Bitcoin did. I'm your host, Danny Knowles. And today I'm covering what I think is probably the most important story in Bitcoin at the moment. The samurai developers, Bill and Keone, were arrested in April this year

and faced basically the rest of their lives in prison for running a number. non-custodial Bitcoin privacy wallet. This obviously has really profound implications, not just for them, but for anyone building open source Bitcoin software. So to cover this show, I asked Bill's lawyer, Roger Burlingame, and head of policy at Bitcoin Policy Institute, Zach Shapiro to join me. And we got into the Bank Secrecy Act, the tornado cash case, the growing state attack on Bitcoin privacy tools, and of course we did a deep dive on the samurai case. I really hope you enjoy this one, and if you want to support the case, you can make a tax deductible donation at p-to-p.p.riots. I'll make sure all the links are

below. Okay, I hope you enjoy the show. And if you want to reach out to me, you can get me at Danny at what Bitcoin did.com. Zach, Roger, thank you for coming on the show. I actually think that this samurai case at the moment is probably the most important story in Bitcoin, and I don't feel like it's getting anywhere near enough attention. So I really appreciate you both coming on. So we're going to dig into that. But before we do, I think it'd be really good just to give a bit background for both of you and your connection to the case. So Roger, do you want to start? Sure. Thanks for having me. So my name is Roger Burlingame. I'm a partner at a law firm named Decker. And I defend individuals like Bill who have been charged with crimes in the United States or being investigated by the United States, by the Department of Justice, typically. And I split my practice between being based in London, where I am today, in our New York offices.

And, yeah, I was a federal prosecutor for 10 years from 2004 to 2013. And as is typical, in the sort of higher levels of the U.S. white collar bar, I then switched over and have been handling cases like this and representing people like Bill since then. Awesome. My name is Zach Shapiro. I wear two hats in the Bitcoin space. My day job is that I run a law firm called Raines.

We represent startups and investors, largely in the Bitcoin space. I think I have the biggest sort of stable of Bitcoin-only clients of any law firm, at least that I know of. And a lot of our clients in the Bitcoin space face issues that are similar to the ones at issue in the Samurai case around where is the line between a non-custodial business model that can be done on a peer-to-peer basis, just mediated by code. and then, you know, who is acting as a money transmitter or a money service business that needs to KYC their clients and is subject to the Bank Secrecy Act. So I come at it partly from that angle. The other hat I wear is that I'm the head of policy at the Bitcoin Policy Institute, which is a Bitcoin-focused think tank, and then I'm spinning out an initiative of BPI called the Peer-to-peer Rights Fund. BPI is really focused on educating lawmakers,

lawmakers, regulators, policymakers on how Bitcoin works and how to create good policy. around Bitcoin. And we've had a lot of success so far, I think, on Capitol Hill. But, you know, unfortunately, in instances like the Samurai case, the courts seem to be a bigger and bigger part of how policy is made. That's not how the American system is supposed to work. But we're seeing the DOJ and, you know, indirectly the Treasury Department do some regulation by enforcement, in this case, regulation by criminal prosecution. And so the peer peer rights fund is meant to step in and help fund cases like the Samurai Wallet case. We're going to bring our own affirmative litigation to establish good precedent for Bitcoin and

Bitcoin tools and then provide a fund to help provide low cost or free regulatory advice to people building open source non-custodial software. Well, thank you both for joining me. I'm going to preface this by saying I could not be further from a lawyer. So I think I'm probably going to ask some of the questions that kind of like the broader a Bitcoin world will have about this case. But I think this obviously has really profound implications on sort of open source development and the Bitcoin world. But before we get into the specifics of the case, I think it would be worth taking a step back and talking about the other things that

are happening right now. And so maybe we should go right back to the Bank Secrecy Act. Zach, do you want to get into that? Yeah, for sure. So the Bank Secrecy Act was a law that was passed in 1970. At that point in time, there was a lot of organized crime. You've probably seen from mob movies, lots of examples of that. And organized crime was laundering money oftentimes through Swiss banks that didn't keep a lot of records. And the domestic banks they used to send the funds, for example, over to Switzerland, often didn't keep records of where client funds are going from and going to. So the FBI would go to banks. They would say, hey, you know, this mafia character, can you show us what records you have on them, and the bank would say, oh, we don't have anything like that.

So the Bank Secrecy Act was passed to force banks and other financial institutions to keep records of funds. And, you know, in the 1970s, it was probably a reasonable measure to do that. The problem is the Bank Secrecy Act kept getting amended over time and became more and more of a problem in terms of widespread financial surveillance. So the two biggest changes were with the Patriot Act, right after September 11th. And then the 2020 amendment to the Bank Secrecy Act meant to cover things like Bitcoin and crypto. To back up a little bit, there was a question sort of at the outset of Bitcoin about how

does the Bank Secrecy Act touch Bitcoin or the Bitcoin ecosystem? There's a question, is Bitcoin itself somehow subject to the Bank Secrecy Act were centralized exchanges like Coinbase subject to the Bank Secrecy Act? subject to the Bank Secrecy Act. And the part of the U.S. government, a department of the Treasury Department called FinCEN, which is responsible for combating illicit finance, first put out guidance in 2013, saying that, you know, Bitcoin itself as a peer-to-peer system is not directly subject to the Bank Secrecy Act, but exchanges are. And then again, in 2019, FinCEN put out a more comprehensive piece of guidance after different business models had come out,

multi-signature wallets were a thing. Decentralized Finance was starting to become a thing. There was custodial and non-custodial wallets. And FinCEN set out a broader set of guidance looking at different business models within the Bitcoin and Crypto space and saying, okay, certain business models, we think under the language of the Bank Secrecy Act involved accepting and transmitting funds on behalf of the public, which would make you legally a money transmitter and subject to the Bank Secrecy Act. And therefore, you know, you have to register with FinCEN, get money transmitter license and KYC your users and certain other business models, there was not an acceptance and transmitting of funds. And so one clear example is a difference between what FinCEN

calls hosted and unhosted wallets. We would call those custodial or non-custodial wallets. So for hosted or custodial wallets, because you are in custody of users' funds, you are accepting money, whether in the form of fiat or Bitcoin, and then you're transmitting that money when people ask you to move the funds because you, the operator of the custodial wallet, are in possession of the private keys, and therefore you're a money transmitter. You need money transmitter licenses, and you need to K-YC. For non-custodial wallets, what they call unhosted wallets, that's just a piece of software, right? That piece of software helps you generate private keys. You can accept Bitcoin to the public key associated with that address that the software provides, and then you,

the user, sign with your private keys to move funds. So the person who coded up that wallet, right is not a money transmitter because they are just providing you with software that allows you to custody and move your own bitcoin. And so this is sort of how the 2018 guidance parsed the Bank Secrecy Act as relates to Bitcoin. We'll get into this, I'm sure, in more detail. But what's shocking about the samurai wallet case that we're talking about today and a related case against an Ethereum privacy tool called Tornado Cash, is that the Department of Justice seems to be really powerfully deviating from that 2019 guidance from FinCent, which is the sort of last and most robust piece of guidance we have from the government about how the Bank Secrecy Act applies in a way that could set

really dangerous, really, really broad precedent for people who are working in the industry. What Bitcoin did is brought to you by our lead sponsor and Massive Legends, Iron. the largest NASDAQ list of Bitcoin miner using 100% renewable energy. Iron are not just powering the Bitcoin network. They're also providing cutting-edge computing resources for AI or backed by renewable energy. We've been working with their founders Dan and Will for quite some time now and have been really impressed with their values,

especially their commitment to local communities and sustainable computing power. So whether you're interested in mining Bitcoin or harnessing AI compute, iron is setting the standard. Visit iron.com to learn more, which is iren.com. So that's kind of where this deviation seemed to have started with the tornado cash, the arrest of Alexi.

And in my understanding, it was relatively clear that after, I assume after exactly what you're talking about, that these kind of like custodial mixes that have been around Bitcoin for a long time, we knew they were clearly illegal at that point. But we were pretty aware at the same time that things that were non-custodial, your coin joint services up until obviously the arrest of Alexi, that seemed to be something that

was widely seen as illegal. So what was the change there? Yeah, so one knit to pick on this, it's not necessarily that even custodial mixers or tumblers are per se illegal. It's that because they are custodial, right, under FinCens's guidance, they would be money transmitters. And so they're kind of illegal in that in order to legally operate those tools, you would have to KYC or users, which would sort of defeat the purpose of a mixer or a tumbler, right? You, you know, certainly the person operating the tool would know who you are. They would have to report to the government. And frankly, a lot of those custodial mixers and tumblers were used in connection with the dark web. And there are other business models, by the way, that, you know, the government

went after custodial business models pre-tornado cash for violations of the Bank Secrecy Act by way of not registering as a money transmitter. There were exchanges. This was part of the Silk Road prosecution, you know, some famous cases, Charlie Shrem in the early days of Bitcoin with Bit Instant went to prison exactly for this type of violation that Bit Instant was a money transmitter business and he didn't register as such. So the industry had gotten comfortable with LISN if you have a custodial product, whether or not it's necessarily a privacy product. If you had a custodial product, you were a money transmitter. At the same time, you know, FinCEN put out this 2019 guidance. was what all of the lawyers in the space were looking to in terms of what does or does not count as money transmission. And the broad understanding, right? And what I would think it would have

been reasonable for the defendants in this case to understand is because, you know, not only were they not holding users keys, but there was no part of the samurai wallet product, which custody is users funds. We'll probably get into a little bit of how a coin join works. But in essence, you know, Bitcoin goes from one wallet you own, is signed by your keys and goes to another wallet, you own and there's no in between. There's no, you know, even compared to tornado cash where there are smart contracts in between the input and the output with a coin join. There is no such thing.

I think most people who are operating tools like that and Sam Rai, well, it wasn't the only one, would have been comfortable with the idea that that was not what the FinCend guidance meant by a, you know, privacy service or a, you know, what would be subject to the bank I know you kind of touched on it lightly there, but I do think it's worth getting into in a little more detail. Can you explain the difference between a custodial mixer and a non-custodial coin join to the listeners? For sure. So what people generally mean by a mixer or a tumbler isn't, in fact, a service that someone is running, right? So I have a Bitcoin wallet. You pay me Bitcoin plus some some extra Bitcoin that I get to keep. I take custody of that Bitcoin. I do this with a bunch of

different people, and then I follow your instructions about some other address that I'm going to pay the Bitcoin out to, right? And I am a person who is operating that service and holding your Bitcoin in between you paying me and my paying the Bitcoin out. The reason you would want a tool like this is because the Bitcoin blockchain is open for everyone to see. You can get into a block explorer and you can see where funds are flowing from and flowing to. You might be someone who is paid in Bitcoin as part of your job, and you don't want everyone to see. who knows one of your addresses exactly how much you make, how much money you have. You might be paying someone at a store and you don't want to docks your net worth to that person.

You might be a human rights advocate in an authoritarian part of the world that doesn't want funds traced to an exchange account where you're exchanging it to Fiat to pay people who are working with you. So there are all sorts of legitimate use cases for this privacy tool. And someone who's running a custodial mixer or Tumblr is someone who is manually doing this process of taking in Bitcoin from someone and then paying it out. And this is in some ways quite analogous to the financial institutions that the Bank Secrecy Act had in mind that are taking in funds and they are just operating a financial service. A coin join is pretty different. A coin join isn't really a, you know, it's software, right? That is usually provided by some party. It could be decentralized

or centralized software. But there's not an actor that is providing a service in between the endpoints of a coin join, right? A coin join at its core is a collaborative transaction between a bunch of users where we get together and say, okay, we're all going to spend a bunch of Bitcoin at the same time in the same amount, right, as part of the same transaction. And thereby, you know, that's the join part. All of us who are taking part in a coin join transaction or a coin join round are providing each other with privacy by creating a type of transaction that makes it hard to see the flow of funds from and two. And, you know, generally what's in between instead of a service where someone is custodying funds and then mixing those funds and creating different outputs

is a coordination. So, you know, the right mental model for this is, is a bulletin board that says, listen, you know, we're looking for a bunch of people that want to create a private transaction for 5% of a Bitcoin, right? Five million Satoshi's. And then five people find each other through that coordination service. And then those five people are the ones who transmit the money. They sign with their private keys as part of a collaborative transaction that's usually built using some piece of software. And then they push those funds for each user. The 5 million stats go from one address I have to another address through this transaction. So this looks very different than my giving my money to a financial institution and then

them providing a different output on my behalf. So you laid out some of the sort of legitimate use cases for wanting financial privacy with Bitcoin. Whenever the sort of US government or whichever government is prosecuting any of these tools, whenever they're talking about it, they generally talk about money laundering. Do you think they understand how these tools are used for good? I think the short answer is no. I think they have been insufficiently curious about the legitimate use cases for these tools. This is some of the work we're trying to do at BPI,

I also want to give a shout out here to the Human Rights Foundation, which part of their logo is the outputs of a coin join. And they've really been at the forefront of highlighting some of the incredible use cases that people around the world, for whom this is a life or death issue, if you're part of the anti-corruption federation in Russia, you really can't have the FSB seeing where your funds flow to. And so, yeah, this is important both in freer countries and more important in authoritarian countries. I don't think that, you know, it's an interesting question about the motivations behind these particular criminal prosecutions, the Tornio Cash case, and the Samurai Wallet case. While I think that the government does not understand the legitimate

use cases for these tools, I also don't think that this is intended necessarily as an attack on Bitcoin. We can talk about later how it's going to likely unintentionally become a serious attack on Bitcoin. What I think is there is panic in the government about this new technology, right? There is real fear that this provides some sort of loophole. And rather than, you know, I think doing the right thing and having a democratic conversation about what should the laws be that apply to this new paradigm of actual peer-to-peer finance, right, on the blockchain, right, where there is no intermediary people are just interfacing with code. How do we regulate that? What laws should we pass, they're trying to stretch existing laws like the Bank Secrecy Act, like Section 60, which

makes it a—1960, which makes it a crime not to register as a money transmitter, and stretching them beyond their breaking point and beyond all logic to try and fit them within the tools the government already has, and thereby making it easier to prosecute people that they think are contributing to money laundering. And in terms of sort of code being speech, have we not had that first? fight, is that not what the 1990 case, the PGP case was all about? Can you give maybe give a bit of background about the PGP case and sort of the legal precedent of that set? Yeah, absolutely. So I think that's a great point. And I think in many ways, the tornado cash and samurai wallet cases are an

echo of what was called the crypto wars in the 1990s. So Bitcoin, as probably a lot of the listeners in the podcast, will know, is an outgrowth of the cypherpunk movement, right? It was a bunch of programmers that had been working basically from the 70s to the 90s to create freedom through code. And I think in many ways that culminated with the creation of Bitcoin in 2008. But there were other steps along the way. And one of those steps was strong encryption, especially using PGP. And when that came out in the 1990s, the government similarly freaked out. They'd said, listen, this is a neutral tool, but this is something that,

bad actors can use to have privacy on the internet around information, the way that we're talking about it being around money now. And we need to find some way basically to ban this. And the attempt the government used is to declare it munitions, right? You can't export this code. This is something that needs to be very heavily regulated. And there was a large lawsuit about this that the government dropped when the cypherpunks figured out, you know, and Adam Back was a big part of this back then, it was, you know, instrumental in the creation of Bitcoin. You could publish the PGP source code in a book. And basically the cypherpunks dared the government ban us from shipping this book overseas. And then, you know, we'll see what kind of first amendment

arguments there are about that. And the government did the right thing and stepped back. And now strong encryption, you know, we wouldn't have e-commerce without it, right? You wouldn't feel comfortable putting your credit card on the internet if you didn't have strong encryption to hide your credit card details. I think the right analogy when you think about the Crypto Wars of the 90s is that was a First Amendment protection for writing code, right? You couldn't, you know, pre-regulate people. You couldn't prosecute people just for writing code. But it didn't go as far as to protect people from running code. And that's what we're dealing with now, right? This sort of Crypto Wars 2.0 is about,

do we have protections for, you know, First Amendment protections and other protections for running the code on the internet that I think everyone agrees it is legal to just write? And even in the, I think we'll probably talk about the tornado cash motion dismiss decision that we got a couple months back. But even in that case, Judge Fala, who created what I think is an incorrect and very damaging ruling for the industry, acknowledge that it would not be legal to prosecute someone just for writing code. And so now we're talking about, okay, you've written the code, you hit publish, and now

people are using that code for whatever they use it for. You're not in control of it. It's just code on the internet. What First Amendment protections, if any, are there in that? case. So just before we bring Roger in from the cold and get his take on the samurai case, do you want to just talk about that tornado cash ruling that happened very recently? Yeah, so there were two recent tornado cash rulings. One of them is a little bit less relevant to samurai, but was sort of a happy ruling. We talk about immutable code. We talk about

things operating on a peer-to-peer basis. There was a similar case that is more important where the tornado cash developers are being prosecuted in much the same way that the samurai while developers are being prosecuted. But that did not stop the tornado cash smart contracts, which is the core of that tool from continuing to operate because they are immutable smart contracts. The admin keys to change them to upgrade them had been burned by the developers. And so the government took another extraordinary step and used its sanctions authority under a different part of the Treasury called OFAC to sanction the code itself, the smart contracts living on the blockchain and said, you know, it is a crime for any American citizen to interact with these,

to send or receive funds and these smart contracts. Now, of course, being the crypto community, the first thing that people did was find all of the public celebrity Ethereum wallets that are out there and then dust small amounts of Ethereum and USDC through the sanctioned, you know, tornado cash smart contracts to these wallets, creating a technical violation of the sanctions to show how absurd this was. And then, you know, there were a pair of lawsuits arguing that it was unconstitutional. It was outside the government's authority to sanction these smart contracts. Unfortunately, both these cases did not succeed at the district court trial level.

But then recently, the Fifth Circuit Court of Appeals said smart contracts are not property. They're not subject to OFAC sanctions authority. And that was a very positive ruling. The flip side of that is in the tornado cash criminal case against one of the developers, Roman Storm, arguing among other things that he was guilty of not registering as a money transmitter because the tornado cash service, so the tornado cash smart contracts, their front-end website, and then this tool called a relayer that helped you pay Ethereum gas fees to use it. Those collectively amounted to money transmission.

Judge Fela, the judge in that criminal case, denied Storm's motion to dismiss. The motion dismiss was based on some of the same arguments they're going to be made in Samurai, saying that, listen, this was a non-custodial product, even though there was a smart contract that pooled users' funds, pooled users Ethereum, and then allowed people to use zero-knowledge proofs to withdraw Ethereum in a private way, which, by the way, is different how things work in Samurai wallet, importantly. But because the defendants had no control of those funds, therefore they were not money transmitters under FinCEN's definition and under the Bank Secrecy Act. Judge Vela denied that motion and the case is moving forward to trial.

And in denying that motion, I think went much farther than she had to and ruled that the Bank Secrecy Act doesn't require control over user funds for money transmission. That the 2019 FinCEN guidance we were talking about doesn't require any kind of control. that tornado cash, this decentralized smart contract that's immutable, is not meaningfully different than custodial mixers, like we were talking about before, like Bitcoin fog, that the tornado cash service goes beyond providing just network services, which is another defense that defense in that case and likely in this case will make. And it was a, I don't know, I think quite a wrong-headed and very broad ruling that I think will probably have to be challenged and overturned on appeal. Obviously, the overturning of those sanctions is a massive win. Were you surprised to

see it, or do you think this was sort of the natural conclusion of that? To be honest, I was surprised to see it. I think the decision was correct. I think the precedent that immutable smart contracts are not property is really powerful. Now, it's important to sort of be a little bit measured in how much of a win that case is. I don't know that it's particularly helpful in You know, the Samurai Wall case were even really in the tornado cash criminal case. And it only applies to immutable smart contracts. It's interesting to just a thought experiment to think what analogs are there in the Bitcoin space. Can you create something like an eCashment that is immutable in the same way that those smart contracts are immutable?

You know, it remains to be seen. You know, a mutable smart contract or, you know, a federation will talk about sort of collateral damage from these cases later. those probably are not the beneficiary of that same ruling. But it's a surprising, I think positive and correct step in the right direction. This episode is brought to you by River. There are many places to buy Bitcoin, but there's no exchange like River. They have innovative products, phone support, and a dedication to security that I haven't seen anywhere else. With River, buying Bitcoin is easy. You can set up zero fee recurring buys to automatically build your stack. And while you're waiting for the perfect buying opportunity, River even lets you earn

daily Bitcoin interest on your cash balance, which outperforms most high-yield savings accounts. Your Bitcoin is stored safely in multi-sig cold storage, plus you have peace of mind knowing that River has monthly proof of reserves and holds all client Bitcoin that wasn't withdrawn to self-custody. Open an account for yourself or your business at river.com forward slash WBD. That's rivir.com forward slash WBD. Okay, Roger. By the way, I love that we've got a classic gray London Day for the backdrop there. So do you want to give us a bit of a background on the samurai case?

Maybe we'll start with sort of the arrest of Bill and Keone and how you first sort of came into contact with them? Sure. So Keone was arrested at his home in Pennsylvania and Bill was arrested at his home in Lisbon. and when you get arrested overseas, the case against you is that you're in custody on a U.S. extradition warrant, and then there's procedure in the country in which you're arrested

as to whether per the extradition treaty with the United States, all the relevant boxes have been ticked, and you should be shipped to the United States or not. And so the first lawyer that you typically get is your extradition lawyer, that's what's happening. And I'm handling a lot of cases involving Europeans and Brits who have been charged in the United States. I know a lot of the people who specialize in extradition cases. And so Bill got in touch with an excellent, probably the best extradition lawyer or retained the best extradition lawyer in Portugal. She and I worked together on other cases. And so she called me

and then I went to go meet with him in jail and Lisbon. And he retained me. And we started forward from there. And so the first thing that happened with him was figuring out how to get him out of jail in Portugal. And because they're as, I think probably even as non-legal expert, people are aware of that there's a long time typically between arrest and trial. and you know it's a huge you're you're innocent until proven guilty but if you're in jail for you know a year and a half prior to a trial it's the same punishment as if you're later proven guilty so the first first step in the case was trying to figure out how to get him out on bail and we were able to do that and we were able to get him bail back to Portugal so he's back living in lisbon and and that was a a nice initial victory because, you know,

United States courts are not typically dealing with defendants who are located outside the United States. And so when you go in front of the judge and say, Judge, we'd like bail. And by the way, we'd like bail across the ocean. You often get some raised eyebrows. So very happy that he is able to spend this time while we are preparing for trial, you know, at home in Lisbon.

And so before this case, Did you have any knowledge about Bitcoin? Yeah, I've done some other cryptocurrency cases. Nothing that's been dialed in as tightly as I am now on Bitcoin. But the sort of remit when you're a criminal defense attorney, especially in the white collar case, is your clients or, you know, there was a period of time when after the financial crisis,

the U.S. government was going after bankers extremely hard. and I had a series of traders. And so, you know, you go from knowing very little to thinking, huh, maybe I'll try my hand as a, you know, derivatives trader because I've now spent so much time understanding how derivatives trading works from my derivative trader client that, you know, I got it. So we're now, I think we've been representing Bill for about half a year. So, you know, there's still more to learn.

I think I'm not as deep into the tech as I'm sure. Zach is and probably you are as well. But, you know, one of the things about criminal cases is that they, you know, it plays out in front of a jury at trial and you're not going to win the case by getting

deeper and deeper and deeper into the technology that nobody understands. You're winning it on big picture issues. And I think there's an interesting divide in this case between you know, the tech being important to the legal arguments.

But then there's also incredibly robust arguments on the sort of big picture, what's right and what's wrong, what's fair and what's not fair. You know, why are we seeking, why is the government seeking to put these people in jail for doing something they thought was completely lawful and legitimate? I think we've got, you know, a great case on that fronts as well. So is that background part of the reason that you were the right pick for Bill? What is it that made you the right lawyer for this case? That's a great question.

So I have a niche where I sort of, by all right, should be sitting with this same background being Manhattan. And about 40% of the time that is the background. But after so it's a very well-trodden path from the U.S. Attorney's Office prosecuting you know, market manipulation and securities fraud and other kinds of big fraud cases to private practice defending companies and people who are in the crosshairs of DOJ or the SEC or CFTC or whatever it might be. And I came over here, was pitched by the head of my prior firm saying, you know, I'm sure you're a wonderful lawyer and your mom probably understands that you're the best lawyer in all of New York City, but the client might have a hard time telling the difference

between you and the other 400 former USA's former federal prosecutors running around New York, you know, offering essentially the same services. But there's this place called London, which the DOJ treats as the 51st state, and you would be one of one person like you over there. When I said, that sounds interesting, but, you know, I'm a conservative lawyer by nature, didn't want to. At that point, I was massively in debt from being a public servant for a law for a decade and had my sort of resume to trade for enough of a salary to get myself out of debt and, you know, wasn't in the mind to take a big bet with my career. And I went home and my wife said, how did the interview go? And I said, well, it seemed pretty good. They seemed interested in

hiring me. And she said, well, why aren't you more excited? And I said, you know, it's this crazy thing where they want me to go move to London. And she goes, we get to move to London? and I was like, you want to move to London? And so that was 12, almost 12 years ago. And it turned out that my former partner was exactly right and it was

very good to be different. And so I have, you know, if I was sort of my career was playing out in the normal way, I would be Sydney Manhattan and I would have maybe had one case over the course of the last 12 years where somebody would be overseas and being extraded back to the United States.

And instead, I think this is, you know, number 15 or something like that. So I have a real specialty in these kinds of cases, and it's extremely helpful, you know, for me to a lot of defending somebody is, like I said, you know, figuring out what it is to be a derivatives trader or figuring out, in this instance, what it is to be a developer for, you know, a Bitcoin privacy wallet. And so you need to spend a lot of time with your clients. And when you're, you know, getting off of a plane and you're five hours off of time zone and,

and, you know, you need to get back to your wife and kids who are five time zones away, you know, it puts an imposition on the job that you can do. And for me, you know, to get to Portugal is two hours and I'm on time zone. And it's really very helpful for doing the majority of the work. And then when you court appearances roll around, I fly in for the court appearances. and, you know, the work of the criminal defense attorney is heavily weighted to, you know, there's much more work with your client than there is work in court up until trial and then it switches. And so on trials, I then go live in the United States for, you know, a while before the trial and during the trial.

One of the big questions I have for you is like, why is now the time you want to come out and talk about this? Because surely there is risk in talking too much pretrial about what you're going to do. Yeah. So the motivation is extremely simple. which is, you know, this is a big, big case and volume-wise. I mean, I think it's a big case stakes-wise for some of the reasons that Zach has been talking about. And anytime the government is trying to put you in jail, it's an enormous stakes for the person

who's on the receiving end of a criminal indictment. But the discovery that's been produced in this case is staggering. And, you know, the clients are already going to burn through their life savings to, you know, be able to minimally defend themselves in this case. And the reason for me being here is to say to the community of people who care about this case, and I think, you know, the outrageous injustice that's being done here, that we could use some help. and that it, you know, especially trials are sort of like going to war, right? It's an oppositional system, and the government has unlimited resources. And you are, you know, obviously there's a lot that's fixed, you know, you, the basic themes of the case are already there and have been there from day one. but if you have, you know, going through, I don't know, 30 or something I think so far,

terabytes of information to find out what's good and what's bad in there for you and what is the government going to argue about this, you know, line of text, which is completely de-contextualized and finding out in advance what the context is. So when it gets raised in trial, you're right on top of it and can respond. You know, that is lawyer. doing the punishing work of the junior lawyer, which is sitting in front of your computer and first running all sorts of searches

to try and identify what's important across the data because obviously we could sit here for the rest of time and not look for 30 terabytes worth of information. But trying to find within the world's biggest haystack, what is the good stuff that is going to make a difference in the case and what is the stuff that the government thinks is going to make a difference and that we need to be prepared to defend.

And basically, the better, you know, this is where resources matter and the better funded you are, the better your odds of winning. It's really, really simple. And, you know, at the moment, we are going to be able to defend the case, but we can defend it on a completely different level if we're better funded.

Roger, you had a great line, I think, in one of the hearings, I want to make sure that I heard, right, if you printed out the 30 terabytes or so, you said that was 75% of the volume of the Library of Congress. Is that true? Yeah. So that was as of, that was the state of that case as of the last status conference, which I think was three months ago. And we've received, you know, many, many terabytes since then. So my guess is we're now beyond 100% of the Library of Congress. The other one was, you know, then if you stacked the paper up page by page, it went to the moon and back, something like 25 times. I mean, it's like

a completely impossible amount of information to deal with. But, you know, this is sort of the reality of being a litigator in the age of, you know, big data and chats and communications and everyone, you know, sending and receiving hundreds of emails a day is, you know, you get this kind of thing. And you can have, you can have computer learning assistance. review. You can have, you know, you can obviously run searches. You have to run searches across the data. You know, AI assisted review is coming and actually is here in some instances. But, you know, there is nothing like having some bright, young, poor bastard who just graduated from Harvard sitting there 70 hours a week, looking through the stuff that might potentially be

valuable and saying, oh my God, I found, you know, the key document. I mean, I remember when I was a prosecutor, this is a little too far off topic, but there was a case. I was prosecuting this New York state senator who was stealing funds hand over fist from the poorest hospital in New York City, a place called Soundview in the Bronx. And one of the ways he was stealing money was by, or when he was a senator, he was stealing money by claiming predisposing. for days when he was not actually going to Albany and serving as a senator. And he had this definition of per diem that I can't remember what it was. But it was basically like, I'm allowed to charge per diem, like essentially no matter what I'm doing. And it was it was sort of superficially appealing enough that some juror, maybe two jurors, would be taken in by it.

And we were, you know, you just work all the time coming up to a trial. And I remember about 3 o'clock in the morning coming across some memo that he had written 35 years before where he had defined for his staff what Pru-Diam meant. And I was like, oh, my God, this is it. We've knocked out the Purdium defense. And I was so excited I went running down the hallway to go, you know, share it with my, the guy was doing the trial with me. And I ran into a concrete post and almost knocked myself out. So it's that, you know, it's the like endless labor that makes a difference. And unfortunately, you know, that is very, very expensive to do. And so, you know, the message is it really, really makes a difference, right? It's the exact same thing as going to war and like, how many tanks do you have? How many planes do you have? How many bullets do you have? And, you know, we've got, we've got a limitlessly funded opponent and we could really use that. help of everybody who's interested in this issue. I just want to highlight that one more time for

anyone who's listened to this and think about making a tax deductible donation to the peer-to-peer rights fund to support this case. This is not an accident that there is this amount of volume of discovery. This is a litigation tactic, right? That is very common, but the government is using here to make it, frankly, difficult to see what is the needle in this ever-growing haystack. and it is expensive to throw smart associates at this to figure out, okay, what are the things that we really need to address? How do we mount the best defense possible at trial and show the jury what they need to see to realize, you know, what is a stray comment as opposed to what the government is alleging is a basis for a money laundering charge? And the money that we're able to raise for this case really goes directly to can you effectively mount that defense. defense and therefore are we going to get precedent that damages people who want to build open source

tools in the future. Is this a tactic that the prosecution are using to make it cost prohibitive to defend this case? It's, it's, I mean, I think it's kind of a natural function of the system, right? What happens is they want to do, in doing their jobs well, they're wanting to collect every possible shred of information in which there could be evidence. And in doing that when you seize, I mean, I think between the two searches, over 40 devices, you know, thumb drives, phones, old phones, computers, old computers, hard drives have been seized. And, you know, it's decades worth of electronic storage devices. and then all sorts of information that's seized prior to the indictment through search warrants from, you know, entire Gmail accounts and cloud storage devices.

Cloud storage. And, you know, so, and then the government needs to make sure that it's turning over all of the information that could be helpful to the defense, right? We don't necessarily want them picking and choosing what they think we should get. But so, you know, it does end up being, you know, the problem that Zach described is absolutely accurate. And kind of, you know, regardless of anybody's intention, the problem that you end up with is the exact same one, which is it's a unmanageable, out of information to get through. And the stakes were getting through it and finding everything that you need to find in there, you know, couldn't be higher. They're attempting to send both these guys to jail for the rest of their lives. This episode is brought to you by CASA. For those

you out there who want to protect your Bitcoin, I want to tell you about CASA, the leading Bitcoin self-custody solution. So if you're serious about protecting your Bitcoin, then you need a rock, a solid security plan. And CASA gives you just that. With their multi-signiture security and key management services, CASA makes it easier than ever to take control of your Bitcoin without the risk of a single point of failure. They offer multiple levels of protection, all designed with simplicity and ease of use in mind, even if you're not a tech expert. Don't leave your Bitcoin security to chance. Go to CASA.org and check out their services today to protect your stack and sleep easy. That is CASA.io, which is c-a-s-a-i-o.

So let's get into the details of the case. What exactly have Bill and Kearney been charged with? So they have been charged in the Southern District of New York, which is the federal prosecutor's office in Manhattan, with conspiring to run an unlicensed money transmitting business and with conspiring to launder money. And conspiring is just an agreement between two people to commit a crime. So agreeing to commit the crime of,

running an unlicensed money laundering business and agreeing to commit the crime of money laundering. And the government's basic theory of the case is, you know, this was, you know, rejecting the FinCEN guidance that Zach was talking about in the beginning and saying, you know, regardless of what the United States government has said in the past, we are declaring this to be a business that is a money transmitting business. And so since we've now declared that it is a money transmitting business, it's a crime for you to run a money transmitting business without a license. And then that's sort of the first side of the coin. And then the backside of the coin is, you know, what you have like a bank is a money transmitting business or Western Union is a money transmitting business. And if you're running that kind of a business, there's massive controls in place about all sorts of things, but particularly, about money laundering. And so where the money laundering charge comes from is you didn't put any of the money laundering controls in place, and people were laundering money via a samurai

wallet. And since you, you know, are aware that you're a money transmitting business, which, by the way, they're not, since no one was saying, this is a money transmitting business privately, and you didn't have these controls in place, you're therefore agreeing to longer money. I mean, it's very aggressive. And I mean, to just give you a little sense of how aggressive it is, I don't know if it was the day after, you know, within the first week,

following the indictment, two United States senators, one Republican and one Democrat, wrote in and said, you know, this is an outrageous and unprecedented application of these rules. And, you know, I have been doing criminal law for upwards to 25 years now and have never, you know, not only had in my personal experience, but never heard of, you know, politicians coming out and advocating on behalf of people who are alleged criminals. It just doesn't happen, and especially United States Senator. So, you know, it is a very aggressive charge, but that doesn't mean that it's an easy case to win, right?

When you're going up against the, you know, juries are made up of average folks. And you go in for your jury duty and you get to. in the, you know, you get picked, and you're sitting there in the jury box, and the prosecutor stands up and says, you know, I mean, I said this for 10 years. I'm Roger Burlingame and I represent the United States of America. Like, that man over there was blah, blah, blah. And then you accuse them of the crime. And, you know, there's a presumption of innocence. Our criminal justice system is built on it. But there's a pretty powerful danger that a lot of people in that jury are going to be thinking like, well, you know, if you didn't commit the crime, what are you doing here?

So anytime you're charged with a crime, no matter how aggressive the charge is, it's, you know, a deadly serious situation. And it's, it's, you know, no matter how good the defense is, there's no such thing as a layup in, you know, defending a criminal case. So that letter from Cynthia Lummis, I forget the senator that co-signed that with her. How much does that move the needle for you? I raised that at the last status conference seeking to file the motion to dismiss. Usually courts group all of the motions that can be filed into one big omnibus motion. I was asking the judge, or me and co-counsel for Keone,

we're asking the judge for permission to file the motion to dismiss early that makes the sorts of arguments based on the FinCent guidance that Zach was going through earlier. To make that, to sort of start the case with that, because this is such an aggressive prosecution, and there is, you know, a real, like, completely non-frivolous argument that what is being, what they're being accused of is not against the law. And cited the, you know, the letters from the two senators. and it could not have gotten less traction. So far, it has not moved the needle, but we shall see. I mean, it's not something that would move the needle at trial

because it's something that the jury would never learn about unless they're not following the judge's orders and reading the paper on their own time. Okay. This might be a silly question, but obviously the US government has a pretty good hit rate. What kind of percentage chance do you think you have of actually winning this case at trial? Well, I think juries are very good at, you know, it's terrifying trying cases, right? Because you put this stupendous amount of work into it and you're incredibly deep in the details.

And you finish the case and you've done your closing argument and you feel really good about, you know, we've explained this all as well as we can. The trial went great. And then the jury gets to send out notes. asking for additional information while they're deliberating. And invariably, you know, the first note comes out and you think, oh my God, like, what are they thinking about? And, but, you know, they tend to get things right for the most part. I think sometimes there's a tendency to split the baby, right? That jurors in the United States have to be unanimous. And when there's a hung jury, the judge will give the instruction to go back and keep deliberating and go back and keep deliberating.

And after that happens four or five times, there sometimes is a tendency to like, okay, well, why don't we just, you know, we'll convict the guy on one small thing and I quit on everything else. And everyone says, okay, great, let's get out of here. But I'm hopeful in this case because I think that the big picture of who these guys are is clear as day. which is that they're privacy advocates. And, you know, you sort of slap them awake at 3 o'clock in the morning and ask them who they are, and they say, I'm a privacy advocates. Like, they're, they're to the bone exactly who they present to be. And I think the government's theory that, you know, these are two guys who set about creating a money laundering machine in order to help criminals launder money is just diametrically opposed to the facts and to who. they are, and I think the jury is going to be able to see that. And when you, and I think there's also a

huge element of unfairness in the case, right? So, you know, if you understand that what you are doing is not running a money transmission business, and therefore you don't need a license, and you don't need to put all these anti-money laundering controls in place, and that's a belief you hold in good faith, it's incredibly unfair for the government to then say, hey, by the way, I know we put out this guidance, but, you know, don't pay any attention of that because we, the prosecutors, have decided the guidance, you know, doesn't have anything to do with this, and you actually are a money-transmitting business. And I think that's, you know, despite the ruling in tornado cash, you know, that's not good for us as a legal matter.

I think Judge Vela got it wrong, and I hope that Judge Berman, our judge, gets it right. But what our clients understood to be the terrain, you can't agree to commit a crime if you don't think you're committing a crime. And, you know, the idea that they should have somehow divine that, you know, when they're doing their business in 2020, the judge Fela in 2024 is going to say, actually, no, this is a money transmitting business,

despite what FinCent is saying is, you know, putting them an impossible situation, and it's deeply unfair. And I think the jurors are going to understand, like, what the hell is going on here? This is totally unfair. And those are, that's powerful. In this case, there's obviously kind of the additional complexity

of having to explain Bitcoin and the intricacies of how it works to the jurors. How are you going to sort of face that challenge? Happily, in a way, for us, that's primary, you know, the government goes first and they're tasked with, so they put on their entire case, and then they rest, and then defense gets to call witnesses and put on its case. And so they'll probably start by calling an FBI agent who will be, you know, their expert on cryptocurrency and he'll give the jury a big tutorial on what, you know, what they need to know about Bitcoin in order to understand what's going to play out in front of them. And that will be

the sort of primary education mechanism. And, and then, you know, what we do is for the parts of the case that we think it's important for the jury to understand, you get to, you know, when the, when the prosecutors are finished asking their questions, then you get to stand up and cross-examine, and you make sure to underline through your cross-examination, you know, what's important and what's not important for the jury. Okay. And just give us a bit of a timeline about how this is going to play out. Like, when are you expecting this to actually go to trial? Well, we're in the middle of discovery, which is discovery is the process of the government providing its evidence to you all of the all of the what we've been discussing all this information.

There's still quite a bit of that to go and then you need to actually look through it all. And then there's lots of legal motions and sort of wrangling about what's going to be an evidence, what's not going to be an evidence should the case be allowed to proceed forward. You know, my guess is that the soonest would be probably in the back half of 2025 and the latest. would be in some point in the sort of latter front half of 2026, but it's up to the judge. And, you know, that's my sort of general sense of the schedule would be, you know, late 2024, early 2025. And presumably is your best case scenario that this case would then be dismissed actually before trial?

And if that's the case, how likely do you think that is? That's absolutely the best case scenario. it's infrequent that that happens in criminal cases, so we're not counting on it and we're doing all of the work for trial. And, you know, I think it is, you know, I think we, the short answer is we should when what you're talking about is the motion to dismiss, right, where we say this case is unsustainable on the law. I think we're right. I think the case should be dismissed. But, you know, whether or not it is, I think that's exactly how the defendants felt, and I'm sure the defendant's legal team felt in the tornado cash case,

Judge Fela felt differently, and, you know, I'd be delighted with a win, but I will not be shocked if we don't get one. Okay, so, Zach, one of the things that I would really like to hit on with you is this doesn't just affect the samurai guys. This affects everyone who's interested in Bitcoin. Do you want to kind of lay out why that is? Yeah, for sure. I think the best way to understand this is to understand what argument the government needs to make in this case to say that the samurai wallet defendants operated a money transmitting business. There need to be, I think, two logical slights of hand that we can see both from the government's briefing in the tornado cash case and then the indictment in this case in the samurai wallet case.

The first is a move from looking at the tool itself, the thing whereby money moved, and then looking at what they're going to call the broader service, right? So all of the stuff around it. In the indictment in the Samurai Wallet case, the fence are charged with paying to have their app listed in the Google Play Store, paying for servers that could help run the coordinator, that bulletin board we were talking about before, that allowed people to coordinate among themselves to do these collaborative transactions. And they're going to say, okay, all of these things, some of which for which the defense received fees, are together this business and not just the coin joint itself, which in the case of

Samurai wallet is the whirlpool tool and then the similar ricochet tool, which creates hops in transactions to add privacy, right? It's all the stuff around it. And they say all of that stuff together is the business. The other slight of hand here is to say that funds were transmitted using the tool without pointing to who is doing the transmitting. In the tornado cash reply briefing, we saw the government analogize. They say, listen, you don't need custody of funds in order for there to be a money transmission, much the same way that a USB cable transmits data or a frying pan transmits heat, even though the frying pan and the USB cable don't have custody of the heat or the data, respectively,

which is all well and good unless you ask the question who's doing the money transmitting. And the 2019 guidance, I think, very squarely points to if you are holding the private keys, if you're the one who's signing and making the transactions on the blockchain, you are the money transmitter. It's not some third party the way that it is if someone has custody of your funds. So if we take all of that together and we say, okay, you don't need to be in custody of funds to be a money transmitter, merely providing sort of ancillary services that facilitate people's movement of their own money on the blockchain using their

own private keys, that's a money transmitting business. Well, then we have to step back and say, okay, what other things could this be true of? So some are very obvious, a lightning routing note. You're making fees on facilitating people's movement of their money, even in a non-custodial sense on the Lightning network, Lightning service providers. Certainly, you know, e-cashments, both federated e-cash mints and the type of mince we see in cashew, I assume it would be a great risk here. People who run all sort of non-custodial wallet products, right? If that might be off the table, if a wallet is, you know, especially if it has a node attached to it, you're using ledger and there's ledger live software and you're relying on ledger's node

to broadcast the transaction that you signed the Bitcoin blockchain, well, isn't that facilitating the transmission or movement of money? so various wallet and node operators could be at risk. Bitcoin miners. There's a specific FinCEN guidance about Bitcoin miners that says essentially if you earn fees from being a minor and then you pay those fees out either to your shareholders or use them to fund your operations, that act of using the fees in that way isn't money transmission because that's income you earned. But the FinCENSign guidance doesn't address the fact that minors basically append transactions to the blockchain, right? That's what they're doing. They're writing transactions to the blockchain. So might that be

facilitation of moving funds in a way that's money transitioned? So miners would have to K.YC people, which would be impossible. That would be an effective ban on mining in the United States. You can go down the list and basically it would render any kind of peer-to-peer finance, any kind of non-custodial tool illegally. So, you know, there is no limiting principle of the government's arguments. The answer is we don't know how far this goes. There are sort of inner and outer layers of what this could be from. This is just a problem for lightning routing nodes, which seems very likely to, at the end of the line, this is essentially a ban on self-custody because no one can write the software that people use to hold their own Bitcoin. But that's the

scary thing about this, so that there is no living principle. There's no way to draw a line and say this part of the industry is safe. And we saw those chilling effects kind of immediately after these arrests. We saw, obviously, Wasabi turned off their coordinator. They removed themselves from the U.S. market, Phoenix removed themselves from the U.S. market. The Wasabi one makes more sense. The Phoenix one, again, like you're saying, it just shows that they're not confident about how far these things are going to go. One of the questions I would have is, with the incoming Trump administration, who are claiming to be sort of pro-Bitcoin, we'll see how that actually plays out. Do you think, Roger, that offers you kind of a,

I guess, does that give you any hope in this case? It would be great if the new leadership of DOJ took another look at the case and decided that they agreed with Senators Wyden and Loomis. You know, we're not banking on it, but it would certainly be extremely welcome news. What would your take on that as a BZAC? Yeah, I think it remains to be seen, but there are some signs for optimism. If we look at, you know, what are the various departments that touch this issue? The most sort of obvious and direct one is the prosecutor's office, the Southern District of New York, the person who's been named to be the next U.S. attorney for the Southern District of New York. Jay Clayton is someone who's very familiar with cryptocurrency and is someone who's going to understand this custodial, non-custodial distinction.

He's an advisor to a VC fund that invests in a lot of non-custodial technology. So that might be a sign for optimism. The person who has been nominated to be the crypto czar, David Sacks, who is likely to have the president's ear on these types of issues, is himself a venture investor in multiple lightning companies, right? That would be directly at risk from this case, right? He was one of the early investors in Lightning Labs, which provides the infrastructure for non-custodial lightning.

So some signs for optimism, on the other hand, the sort of big money interests in lobbying the United States government about crypto and digital asset policy are frankly really concerned with this issue of sort of token launches and our tokens securities or commodities and can we legalize a lot of the sort of VC token launches. And I think there's sort of less big money pushing this issue, which frankly is a much bigger existential threat to sovereign use of Bitcoin and crypto. So I think it is incumbent upon people listening to this, people who are working in the policy space to really keep the fight moving forward and to focus on this issue, which is the difference at the end of the day, if we do this right, having strong protections for all of the things that Bitcoin

is meant to promise and all the things that makes Bitcoin different than the traditional financial system on the one hand, or on the other hand, if this goes in the worst way possible, this could be a backdoor ban on self-custy. It's every bit as bad as whatever Elizabeth Warren can dream up. So Roger, for any just regular Bitcoiners, people like me out there who are listening to this, what do you want people to do? Give to Zach's fund. Okay, Zach, where do they go to do that? At p-to-prights.org.

And then there's a, on that website, there is a tab specifically to help fund the Samurai Wallet Defense. If you pay in either Fiat or Bitcoin and you provide your information, it's a tax-deductible donation or a 501. So especially if you're someone out there that has really large Bitcoin or micro strategy gains this year, you know, maybe you can offset some of those capital gains that you've incurred by making this donation. Or if you're a privacy advocate, maybe you've been sitting on Bitcoin for, you know, 10 plus years now and you'd rather not docks yourself even to us. We are very happy to accept anonymous donations and we are certainly not going to ask any questions. Love that. Well, you have my full support. I'll make sure all those links are included.

Do you want to say something else to that? No, I was just going to say, you know, we talked about this at length, but it is, you know, it's the highest stakes imaginable for both Keone and Bill. And the money that would be donated is going to go directly to enhancing our chances of winning this case, which, you know, what I care about is for them personally, getting out from under this, you know, nightmare that they're going to. they're living. But, you know, it also, I think that the outcome of this case is going to effectively set policy. And so if you're primarily concerned about the issues Zach was just talking about,

you know, it's also the best practical way to have an impact on those issues. Love it. Well, thank you very much, Roger, for defending this case. Very much appreciate it. And thank you, Zach, for setting up the fund. I'll make sure everyone has access to that link. And if there's anything else, anywhere else you guys want to send them? Or are you happy with that? Yeah, one other pitch. If you're listening to this and you are working a Bitcoin startup, you're building Bitcoin technology or you're thinking about doing so, and you're at all feeling scared by the precedent that might be said in these cases. One of the sort of reasons for the peer-to-peer funds to exist is to help folks like you is to develop a war chest to defend these future cases. And I'm always happy to have a conversation with folks who want to think about their business model. but we want to limit the chilling effect from the samurai wallet and tornado cash case as much as possible. So please, please, feel free to reach out. My Twitter DMs are open.

You can find me at Telegram at CoinLoyer. But, you know, don't let bad actions by, you know, certain prosecutors stop you from building the tools that we need to spread Bitcoin to the world. Well, thank you very much. All the best with the case, Roger. I hope it goes well. Yeah, thank you very much at the time. Appreciate it. Thanks so much, Jenny.

Thanks, Zach. Thanks for having me. You know.