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>but that is a pretty onerous requirement if you think you're not a security

But the SEC does, so tough luck?

>The Telegram token may increase in price but there's no profit sharing directly from Telegram

Sounds like a weasely attempt to skirt the rules. Look up the Howey test

>The leading case on the definition of an investment contract is the U.S. Supreme Court case, SEC v. W.J. Howey Co. Under the Howey test, an investment contract is “a contract, transaction or scheme whereby a person invests his money in a common enterprise[1] and is led to expect profits solely from the efforts of the promoter or a third party.”



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