Trying to Think like the SEC (Feat. John Reed Stark) – Crypto Critics' Corner
Cas Piancey and Bennett Tomlin are joined by John Reed Stark, president of John Reed Stark Consulting, and former Chief of the SEC office of Internet Enforcement. John has also started a website focused on cryptocurrency called DigitalTrustWatch.
In this wide ranging episode we discuss the nature of fraud, what cryptocurrencies look like, similarities between internet fraud and crypto fraud, and why the SEC has been muted in their response to crypto so far.
One brief correction we would like to note: John says that the crypto holdings of the SEC were requested in the KIN case, but it was actually in the XRP case.
Other episodes mentioned in this show:
- Episode 50 – The Return of the Bitfinex Hack: $4.5 billion in Bitcoin is Found and Seized
- Episode 26 – Cryptocurrency Lending is Too Good to Believe
- Episode 39 – Fuck the SEC, all my friends hate the SEC
- Episode 57 – Ukraine and Russia and What it Means for Cryptocurrency
- Episode 9 – Shillfluencers (and the unspoken financial epidemic)
- Episode 42 – Elizabeth Holmes, Theranos, and the Future of VC (Feat. Elizabeth Lopatto)
- Episode 60 – The Foul Financials of Cryptocurrency (Feat. Francine McKenna)
- Episode 54 – Web3 is Wonky (Feat. Molly White)
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Welcome back, everyone. I am Cas Piancey, and I'm joined as usual by my partner in crime, Mr. Bennett. Tomlin, how are you today? I'm doing well. Cas, how are you? I'm doing good. We are joined by a very special guest today. I don't know how we keep getting the best guests, but we have another fantastic guest today, John Reed Stark of John Reed Stark Consulting, who is also a professor of law at Duke University and also was the chief of SEC Office of Internet Enforcement for roughly how long was that? 20 years? Almost. I was with the enforcement division for almost 20, and then I was chief for about eleven years. And technically, I guess I'm a senior lecturer in law as opposed to a professor, but they all call me professor. And I've been teaching for 20 years, so I had 15 years at Georgetown, so I don't care if you call me professor. I've earned it. Well, good then. Yeah. Professor John Reed Stark, welcome to Crypto Critics' Corner, and it's a pleasure to have you here. Recently, we were just talking off the record about how you had recently done a forum. I don't know exactly how we want to call it, but you were doing a chat with a host of different individuals, including Anthony Scaramucci. Right. And it just seems like there's a lot of loud people right now who are very keen on suggesting that there isn't so much risk, as many people seem to perceive there is in cryptocurrency. But I don't think you feel that way. So can we talk about where you're coming from and why you think it's important to talk about these risks and everything? Sure, Cas. Well, first of all, thanks for having me, guys. I love this Crypto Critics' Corner. To me, this is like The Tonight Show. So I'm peaking right now. All right. I'm not joking. I've been in this mess, and we can all feel like it's a chaotic morass. I tweeted something this morning, and I don't think I've experienced such vitriol since I told my daughter she couldn't go out last Saturday night when she was like 20 below zero. So it's a difficult place to be. It doesn't get you any business to be a skeptic. A crypto skeptic. It doesn't get you really anything. And I've often wondered why the heck I do. It's more like a Larry David kind of thing. I asked my old deputy chief, I don't know how long I can keep this up if for whatever reason, I'm really energized about it. And I can't imagine that lasting forever. And he said, yeah, I can imagine that lasting forever. You were pretty much like this when we work together, when something really ticks me off. And that's what happened. The ICOs, when they came out in 2017, I thought were ridiculous. And I love when people say, well, the Genie is out of the bottle now and you can't stop what's going on. Well, they stopped ICOs. And initially everybody said these things were here to stay. Then afterward, you had Telegram, you had Kik, you had Block One. So these iterations keep coming of things that were just to me as a law professor of 20 years, as I said, 15 years at Georgetown, more than five now at Duke, teaching the law of technology, the juxtaposition of law, technology and business. These things were obviously securities violations. So when you look at, for example, you look at something like BlockFi, where they pay $100 million fine, they stop offering their lending program, which again, I had written was clearly a violation, and they had already been barred, I think, by five different States in doing that. And then they put out a Press release that this was the greatest victory they've ever had since probably their first round of financing. So you can't make this stuff up. If I had the ability to write a screenplay or write a book like Ben Mackenzie and Jacob Silverman, your other guests are doing, that's what I would do. I would stop all this tweeting and LinkedIn posting and article writing. I've probably written about maybe 150 to 200 articles in real publications about this, about different things with technology. I would probably move toward the screenplay because you can't make some of this stuff up, and it's really incredible. And why am I skeptical? Let me count the ways again, this is something with no intrinsic value. Look what the Department of labor just wrote two or three days ago. The Department of labor has this tiny little carve out for 401 KS. So they're essentially the SEC for retirement funds in a 401K. They're very interesting. When I worked at the SEC, I trained the investigators at the Department of labor who were investigating complaints regarding 401 case. And, you know, it's not normally their bail. They're like about workplace safety and everything. So they come out with this guidance that essentially says if you're recommending crypto, your per se, meaning you're presumptively violating your fiduciary duty by doing so. In the world of finance back in 1929, after the crash, somebody sat around and said, we don't want to have another crash. So we're going to regulate, like the way we regulate medicine. We're going to regulate finance, and it's going to be different. There's going to be really rigorous onerous regulation. There's going to be inspections, examinations, record keeping, all sorts of oversight, because the externalities meaning, the things that can really impact us by bad actors in this place could really cause the downfall of everyone. So that's why they put this legal framework together. So you look at all that's going on in the area of crypto. Initially, when it came out, I kind of thought, okay, you want to invest in something ridiculous and absurd that I can't even understand in any way, shape or form? Go ahead, have at it. Have fun. I'm not at the SEC. Anymore. I don't have to protect you anymore. Caveat emptor. But then as you start to get into it, because I do a lot of ransomware consulting, most of my work is cyber related. You realize how devastating crypto is and how awful these externalities are. People can die because of crypto. People can die because of ransomware, because of terrorism, because of sex trafficking, because of drug dealing. All of these dire externalities that cryptocurrency facilitates, including evading sanctions that's again, picked up when the supply chain attack happened. And everybody in States like North Carolina suddenly couldn't get gasoline. And there were lines like there were in the 70s, which I remember trying to get gas. Suddenly people realize ransomware is an issue. How do we stop it? And the way to stop it is the thing that gave it its lifeblood. The killer app for ransomware, which is Bitcoin. And that's how they collect it. And you'll hear people say, Well, Gee, Bitcoin is traceable. That's again, one of the most absurd things anyone has ever said. Look at any law enforcement agency and what they say about it. Yes, occasionally they do catch people. But when you really dig into the indictments and dig into the charging papers and affidavits relating to these arrests, you realize, like the last ransomware arrests took 25 different federal agencies to do. Or you look at the supply chain attack when they got somebody six years to take care to finally get the person and secure the money. And a lot of luck. Same with Bitfinex, with Razzlekhan. However long that took for them to catch her. What was that? Six years. Six years. Yeah, that was six years. Right. And that's a good one to explain because that person happens to reside in New York. That's a big plus, by the way. That's like going on vacation in London and saying, it's nice they speak English here. It's a big plus when they're here in the US, because if they're outside the US and I have a lot of experience prosecuting and investigating outside the US, it is so challenging just to talk to a witness requires a witness who's a victim requires regulatory interaction with whatever authority in that country through a treaty, a memorandum of understanding, or some informal arrangement you might have. One thing that was striking for me in preparing for this episode was some of the similarities between cases that the SEC's Office of Internet Enforcement pursued and things we've seen in the cryptocurrency industry. We can talk about the outright Ponzi schemes, which are, of course, common in cryptocurrency, but some of the more interesting ones was like there was a couple of different related cases brought against several entities for releasing unregistered securities. And the one that I was reading about in preparation for this that was especially interesting was one in which the lawyer in specific ended up getting tagged by the SEC because their role had been to basically try to write a letter that said these things that look like securities are not securities. And it was very striking to me because during the ICO boom, which you already mentioned, we saw tons of these major law firms go out and write very similar sounding letters for the utility tokens or claimed utility tokens that were being released in the ICO. Do you see any similarities between those kind of things and what was going on there? Well, I do. And the way you bring it up, because I forgot about that lawyer. He had written like 25 opinion letters for 25 different offerings or something like that. And that's the thing about catching these people. A lot of it is in plain view when you're dealing with securities crimes. So I see huge similarities. But I think it's a lot worse nowadays because typically the lawyers that were involved in those kinds of microcap schemes and Penny stock frauds and fake offerings were usually pretty clearly shyster lawyers, meaning that they may have even been disbarred before. They're operating very much in the worst areas of securities regulation and in an area rife with fraud and seem like they're fraud honest and they're in on it today. If you look at Telegram or KIK or the case with Ripple, you're talking about a lot of the ICOs or the Fafs, you're talking about lawyers from some of the best law firms in the world, some of the most well trained lawyers. Or you look at Coinbase, right? Coinbase decides or TerraForm. I could go on and on. Look at Coinbase, the lawyer in Coinbase, when the SEC issues a Wells submission, right? What's a Wells submission? Well, that's when the SEC staff has decided after a full investigation of working with everybody that they've got a case against you and they're going to recommend the commissioners that the SEC bring an action against you. It's named after this guy, Steven Wells, who was a Commissioner and said, hey, the defendant, who's our potential defendant, should have a chance to have a say in whatever proceeding we begin this enforcement action with, which is typically a closed Commission meeting. It's in secret. The staff presents the commissioners and say, hey, these are some bad people. Here's what we think you should do. And the commissioners either vote to do that or vote not to do that. And that's typically a secret process. Wells said, hey, you got to open it up. Let's present this Wells notice to people, and they can write a brief. They can submit a video, do what they wanted. So Coinbase has a program called Lend that is similar to BlockFi's and Celsius' program, which have both been charged and thrown out of different States. By the way, when has it ever been legal to do an offering in one state and not legal in the other? I've never seen that in history. This isn't like cannabis or helmet laws. This is different. Okay, so back to the Wells. They give the Wells notice to Coinbase. Any defense lawyer on the planet will tell you when you get the Wells notice. Not good news, okay? And you're likely to get sued. It's going to be tough to convince the staff they've got their Ducks in a row. When I would give Wells notices, I would open up the jacket of all the evidence that I had and say, here it is no time limit. Tell me why I shouldn't sue you. I don't want to waste my time suing someone who's innocent. This is America. I don't want to sue anybody who's innocent. You got to convince me overwhelmingly. Anyway. They do that Coinbase, what does Coinbase do? They issue a public statement saying the SEC are a bunch of idiots. We disagree. They're antiquated, they're stupid. The GC puts up a blog again, you can't make this stuff up. And I don't know who's advising them to do this. So eventually the SEC wins that, of course. And then Coinbase stops. But go ahead. I was just going to say that I don't know who is advising them of this, but then I think about who the GC is for Coinbase. And it's like a previous district court level judge. This is not someone who's an idiot when it comes to law. And so you go, why in God's name would you respond in that way? Look at TerraForm. Right? So this guy, Do Kwon is at a conference in New York. His GC lives in New York. They're doing deals with big American organizations, like professional sports organizations, and they assert, you don't have jurisdiction over me. You can't serve me. And they assured that because you used a process server, which I used a bazillion times when I was an enforcement lawyer. You can't use a process to serve me. It's ineffective process and you're violating your own rules. And then they lose before the judge and they appeal it. Telegram is probably my favorite because that case is a $2 billion offering. Their lawyers are very sophisticated. They say, go ahead, do your $2 billion staff. We don't believe it violates the securities laws. The SEC steps in with an emergency action that doesn't allege fraud. An emergency action is a huge deal. You go to a judge ex parte, meaning without telling the defendant, and you say, we are very likely to succeed on the merits here. There are terrible things that are going to have to investors. You need to give us relief right now. Freeze everything, have a hearing in ten days, and have expedited discovery of testimony and documents and everything. I've done dozens of TROS, okay? There's always a terrible, terrible fraud involved in them. And you get in front of the judge and you say, you have affidavits from victims and you say, if we don't do this now, all this money is going to disappear. Well, did Telegram have that? No, no fraud. The SEC just said this is an unregistered offering, and clearly it's an unregistered offering. Let's freeze it. So imagine the lawyers there calling their client. Yeah, Hi. Client. Right there's. This freeze that the SEC had. They've never done anything like this before on the planet in history. Apparently, they believe there's been some sort of securities violation. Let me get back to you again. If I wrote that in a fictional novel, my former SEC colleagues would say that would never, ever happen. But you mentioned, John, that it's very difficult to try to prosecute people who aren't in America. And it made me reflect on a couple of different stories. First of all, I constantly am thinking about Paul Le Roux, who I think he was doing his down and dirty business while you were over there at the SEC Internet office. So Paul Le Roux was doing all kinds of crazy things and decided, oh, I'm going to live in Brazil and have a kid. And that way the Americans won't be able to get me. We had Arthur Hayes, Singapore. We had another guy from BitMEX in I think it was Bermuda or Granada or something like that. I know we have Justin Sun in Granada now. So all of these crypto people, a lot of them have gone to other places. But then it seems like a lot of them still end up either getting caught or turning themselves in. And I'm wondering why or how. I think it's a huge challenge, first of all. But you have one thing that President Biden has done that I really admire is just how many amazing people he's put in the Department of justice. And typically, I can be a big FBI critic, and I taught at the FBI Academy. I can be a big SEC critic as well. But in this case, you really have some amazing superstars there. And they're getting more and more people involved. They have the computer crimes and intellectual property section. They have the terrorist section. They have national security. They have all these different sections now working together also with the US Attorney's office around the country. Plus they have the legal attaches in the various countries, and they really are making incredible strides. I think when these really notorious people become famous and hit the headlines, it's easier to get them because there is just more of a spirit of cooperation. And that's what law enforcement does. They chase headlines. You want to make headlines because headlines give you the deterrence that you need. So that's happening a little. But the ones that you don't hear about are the ones that are a real problem, and they, unfortunately, are the vast majority. You mentioned TerraForm Labs, which has been such an exciting case to spectate from the beginning. When dough was served, it was at Ryan Selkis conference. And Ryan Selkis immediately went on Twitter, complained at the SEC that this person had been served at his conference, and then announced his intentions to run for Senate all in one tweet. It was really quite incredible. And during this, the TerraForm Labs has been ignoring the SEC's investigative subpoenas to the point where the SEC ended up needing to issue what I believe is called like an SEC subpoena enforcement action to try to force TerraForm Labs to actually provide the documents they were supposed to. I was reading something on the Duke Lofty blog this morning that excerpted from some of your writing from December where you predicted that TerraForm Labs would lose this and would end up needing to hand over the documents. So I really have two questions here that I think are interrelated. One is, how do you see the TerraForm Labs case at this point in time? And then the second one is related to the fact that recently the SEC has been apparently at least the rumors I keep hearing from people in DeFi is sending out letters to a whole bunch of companies and protocols in the decentralized finance space asking them for information. Today, Representative Tom Emmer, the Republican representative for Minnesota's 6th District, published a letter to the SEC asking them to explain their information requests and suggesting that the crypto companies that have talked to him have said that the requests are burdensome, they don't feel voluntary. And Representative Tom Emmer suggested that the SEC may be violating the Paperwork Reduction Act. Do you have any thoughts on both the specific requests of the SEC towards TerraForm Labs and the SEC's actions more broadly in the recent months? Of course I do. First of all, there's an old case called Wheeling Pittsburgh, which we used to always cite when anybody from Congress emailed anything about any investigation. And what it says is because of the SEC's independence, Congress can't be perceived as influencing an investigation. So as far as that letter, period, end of story. Done and done. Her, if you're on the Oversight Committee, sometimes you will get a little extra view into what's going on. And it's sad the partisanship, because when I first started criticizing crypto, I used to always say how remarkable the lack of partisanship was and how unified everyone. I mean, Donald Trump, Hillary Clinton, and Elizabeth Warren all agreed that crypto was a scourge, so it wasn't an issue that was polarizing. Now you have the progressive left saying that this is a matter of financial inclusion, which is a huge misrepresentation and sad exploitation. And then you have the extreme right saying, don't let them take away your Bitcoin. It because the Liberals want to keep the tabs on you, and Bitcoin doesn't allow them to do that. So it's incredibly fractured. I mean, I'm not enough of a political expert to really understand that dynamic and what its implications are, but when I use the term chaotic morass, you can also apply that to Congress. So somebody writes to the SEC and said, you better stop doing this or block whatever. It doesn't matter. Wheeling Pittsburgh was a case that they just rely on. And I'm sure that Congressman already got their Wheeling Pittsburgh response back. So that's number one, in answer to your second question, your first question is a great question, Bennett, because it's about subpoena enforcement, which is something the SEC has rarely done in its history. Why would they rarely do subpoena enforcement? You would think it would be something that would be done routinely. I'll tell you what, first of all, SEC subpoenas are not self enforcing. So the only way you can't file some sort of a motion to quash an SEC subpoena, there's no actual judicial proceeding. It's just an investigation. The threshold for an investigation is something like the standards, like official curiosity. So it's a very vague and open ended standard. So if I wake up one morning and I watch a broadcast of yours and I think there's some shenanigans on, I can open a matter under informal investigation very quickly. I can get subpoena authority even quicker. So that's a very easy thing to get. And that comes up in what's called a formal order of investigation. Now, normally, nobody ever opposes an SEC subpoena, because what happens is they file that subpoena enforcement action, which now contains all the secret information. I mean, the response of the SEC is going to contain all the secret information of their findings. Prior to that, the SEC wouldn't even confirm the existence of an investigation involving a company like TerraForm. So you wouldn't even be able to say that it was absolutely for sure happening unless you had a source from one of the defense Council. So it's just never done. Why would you want to give the SEC cart Blanche to say whatever they wanted in their papers and make whatever conclusions they found and they haven't finished their investigation? So that's what the SEC did. If you look carefully at those papers and study them, they're giant. They're a huge affidavits in there from the staff attorneys involved saying, here's what I found. Here's what I'm investing in. Here's the problem. So now, number one, all of this information is public, which can't be good for your shareholders, your board, your other constituents, like your partners, your investors. No one ever does that. So subpoena enforcement actions are. So there are also ways to delay things. A good defense can sort of delay the staff or narrow over broad subpoenas, but generally, you're going to have to answer sooner or later. The other thing is and this, Ben, not to be so long winded about this, but what do you think happens human nature? What do you think happens to staff attorneys when you tell them, no, you refuse to cooperate. No one at the SEC, even the person who doesn't support your investigation, is going to say, don't lean in. You're only human. You're not going to say, oh, God, these guys don't want to cooperate. Well, I joined the SEC enforcement division, but not for this kind of conflict, I think I'll move on and close the investigation. They lean in, and that's what they do. And then the judge, they keep saying they're not going to respond. And the Telegram, they did the same thing. They said something. The SEC wanted a list of all the investor names in Telegram. And their lawyers wrote these giant briefs about why the SEC wasn't entitled to that information. And I'm looking at these briefs, I'm going, what are they talking about? The most basic essential information during an investigation are the names of the investors. So you can call them and say, what were you told about this investment? Yet the lawyers are arguing that that's crazy. The lawyers in KIK (ed. actually Ripple) subpoenaed. And this is the former chairman of the SEC, former director of enforcement. They subpoenaed the SEC. And I think they wanted to know something along the lines of every single staff attorney who owns crypto wanted the names and their holdings something along those lines. The judge said, no, but that was disgraceful. I mean, that's just not something that there is any rational basis for. That should be just because somebody owns crypto that's somehow relevant. I mean, this is the kind of defense law that you see, like on Law and Order, from Shysters, not from legitimate lawyers who worry about their reputations and trust and so forth. So that's a long winded answer to both your questions. But I do feel like TerraForm is a really good metaphorical, sort of showing. People say, hey, it's easy to trace crypto, easy to do this, easy to do that. The SEC can't even serve subpoenas on this guy, and he's in New York without a billion dollar fight. Man, this feels like a perfect segue because let's be real here. Bennett and I have published an episode of this podcast titled Fuck the SEC. All my friends hate the SEC. The title is very intense there because the reality is that we come from a place of understanding that the SEC is certainly caught between what appears to be a rock and a hard place, and that they're not allowed to squash innovation, whatever innovation is, and everyone is livid when Madoff continues for 30 years. Right. So it's like you have to find some weird balance between those two. I'm wondering if you're feeling better about the direction of the SEC right now. It sounds like you are just based on what you've said about the current enforcement regime and who Biden is placing at the helm and stuff like that. But I'd love to hear what you think the future holds for the SEC, maybe how it can get better at what it's supposed to do. Just kind of your predictions for it. Sure. Well, first of all, I think the last time Cornerstone did a report this year, and I think they said the SEC was 94, because these cases are like shooting fish in a barrel. Okay. The SEC hasn't lost a single one of them on any matter. Occasionally, maybe there's a motion where they don't get everything they want, like the recent ripple motion kept the defense of fair notice alive. And the SEC wanted to quash the defense before there was even any consideration of it, which I'm not surprised they lost that, but I don't have any faith in that defense in any way. So occasionally maybe they're a little skirmishes, which of course, the industry will say are huge victories. But generally the SEC is winning all these cases. They're doing an incredible job. And the way the empirical evidence behind that is read some of these papers. As a lawyer, as a law Professor, I can be very critical of any of the charging documents, the complaints, the briefs supporting the complaints, the motions. And when you read them and you sit down and I catalogue most of them on my website for different cases. And in the articles that I write, I try to bring them all up so that you can see them. The writing is unbelievable. The lawyers are unbelievable. And again, there's an SEC insider trading case going on, and I've written a very critical article about that. And I wrote an op Ed piece in the Wall Street Journal criticizing the SEC's view with respect to email. They wanted to see the content of people's emails from third party providers. And I said that was absolutely nothing that a civil agency should ever be allowed to get. So I can be very, very critical. But in this instance, I'm very happy that Chairman Gensler recently said, I think he got the memo. I think what happened with this Ukraine event, the war in Ukraine, is suddenly people got very frightened that Russia was going to be able to evade sanctions with cryptocurrency. And I think that's a real concern. I've written about that. And I think the President looked down at his various agencies. This is prior to the executive order, the recent executive order on crypto, and said, look, everybody better be doing something to stop this nonsense. So, right. I think the next day after that happened, Gentler was in an interview on Yahoo TV or something. And he said, oh, by the way, when it comes to cryptocurrency exchanges, if they're not registered, they're operating outside of the law. That was a nuclear bomb. I'd written some articles about this because, again, it's like a driver's Ed film. Remember when you were little and you watched the driver's Ed films and they had every conceivable, there'd be someone crossing the street. The light would be changing, the rain would be coming, someone would be tailgating you, the baby would be grabbing the steering wheel. All kinds of things will be happening at one time. That's what happens when you look into these things. It's got every conceivable security violation going on, at least arguably on its face. So when you look into these places, it seemed to me they were exchanges or they were broker dealers. So denser just suddenly said, by the way, anybody doing this should be registered. And he had never really said that before. Now, going to your point, though, I think it's important. When I was the chief of the Office of Internet Enforcement, if you read my articles back then, you'll always see me talk about how amazing the technology is and our job is just to stop, to take the bad guys out so it can thrive. And it was very easy to do because first of all, as I said, it was shooting fish in a barrel, for instance, investment newsletters. There were all these fraudulent investment newsletters that were essentially paid to tout stocks. And they were everywhere when the Internet first started. And everyone said, you're never going to stop these. Well, we did like three sweeps where we charged them all with violations of Section 17 B in the securities act, which is very simple. It just says you can't promote a security. If you're being paid to promote a security, you have to disclose the nature, source, and amount of that compensation. No rules under it just a pure, simple statute. We put strict liability. Doesn't matter what your defense is, it doesn't matter what your lawyers told you. It doesn't matter what you had for breakfast that morning. You violated it. We brought a ton of these cases. All we had to say is promoted. Did you promote this security? Which they did because it's on their website with their name. Did you get paid? Yes. Boom. You violated and those violations were all gone. Cas, you're going to say something? Well, what you're talking about right now, instantly my brain is like I'm going through a traumatic, like, PTSD moment, seeing like, all of the people on Twitter doing essentially paid advertisements and not announcing it. They're doing newsletters that are financial advice on substance. They're doing all of the things that you're talking about right now. Right. So you know what? The SEC is going to dust off 17 (b). They already dusted off 17 (b). They sued Floyd the money man, Mayweather, Steven Segal. There's at least half a dozen other celebrities. I wrote articles about all of them again. Or DJ Khaled. It's shooting fish in a barrel. Did you receive compensation? Yeah, I did. Did you promote this on this tweet in your account? Yeah, I did. Okay, here's your Wells. Thank you. I don't have to do much investigation. There's so much more I need to know. So most of these statutes are pretty clear to me, at least. And that's why I look at this executive order, which everybody on the crypto industry, they have this marvelous way of saying, this is amazing news. The example of BlockFi. We just paid $100 million, which is one of the largest finds in SEC history. Boy, what a victory. We just had to stop everything we were doing dead in its track. Boy, this is the perfect outcome. Exactly what we wanted. You know, it's like the guy remember Tom Hanks in the movie Big? I don't get it. I don't get it. That's what I'm raising my hand. I get the PTSD every morning. I get days shabu all over again. Whatever the cliche is, it's all the same. It's all get rich, quick schemes. It's all doing this to vulnerable people. It's like the embroidery has no clothes. Because you tell people if you aren't investing this, even this morning, when I tweeted, they always say to me, you got to do the research, John. You haven't done the research. I put this website together. It's not sponsored by anyone. I don't make any money. I make no money off of any of this. Nobody's paying me to be a crypto skeptic. If I just joined one of these crypto, they'd love to have me for window dressing, trust me. I mean, maybe it might be too late now, but I still get offers, but I'm not going to join you. Lie down with dogs, you wake up with fleas. Judge PorkIN used to tell me that. I think he was quoting Shakespeare. So in looking at all of these entities operating, you just sort of have to say, okay, it looks like violations to me. Gentler. Seems he's doing something. The executive order comes out. Everybody says, this is great news to me. Look at the Infrastructure Act regulation about form 1099, right? The infrastructure, this little regulation that said, any cryptocurrency exchange has to send 1099. Those forms that talk about whatever your investment holdings are to the IRS. So the IRS will now know anytime after January 2023, anytime you trade and profit or get losses in crypto. That's number one. Look at the SEC regulation ATS where they define cryptocurrency exchanges. Look at FinCen. FinCen has a rule right now, a terrorism rule that says if you have a $10,000 cash account outside of the US, you've got to report that. If you fail to report that, you can go to jail for up to five years. This is serious stuff. So FinCen is going to propose a rule that says if you've got more than $10,000 in crypto, you've got to report that. So all this is happening. And then you look at the Department of Labor guidance, which essentially says anybody advising a 401K participant to invest in crypto is breaching their fiduciary duty per second presumptively doing that. That's what the regulation is. I doubt the industry is in favor of any of that. But what do you think is going to happen when the Department of labor or the SEC write their reports in response to the executive order? They're going to say, okay, here are the ten things you have to do. Look at the Sky Bridge rejection letter for the Bitcoin ETF. The SEC lays out, like 15 reasons, 15 reasons as to why they can't. Ok, this Bitcoin ETF. And until those reasons are met by somebody, that same language is going to become boilerplate for all the rejection, for all the registrations of all these entities, because they have to solve those issues of transparency, cybersecurity wash trading, market manipulation, insider trading. They just don't have any visibility into this marketplace. Who knows what's going on? Yeah. And some of the language on those ETF rejections has basically become boilerplate, at least since I first started looking at them in 2018. It's been the same marks about market transparency and market manipulation and just lack of visibility for four years now. And we get a few new applications each year and a few additional rejections on the pile, and the cycle continues. One of the things that was perhaps most striking to me when I was preparing for this episode was looking at the variety of ways the Office of Internet Enforcement was able to bring cases and kind of in line with what we're talking about against a lot of behavior that people seem to again believe is acceptable. And so we talked about, like, the stock promoting newsletters and stuff like that. There was also a case that the Office of Internet Enforcement brought against a bunch of pink sheets that were advertising through Spam and YouTube to try to get people to buy into the pink sheets, which we clearly see all the time in crypto with the YouTube shillers who go out and do that. And even, like, the Vicemail stock manipulation scheme where they were calling a bunch of random numbers and pretending it was a wrong number and they were accidentally giving out a hot stock tip there's. One thing we've started to see in crypto is certain projects use leaks from old databases, like the old Mount GOx emails, the Ledger emails that leaked, even the BTC-e emails that leaked from all these cryptocurrency exchanges and companies that got hacked. And they then use those for targeting. They get added to, like, the mailing list for any new scammy type project that launches because they've got this whole list now of cryptocurrency investors who they see as potential marks upper list, they call. Yeah. We talked about the lawyer who was writing these letters that were saying these things weren't securities. There's all the pump and dump groups where you have people cooperating together to try to pump these microcap stocks. And we see the same things in cryptocurrencies. And even, like, the Prime Bank fraud cases where you had these individuals guaranteeing returns on these highly complex or they were advertising what they claimed with these highly complex instruments with these guaranteed returns and stuff. And it was just really fascinating to me to see such a wide variety of cases brought under so many statues, because at least from what I've seen so far, much of the cryptocurrency enforcement so far has focused on, like, a couple of unregistered security cases and then, like, a couple of unlawful promoter cases. And I haven't seen much else beyond that. And this just seems like it was a much broader tech taken at that point in the Internet office than we've seen so far in crypto. Yeah, you bring up the Prime Bank cases. That's always one of the best examples. So these are bogus instruments that purport to represent the secondary market in standby letters of credit. And you had true believers at every end of those selling those. And they were all over the place. One time there was a municipality that was within driving distance of my office. And on the phone, you can't really say when you're at the SEC, you can't say they have violated the law. You shouldn't invest because you can't draw those kinds of conclusions. And you're not even supposed to comment on the nature or even the existence of an investigation. So my assistant director with that one, she just said, Get in your car today and drive for whatever 5 hours and go meet with this municipal board. And at the time, there was no Internet. So I brought a bunch of our warnings on Prime Bank fraud and just don't let them invest in this. This is money that they're setting aside. So I did that. And it took that much effort for them to actually see me and ask questions. And I couldn't speak specifically as to their offering, but just to warn them, go find a good lawyer to look at this before you invest this 5 million. Now, the Chicago Housing Authority actually invested, I think, four or 5 million in Prime Bank notes. And these were fake frauds that emanated from overseas. And they got duped. And when it went to court, this is what you love, Bennett, because it's very similar to what a cryptocurrency defendant would say. They went to court and they said, you can't be here because Prime Banknotes are not securities. They're fictional. So the judge said, very Interestingly. It doesn't even matter if they're fictional. If they were real, what they are purported to be would be a security. And so everybody said these are outside of the SEC's jurisdiction, their banking instruments. And that's what the security flaws were written. This is the irony of all these defenses saying we need more particularity. Well, insider trading. There's no real statute about that. That's all. Judge made unlawful insider trading, offering frauds. I did cases. Ostrich Farms, eel farms. You mentioned Prime Bank fraud. It didn't matter what it was. You're giving your money. Someone else is taking it. They're promising you some returns because of some stuff they're going to do. It's not complicated. And it was written to be very broad. And if you read the Supreme Court interpretation and the legislative history, it says this statute is intended to cover securities and investments and products that are not contemplated that we don't know about at this time because we understand that criminals can be clever and ingenious and create different things. So the jurisdiction, then it's always there, and it's just a matter of pushing it. And sometimes you may, like multilevel marketing schemes were a good example where I think the SEC got a little gun shy and said, this is the FTC's thing. These aren't necessarily securities. You see it a little bit with NFT. You don't see the SEC saying a lot about non fungible tokens. They might, though, because they bear a strong resemblance to securities, but they just might sort of say, let's get all this other let's get the low hanging fruit today, and then we'll hit the other stuff later. And what's happening, though, again, you have these real money laundering dangers, this idea of decentralization, and the idea of libertarian idea of being free from oversight. Those two things are both completely ludicrous. First of all, it's not decentralized, right? You have a wallet, a minor, an exchange. You might have a fund owning it. Second of all, these things are obviously a money laundering threat. And we have the USA Patriot Act, the Bank Secrecy Act. All of these laws tell you that you have no Privacy rights to your financial dealings. If the US Attorney's office or a state prosecutor gets a search warrant or a grand jury subpoena, they can look at that information. The SEC looks at it. Under the Financial Rights to Privacy Act, you might get notice, but in those other instances, you won't even get noticed. If you go in and withdraw more than $10,000 from your bank account, the teller is going to automatically file a suspicious activity report. And you know what? If you try to evade that with 9999, you're going to get caught. More likely, I caught a guy who did that at four banks in a row, $9,999. So the red flags were big and easy to see. A lot of people withdraw more than 10,000 in a day. So you might roll the dice and not get caught there. But not a lot of people withdraw 9990. Let's say, watch that episode of The Sopranos where Camilla Soprano walked around to different banks withdrawing that money. So you don't have a right to financial Privacy from the government because we worry about terrorism. You don't have any decentralized right to crypto because there are all these parties who are taking big fees from you along the way, and they're unregulated. So who knows what sort of risks there are? If you look at the risk disclosure for any of these Bitcoin funds, it's volumes. If the fund has a perspective that's 100 pages, 75 pages are going to be risk and the risk is going to be unbelievable. It's going to say things like, we don't know what we're doing. We've never done this before. We may completely lose your money. That's the kind of risk disclosure you will find. And yet people, for whatever reason, still want to invest. I think withdrawing at $9,999 is probably the single fastest way to get a SAR filed. Yeah, I was in preparing for this found an old document on the SEC's website that was last modified in 2009. So during the year when Prime Bank fraud was really happening, describing some of the warning signs that people should be aware of when they get pitched. Investment opportunities. And Cas, I think you'll really like these warning signs when you hear them. Excessive guaranteed returns, fictitious financial instrument, extreme secrecy, exclusive opportunity, and claims of inordinate complexity, which is just in general, a great set of warning signs for high yield investment programs and scams in general. But that specific set describes a lot of crypto projects. And so when I was reading it, it made me chuckle a bit. You're giving CAS PTSD again. I do think it's interesting, though, to me, because on one hand, and we were talking this episode will be coming out later today, but we were talking to Francine McKenna and she made a good point in that I think there's like a certain we've reached this weird, we're reaching this point of no return almost, where, as she said, people don't care about audited financials anymore. They just don't even care at all. Theranos could just continue going without getting audited financials for a decade because no one asked for them. And I think when I hear Bennett say those warnings and I think, well, yes, that's every crypto project, but also that's probably a ton of that's, probably like Uber and Lyft and other real businesses in the real world, and it just becomes hard to delineate anymore. Yeah, I think you make such a great point. And I've heard this a couple of times recently. Kelsey Hightower sort of said the same thing to me. That the gamification that I'm told, they always say, hey, Boomer, every time I write anything and they are spot on, okay? Because I don't invest that way. I do my homework. Like Arthur Levitt, the chairman I worked for seven or eight different chairman. Arthur Levitt was one of them. And he used to go around in these town meetings, which is what Gensler should do right now. He would go to every city in these town meetings and he's remarkable. Everyone would show up and he'd be with the local congressmen, local leaders, local journalists, and just say, ask me anything. And people would say things like, should I invest in crypto? Or in that case, back then, why shouldn't I invest in microcap stocks? Why don't I just bet on this spam that I got? Why don't I just bet on it? I mean, yeah, it's a total scam, it's a total fraud, but I think people are stupid. So I'm going to buy into it and I'll get out soon enough that I'll make some money. He's still alive. I think it's like 94, 93 or 94. He was so great at this. He would just say, that's not how you invest. You invest for the long term. I had heart surgery in my life, and I remember choosing the doctor. That's a huge deal, okay? Especially when you've got kids now. You should make the same sort of due diligence when you make an investment, because this is your life, your retirement. I mean, unless you're taking and saying, hey, this is 5% of my money, I literally do not care what's going to happen, okay? I'm taking it to Vegas. Even Vegas, though, is a bad analogy, because when you take it into the casino, there's oversight of that casino. And, you know, the deck's not stacked. You know, the dice are not loaded. And you have some idea that if they don't pay you, you can have some sort of redress. None of those things are possible with crypto. But the bottom line is you should invest for the long term. And I think Kelsey's, like his generation, they don't want to hear that. The Gamification, the memes, they just say, I can make a lot of money by doing this. Why don't I just do it? And I think that's a legitimate concern because maybe I just can't relate to people anymore like that. I can relate to my children. I can tell them, this is not how you invest, but good luck. I can't really tell them anything. So investment, that's a hard one to get them to listen to me, but I can teach them. But maybe that's all falling on deaf ears, because people need to get shocked. They need to lose all their money in order to face that kind of reality. Because when you spent almost 20 years at the SEC like I did, I talk to victims of Prime Bank fraud. And let me tell you this. There's no standard profile. You'll find sophisticated victims, you'll find unsophisticated educated, uneducated. And it's just awful. I was on Dr. Phil talking about this. And after I was done, the emails, because I'm pretty easy to find. Right? You can just search by name. You'll find my website, you can send me an email. The emails, the phone calls poured in from people who had lost money on Bitcoin related or crypto related scams. And they keep coming in. And a lot of times I was telling one of my colleagues, Bruce Carton, this this morning, Sean. Bruce, I was like, I get these complaints. I've not even heard of these exchanges. I've not even heard of these products. And I'm knee deep in it. And there's so much going on on Reddit and all these places that I don't visit very often where a lot of these advice and my son is always showing me these ticktock, crazy people offering investment advice, and he's saying, like, we should get into this. We should start a TikTok investor thing. My preaching would be like Arthur Levitt, and it's what's kept me and my family prosperous and safe. And, yeah, I don't make any crazy returns, but I'm happy and I got a nice place to live and I got a future for my kids when I'm gone, which hopefully won't be soon. So those are the kinds of things that I look at and maybe the hey Boomer is totally accurate and maybe the train has left the station with respect to these people because this is how they look at investing. And I don't think I can change their mind. Some almost 60 year old guy, former regulator, former prosecutor and law professor. I don't think I have the stuff to really change your mind. I did put this website digitaltrustwatch.com and again, I think I mentioned it before. I'm not promoting it. It's just we're at a warehouse for things that you can read and video and audio podcasts. I put you guys up there to follow you guys watch your stuff. Am I speaking in a different language? I'm speaking common sense here. Call me crazy. I've been in space for a long time. Well, I think even Bennett, who's a baby compared to you, and I think he gets Hay Boomer because of his financial perspectives, which Ben and I are not risk on. And I don't think there's anything wrong with taking some risk. If you want to play the lottery, go play the lottery. If you want to go gamble, go gamble. I'm fine with it. It's fine. It doesn't bother me. If that's something you want to do, that's okay with me. I think calling the issue that we're all having here is calling it an investment, right? Oh, absolutely. And the externalities right. That's what everyone loves to talk about. It ransomware, extortion, sex trafficking, drug dealing. This isn't just a laundry list of boilerplate that I spit out. These are real things that the DOJ, the US Treasury, the GAO have all said, look at these ATM machines, okay? There are these crypto ATM machines. The government doesn't even know where they are. The Gao put out a report in October saying these were a real threat for money laundering. When I was on, Dr. Phil, the owner of one of the machines, stood up and said, yeah, the reason we love our machines is because of the anonymity. So UK. It's not surprising that the UK just banned them, but it is surprising that there are more than 32,000 in the US, and there seems to be no concern about that. And guess what? Guess where they're located? In inner cities, mostly in inner cities and in the types of places where you can prey on people who might be vulnerable to these kinds of schemes and the fees associated with them, the mystery associated they're not bank teller machines. There's no one you can call if it takes your money and gives you nothing. And there have been reports. Matt Robinson at Bloomberg, like five years ago, four years ago, actually studied one of these things and saw just how extraordinarily nefarious everything about them was, and there's no need for them. We have PayPal, we have cash app, we have Visa, Mastercard. There are a million ways to move money. You don't need any cryptocurrency. It solves no problem that anyone, at least in the US, is having right now in any way, shape or form, does nothing. There's no benefit, and it creates all kinds of tax hurdles and unnecessary risks. And you have no idea if it's not completely manipulated. My recollection was that for, like, the Bitcoin ATMs? I think it was. FinCen issued guidance in 2016 or so saying that they were supposed to be collecting full KYC. But I can imagine that may not have been enforced or universally followed. The GAO is historically the most bipartisan, neutral, objective, non political agency in all of government. So when I read their reports, they're not subject to gossip. They're very methodical. So when they come out and say the government doesn't know where these are, I believe them. I don't think that's hyperbole. And when they say that these are a great way to do money laundering, to commit terrorism, to do drug dealing and all these awful crime, sex trafficking, I believe them. And that was only a few months ago that they wrote this. So I don't understand why other people don't believe them. No, I certainly do believe that. It's more just striking to me that they've continued to proliferate without enforcement or anything like over half a decade since people were aware that they were a problem. And why is the UK banning them? But we're not are our economies and our culture is so different that it should be allowed here, but not in the UK. Is there something I'm missing there? Yeah. And this kind of leads there's two conflicting views. I hear a lot about crypto regulation, especially as it relates to the SEC in the United States. From cryptocurrency companies. I often hear that the SEC has been derelict in not providing new regulations or guidelines to cryptocurrency companies. And from at least a subset of security lawyers and other people, I hear that the issue can more accurately be described as the SEC saying these things look like securities or these things look like whatever and cryptocurrency companies deciding to go forward regardless, despite that guidance. What is your perspective or what nuance can you add to that discussion? Sure. Well, what's interesting is that Chairman Jay Clayton, who was a Republican appointee under Donald Trump, he was like a broken record, okay? He put out investor alerts. There was what was called a 21, a report on the Dow 21, a report that the SCE. Those are very rare. That means they're not suing someone, but they're saying, here's the bad things you did and here's why we think they're bad, but nobody's getting charged here. It's called a report of investigation, which is a very serious document. They put out a 21, a report about these. Chairman Clayton got up before Congress, and he said, Every single ICO I have ever seen is a security period, end of story. That's a direct quote. And then he gave about 19 speeches where he said the same thing. Then if you looked at again, all the written material coming out of the SEC, all the cases they had brought, the notice was Crystal clear. Now it's tough for the SEC to get specific. They never will. If you show them something and you say, hey, is that a violation? They're not going to say, yes, that is, don't do it. They might talk to you and say, well, it raises serious concerns about this and this and this. And you should be smart enough to hear that and say, you know what? I don't think I'm going to do it because those guys are going to sue me. And they're really smart. They're not stupid. Over there. Maybe half of the people who are in the Office of Internet Enforced when I left, they're still there doing incredible things. Bowser Panic was part of the Office of Internet Enforcement. I hired her. She's in charge of the whole crypto lab in Corp Finn in a very high so a lot of people are still doing this stuff and they know what they're doing. So I think the notice, they talk about this fair notice defense. It's absurd to me. Okay. The other thing is, who decides that you get fair notice if the police come by and arrest you for something? You say, I didn't know that drug dealing was a crime in my country. It's not. Or I didn't know that prostitution was a crime in my country. It's not. And in some States, they seem to allow it. That's not going to get you anything. The policy argument is not one that's a defense argument. And it's also been one that judges have rejected over and over and over and over again because the defense, they always say the same thing. The regulations are too broad and they're unconstitutional. That has been completely rejected by every single judge that has looked at it. In fact, they've said they're supposed to be broad so they can't be too broad. And the other thing is, I always say this, be careful what you wish for, because when the Infrastructure Act came out and put that definition into play, or the FCC came out with their definition of communications network that would include cryptocurrency trading platforms, meaning that they would have to register as an alternative trading system. The industry went crazy saying that we don't like this. So all of this regulation, whenever it comes out, they don't like it. I don't think there's a single piece of legislation or law that you will find that big crypto will say, yes, we like that. That's a good one. They love to say, we need clarity. You give them clarity, not so much. They don't like it anymore. Yeah, but they sure do. Like to ask for it. You're right. They sure do love to say that. Like, well, if we could just get a little regulatory clarity, I think all of this would be worked out in a second. And I think that you're right. Be careful what you wish for, because once all of that clarity comes, I think all of them are going to regret asking for it. And they say this is legislation by enforcement. Well, that's like 90% of what the SEC does. I mean, everything. Like I said, insider trading is the best example. Is there a law that says you can't insider trade? No. There's a law that says you can't lie, cheat, and steal in connection with the purchase or sale of the security. And that's where insider trading developed under numerous different theories. So that's clearly should there be a definition of insider trading? Maybe. But guess what? There isn't. And judges have said that that's fine. And apparently Congress thinks it's fine because they haven't changed it. So you want to lobby Congress for more clarity, that's fine. You can do that. And Elizabeth Warren has said she's coming out with some legislation. We'll see. Will the industry like it? I bet they won't, because I don't think they've seen any legislation that the big crypto actually likes. I mean, who does? If you're running your business and you're making a lot of money and some government says they're going to regulate it, of course you're going to say publicly, regulation is good. Regulation is going to make us better. You're going to say that, but do you really want it? Do you really want SEC auditors and examiners coming on site unannounced and showing up at your front door and demanding to see every single customer complaint of the last three months? And if you don't show at them, shutting you down for not maintaining those records, do you really want if the SEC comes in and says, we want to interview every single employee in your company today and you say no, and they say, fine, we'll take your license away. Are you ready for that? That's the way it is. I mean, the fed lives at all of the banks. They literally have people who work in the same office as the bank employees. So is crypto ready for that sort of oversight? I doubt it. The requests for regulatory clarity are really just an excuse to continue being unregulated for the time being. And like I said, it's not a defense in a case. You try to say something is constitutionally over broad. Those are tough defense. Anybody's gone to law school knows that. Those are not easy defenses. They've been tried and failed many times. And even the Howie test and the Reeves test are both judicial standards. Right? They arose out of oh, absolutely. They've stood the test of time. And there's a reason because they make sense. They just sort of say and people talk about vertical and horizontal commonality, and they get into the complexity of how lawyers can make a lot of money. Look, in this industry of crypto, it's very sad that so many lawyers, their view is essentially, let's beg forgiveness rather than ask permission, number one. And then when they ask permission and they're told this raises consideration, they feel they've been cheated. And then you get this, it depends defense, which you're always going to get. Look, if somebody comes to me and I've been practicing in this area forever and says, is this a security? Of course I'm going to say it depends on the following things. But I'm also going to say, yeah, it looks like it is. But you can make a lot of money. There's so much money to be made advising these so called fintech industries. And you wake up in the morning and you say, I'm a fintech lawyer. And you change your bio from whatever lawyer you were before. And you put the word Finn, you do a search and replace and you put the word fintech in there and you're a fintech lawyer. So now you walk around and all of a sudden you have a book of business potential that's ten times bigger than it ever was before. So you want to feed your family. You want to live in a decent house. You're not going to stand up and say, fintech is a scam. You're not going to say web three is a scam. Crypto is a scam. Why would you do that? You are a crazy 60 year old like me. I won't name names, I guess, but we definitely are familiar with someone who put crypto lawyer in their Twitter profile and also never passed the bar exam. So you never know what's going to happen with these folks. But anyway, I think my last question for you is about stable coins. I would just like to hear your position on stable coins. All of them. Tether, USDC, Gemini. Obviously they're different and algorithmic stablecoins, decentralized, stable coins, whatever, die, whatever. I know they're all different, but overall, what's your thought on stablecoins? Do you think some of them are securities, et cetera? It's so tough to say because like you said, they're very complex to me. I didn't work at the Fed, so sometimes I don't have the background. But having said that, I'm just looking for the problem that they solve. I'm just looking for these are just like solutions of some sort, looking for some problem that doesn't exist. So again, it sort of goes back to, I don't understand it at all. I don't understand the reason. I do understand why government still will take the position that, hey, let's look at this. Let's see what it's all about. Nobody wants to be perceived as some sort of Luddite who does it, who hates technology and hates technological advances in finance. I get that there are all kinds of problems with finance that could be better that's sort of whataboutism always drives me crazy. So when it comes to all these stable coins and they've surfaced so quickly, I haven't even written about it yet, because again, it comes up so quickly that I haven't really had the time to say, do my usual, here are ten things wrong with this, but the bottom line for me is much more simplistic, which is Molly White. You had Molly White on, and she gave a guest lecture at Stanford. She's like a national treasure, right? She had her guest lecture. She was like, I don't think it's smart to do these technologies and then say, we'll worry about the problems later on and we'll figure out how to solve them. Her point is that blockchain itself, which again, I'm still looking for an application for it. Again, when I was chief of the Office of Internet Enforcement, I could see the amazing things the Internet did every day. And that gave me a lot of pride in doing what I was doing. I was the biggest promoter of the Internet that you would ever find. And you could look at my writings and you'll find all sorts of promotions. I can't see it with blockchain. I can't see it with stable coin. I can't see the benefit other than this kind of greater full nonsense that, hey, I could invest in this, there'll be a greater fool because there's so much PT Barnum around this stuff that I'll make some money. The rest of it, I just don't see. And when you listen to Molly's lecture, where she talks about the cybersecurity issues, the Privacy issues, the dangerous threat of things in the blockchain, and she sort of says, why should we adapt this technology? This append only glorified spreadsheet when we're really not sure of all these negative potential extra. Now the answer is always like, well, everything has problems. But again, you get into that. What about ism? And you look at social media is Instagram for kids a good idea for children? A good idea. It would be better to hit these issues before we get started than after the train has left the station. So that's what I say the most to that question is, just find me the solution that it's doing. Find me an application that I can at least say, look, it's easier to pick up my groceries or my car is cheaper, or my energy bill is cheaper. And we haven't even talked about the environmental ramifications, these mining facilities that have entered these small towns, exploiting these small towns, eating up all their energy, giving them nothing. I don't like to sound like a bleeding heart, because I'm really not. I'm a real capitalist. I'm a libertarian myself. But I do feel terrible for all the exploitation. And when you get into the similarities, a lot of these frauds that you were researching are what we call affinity frauds. Right. And I remember writing that Prime Bank warning with my friend Dave Jeanfrito, who was a phenomenal writer, and we just were looking at the offering documents and picking out the things that they said. It wasn't genius writing, but people tie into an affinity. And this latest one about inclusion is the one that drives me the most crazy that this is going to solve financial inclusion. This is going to prevent the next financial crisis. I agree. Financial crisis was terrible. I agree financial inclusion is a huge problem, but I fail to see the Nexus of these solutions. But I'm perfectly willing to talk about the real applications of this. But I do think it should be simple for me to see, just like it was back in the early 90s when I started doing this, that it should be simple for me to see, wow, this technology is going to do amazing things. So Where's Microsoft? Where's Apple? Where's Amazon? Where are all these technological behemoths who ran into cloud computing because it was such an incredible solution? Where are they when it comes to blockchain? Why are they not producing fantastic devices to make our life better with blockchain? There's got to be some reason. I think you bring up a lot of great points, John, and what an absolute pleasure to have you on. I look forward to bringing you back sometime soon if we can get into more of the bullshit that you've seen. Yeah. All I can do is say thank you. This has been very informative and great. I mean, all I can do is thank you guys because you guys allow people like me to have a voice, and it's courageous stuff. It's not fun. It is fun, actually, but it's not easy, and it's a little scary sometimes. Why are we in this space where everybody hates us and it's not easy to be in that, and I don't know how long I can last, honestly. I'm sure you guys ask yourselves the same questions. Why not just go out and promote something fun and easy? That's good, like better education for kids or better safety for kids or pick an issue like that and everybody loves when I saw what you were doing, I was really excited to be a part of it. And I mean this for me, like I said, it's like The Tonight Show. It's bigger to me than Dr. Phil or CNBC or anything to give me a full hour to talk about this stuff where you guys have and the research that you guys do. There's a lot of media capture, and you guys are fighting that. It's really an honor, and I mean that from the bottom of my heart. It's an honor to be with you guys. I hope you keep it going. I love watching the different people that you bring in. You bring to life some of these figures that I follow and read. And that's always really fun, too. For me, that community is really a good family to be in. Even though we're small, we're proud and we're trying to stick to our guns as best we can. Thank you very much. That means a lot. And it was wonderful to have you on here today. You did it again a few days ago we broke the record for longest episode of Crypto Critics' Corner. Did it again today and you got all the way through it. I feel like it's similar to that Chinese curse or saying may you lead an interesting life. That was an hour of your time and you're still listening to me. Talk to you. Leave a review. Leave a rating. Come on, man. This is ridiculous. It's absurd. Come on, let's go.