High Noon at Ooki Corral: CFTC Sues DAO Participants – Crypto Critics' Corner
Today Cas Piancey and Bennett Tomlin discuss the CFTC lawsuit against Ooki DAO, and what it means for the cryptocurrency ecosystem.
This episode was recorded on September 28th, 2022.
Other episodes mentioned in this episode:
- Episode 17 – From Skeptic to Believer: Preston Byrne on the cryptocurrency ecosystem
- Episode 92 – Journshillism (feat. Nikhilesh De)
Other resources mentioned in this episode:
- Coverage of Ooki Lawsuit
- Order settling with BZeroX LLC, Kistner, and Bean
- Complaint against Ooki DAO
- How to sue a DAO
- CFTC chatbot service
- Gabe Shapiro’s tweet about default judgement
- Summer Mersinger’s dissent
Where to find Crypto Critics’ Corner:
- Bennett’s Twitter
- Cas’ Twitter
- Bennett’s Newsletter
- Cas’ Blog
- Bennett’s Blog
- Bennett’s YouTube
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00:00:05:06 - 00:00:11:29 Cas Piancey 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? 00:00:12:06 - 00:00:14:00 Bennett Tomlin I'm doing pretty well. How are you doing, Cas? 00:00:14:14 - 00:00:43:24 Cas Piancey I'm doing fine. I'm doing fine. There's just been a lot going on in terms of the space in general. There's just it's kind of crazy right now. But we're going to start with something that, in a sense, we disagree about a little bit. I think it's, you know, another fart in the wind in terms of cryptocurrency news. But you you are convinced that this is going to set a precedent that will be remembered for a very long time. 00:00:44:08 - 00:01:15:18 Cas Piancey So we're going to talk about Ooki DAO. I don't I don't know if that's the right way to say it. You know, I feel like an idiot regardless. Okay? I don't know. I don't know how you're supposed to say it. It's Ooki DAO, and it has been hit by the CFTC with some pretty incredible claims. Why don't you get into the exact statements that the CFTC has made and what they're trying to suggest it really is? 00:01:16:16 - 00:01:45:15 Bennett Tomlin Sure. I think before that, I'm going to go a little bit over kind of the history of Hokkaido. So we've got a little bit of context here. bZeroX LLC Tom Bean and Kyle Kistner launched the bZeroX Protocol way back in like June of 2018, and this protocol was another cryptocurrency borrowing and lending protocol during that defi mania. And specifically, what bZeroX enabled people to do was merge and trade. 00:01:45:18 - 00:02:20:25 Bennett Tomlin They'd be able to put up their ether as collateral and get basically a token that represented a margin position. In Ethereum, the price went up, you got a larger amount because you had five X exposure, whatever the price went DAOn and you were shorting, you got all that because of the protocol and this is eventually what they got in trouble for is the CFTC thought that these derivative products they were offering could and should only be offered through registered futures exchange, through registered commodities exchanges and through like the appropriate CFTC process. 00:02:21:09 - 00:02:49:10 Bennett Tomlin The reason I think this case is interesting and the reason I think that this will end up being more precedent setting and more important for DAOs in the future is because there's like two separate things they filed. One was the order establishing and then settling charges against bZeroX LLC. Tom Bean and Kyle Kistner basically saying, you know, started this, paid $250,000 in fines, stop doing this and you'll be fine. 00:02:49:11 - 00:03:17:15 Bennett Tomlin Right. But the other thing they filed was a complaint was a lawsuit against Ooki DAO broadly and the members thereof. And they specifically talked about how Ooki, there was this unincorporated association where all the people who participated shared in the liability for the unlawful acts that Ooki DAO participate in, which was offering this margin trading. So Ooki DAO was offering margin trading without KYC through a smart contract. 00:03:18:00 - 00:03:37:08 Bennett Tomlin They pretended to be decentralized to be enforcement proof if you listen to their executives before the transition to the DAO. But what ended up happening is the CFTC took a look at it, thought it looks like it should be a regulated futures thing and is now pursuing anyone who voted their governance tokens in the DAO. 00:03:37:26 - 00:03:53:12 Cas Piancey Why do you think this is a big deal? Why do you think that this is going to be setting some precedents that are likely to it seems like you're you're pretty certain it's going to trouble the cryptocurrency community at large and that it's going to cause a lot of DAOs a lot of issues. 00:03:54:00 - 00:04:10:21 Bennett Tomlin Yeah. So I think there's a couple of things at play here. One is just and like crypto currency lawyers have been warning about this like since the original DAO Stephen Palley back in 2016 wrote a piece for Coindesk talking like talking about how do you slow it DAOn? And his point was basically that these structures look a lot like things we've seen before. 00:04:10:28 - 00:04:30:26 Bennett Tomlin They look like partnerships, they look like unincorporated associations. And it's likely that the participants, if they aren't careful, will end up sharing liability like they would in those structures. And so I think this is going to be an important case for DAOs, because it's a reminder that the pastiche of decentralization is inadequate to protect yourself from regulatory intervention. 00:04:31:06 - 00:05:03:27 Bennett Tomlin Right. You can't just give a bunch of people tokens, make them vote on things, and then do whatever you want and assume that regulators will not be able to pursue you. The other reason I think it's important is because despite them having already settled with Bean and Kistner and with bZeroX LLC, who are most clearly like the people responsible for a lot of the governance decisions, for claiming that it was going to be enforcement proof when they transitioned it originally to bZeroX DAO and then rebranded it Ooki DAO like they were the ones behind this protocol and I think are the clearest ones that the CFTC should be targeting. 00:05:03:27 - 00:05:32:21 Bennett Tomlin Right. But they also, despite already having the settlement, filed the complaint against the DAO more broadly and yesterday tried to serve the DAO by sending a message through the Ooki DAOs website's help like chat thing and then made a post in the OokiDAO forum. This is the CFTC that did that, saying, Hey, just so you all know, we sent these documents to your help chat, but you've been served. 00:05:33:08 - 00:05:59:22 Bennett Tomlin And so two days ago I was more skeptical that this was going to be important. I thought the CFTC was going to let a lot of the smaller fish who participated kind of go and just kind of use it as more of a symbolic gesture. The fact that they're trying to serve the DAO through a website help chat, but makes me think they're more serious about pursuing the penalties and things they discussed in the complaint. 00:06:00:07 - 00:06:09:04 Cas Piancey I wonder, I mean, that seems precedent setting. I guess I, I actually wonder if anyone has been served through a help bot before. 00:06:09:09 - 00:06:39:14 Bennett Tomlin I, I expect that that service may be challenged. Gabe Shapiro, who's another cryptocurrency lawyer, was talking in Twitter about how he thinks that service may not be appropriate. But if, like, no one responds and like nothing happens, there's a chance that the CFTC gets a default judgment against the DAO put in place by a judge because no one from the DAO will have responded to the service. 00:06:39:14 - 00:07:08:14 Bennett Tomlin Right. And this is like the other tricky part, right, is because like the CFTC does know two members and participants in the Ooki DAO. Right. Definitively, they know Kyle Kistner and Tom Beam participated, but they are not being pursued as part of the complaint and they're not likely to have the same penalties is discussed in the complaint. So in the order that they made settling with the CFTC, they agreed to pay this fine to stop doing this and to stop voting in the DAO, yadda yadda, yadda, yadda. 00:07:08:24 - 00:07:36:09 Bennett Tomlin But in the complaint, there's another thing that the CFTC is pursuing, which by my reading, seems to forbid people who end up charged with this from trading commodities. So people who participated in this DAO, who voted their governance tokens, if the CFTC is successful and gets the penalties they are looking for, may be legally forbidden from trading. Ethereum Bitcoin or other commodities ever again. 00:07:36:22 - 00:08:00:04 Cas Piancey Lifetime bans. Wow. So here's a question. And you know, I guess I wish we had a lawyer on to discuss this with with us. But I wonder if the like you were saying, if nobody responds to this and they get their default judgment, how would they go about actually making sure that that judgment was seen through? 00:08:00:09 - 00:08:21:26 Bennett Tomlin I'm not 100% sure, but I imagine they would be able to identify many of the wallets who voted in governance protocols and stuff. And then it's a matter of subpoenaing exchanges and other entities which may have KYC info and stuff like that until you start to identify the people. Right. And again, I don't necessarily know that this is what the CFTC wants to do. 00:08:22:06 - 00:08:59:16 Bennett Tomlin One of the CFTC commissioners, summer Messenger, a Biden nominee, specifically filed a dissent against this complaint and thought that what the CFTC was trying to do here was an overreach. And so I think there's a good chance that, like your general thoughts and this is right, the CFTC went in to get these two people Bean and Kistner mostly and are filing the rest of this is like a way to signal this is under our jurisdiction, this is important and we can assert her influence, I don't know, practically that many of the people who chose to participate in this DAO are actually going to end up in trouble because I don't know that it's worth it 00:08:59:16 - 00:09:37:08 Bennett Tomlin for the CFTC to do that. But like symbolically now, everyone in cryptocurrency is very acutely aware that if they have governance tokens and they choose to use those governance tokens to achieve governance, they are more likely to end up liable for the actions that the protocol, the DAO, whatever are doing in court. And I think that that is a very strong disincentive to most of the governance models we've seen in crypto so far, at least like the token based governance models because it adds such an extra layer of risk on to participating in the governance process. 00:09:37:18 - 00:09:54:27 Cas Piancey I think you already hinted at this by mentioning a certain word, but what is the reason that the CFTC is going after this as opposed to, say, the SEC or any other governmental agency? I heard you mention the word I'm thinking of earlier, so I suspect that's the reason. 00:09:54:27 - 00:10:05:20 Bennett Tomlin But yeah, it's because they're doing derivatives trading. I think because you're doing margin trading, retail margin trading of commodities. And I think you're talking. 00:10:05:26 - 00:10:07:06 Cas Piancey So you mentioned, right. 00:10:07:23 - 00:10:37:17 Bennett Tomlin Yes. That was really two of the charges they have and that that's kind of the protocol works at a technical level. And so the CFTC sees these tokenized representations of margin they're doing and sees them as like perpetual futures contracts basically that should be under their jurisdiction. I think you could probably make an argument that the original bZeroX token and the and therefore the later Ooki token, which was really just a rebrand, could also be securities and under S.E.C jurisdiction. 00:10:37:24 - 00:11:10:24 Bennett Tomlin But like service, the DAO offered is very explicitly exempting under CFTC regulation. And I think we should really emphasize here that like part of what the CFTC is trying to show here, bZeroX was such a good test case for them because it started out quite centralized. It was a protocol with admin fees that allowed them to stop things, change things, run by this company in Georgia, by these two American persons offering this service to Americans that is not supposed to be offered, that advertised that they didn't do KYC checks, didn't do any of that. 00:11:10:24 - 00:11:30:22 Bennett Tomlin Right. And so like at that point it was like very clear cut bZeroX LLC is doing something wrong. And then when it came time for them to do the transition in, in August of 2021 and to become this bZeroX DAO, you have these same executives talking about how this was going to make them future proof that they would no longer get regulators. 00:11:30:22 - 00:11:52:22 Bennett Tomlin When they came to them and told them to comply, they would be able to tell the regulators to fuck off because there was no way for them to comply. Look, we're too centralized. And so that narrative, that belief, that idea that you can avoid regulator ire by putting a very thin voting mechanism on top of it, I think has been pretty thoroughly disabused after this. 00:11:52:27 - 00:12:21:09 Cas Piancey It is interesting, though, because I feel like and I imagine there will be some people who take issue with this, but to some extent, Ethereum itself started out very centralized where you could argue that people could very well be prosecute, too, for this offering that that took place and then essentially future proofed itself. And now none of these people a seemingly we have we have no idea what the future holds. 00:12:21:09 - 00:12:47:03 Cas Piancey But it seems like all of these people are not going to have anything charged against them or any anything like that. And and it is much different than something like Bitcoin, where you have one or a team of anonymous creators who have never been. Nobody knows. Still, to this day, there's all sorts of guesses and and most of them are silly, including my favorite. 00:12:47:03 - 00:13:04:10 Cas Piancey But there's there's no real person to even try to prosecute with that. Whereas with Ethereum, there definitely was. Now maybe that is no longer the case, but there definitely was at one point. So I wonder how that narrative is now shifting, if it is. 00:13:05:19 - 00:13:33:18 Bennett Tomlin Yeah. So I think that like pragmatically, practically, we can say that it is unlikely any of the Ethereum co-founders get pursued by the SEC for the selling of an unregistered security. In the original Ethereum sale. We had Preston Byrne on way back and he talked a little bit about how, in his opinion you can make the argument that it was a security sale and that there was this bit of manipulation of the sale by some of these powerful individuals who were there at the founding of Ethereum. 00:13:34:12 - 00:13:43:00 Bennett Tomlin Hinman made the comment about it being sufficiently decentralized, which has been very controversial and has of. 00:13:43:01 - 00:13:47:13 Cas Piancey Wasn't it was not like an official statement I just want know it was a personal audience. 00:13:47:13 - 00:13:48:18 Bennett Tomlin Personal stance. Yes. 00:13:49:07 - 00:14:02:14 Cas Piancey Yeah. That personal statement he made at an event or something like that versus like something actually stated with SEC header on it saying like, hey, we see it this way. So that's that's the controversy surrounding that. 00:14:02:17 - 00:14:32:13 Bennett Tomlin Yeah. Yeah. And that is a good note. But I think pragmatically that the SEC is kind of basically adopted that as their stance and they're unlikely to pursue it. And I think like we've talked about on a lot of these episodes, cryptocurrency is supposed to be about building systems that are at a sense actually enforcement proof and actually regulator proof, and they're actually censorship resistant and that a lot of our frustration comes DAOn to the fact that so many of these things inherent that language without making an effort to actually achieve that goal. 00:14:32:27 - 00:14:59:09 Bennett Tomlin And so I think what we're really seeing here is that many projects, including Ooki DAO, bZeroX, whatever you want to call this fucking piece of shit, took on that language in an attempt to appeal to this community, to these people who claim to believe in these things and believed that that was a sufficient deception, that regulators would treat it as if it actually was censorship resistant regulator proof and enforcement proof. 00:14:59:24 - 00:15:19:25 Cas Piancey This. But this brings up a point that I like. Again, I mean, maybe I'm pushing on something that we we have sort of already touched on. But like, if we go back in time and we go to 2017, 2018, Bitconnect also suffered from all kinds of these issues that you're discussing or for that, for that matter, what's it called? 00:15:20:02 - 00:15:21:22 Cas Piancey What one coin was that? 00:15:21:22 - 00:15:25:03 Bennett Tomlin The the that was the it was queen. We really. 00:15:25:09 - 00:15:57:10 Cas Piancey Yeah, yeah. So, so both of those used language that you would associate with cryptocurrency is a decentralization, you know, high yield. Like all these, all these things that are very common in this space. But I would argue that neither one of them truly achieved either of those either of those things. Meanwhile, when it comes to at least bitconnect, I know the SEC ended up going after some of the promoters and we had the Texas attorney general who went after the actual company. 00:15:57:10 - 00:16:13:08 Cas Piancey I don't even know what happened with the people who started it and ran it. I know maybe they're facing SEC issues, but again, why? Why are they facing SEC issues? Why is that considered a security whereas this thing is a futures contract or it's a whatever? Like what is the big difference here? 00:16:13:29 - 00:16:30:24 Bennett Tomlin I don't know that there is one. And like I kind of said, I think that you could definitely argue that the original bZeroX token was in equity, right? It was this company selling this token to raise money so that they in their very small limited capacity with admin keys that gave them full control over the contract, continue to develop and grow it. 00:16:30:24 - 00:16:41:21 Bennett Tomlin Right. Like there's very clearly an argument to be made to me that the X should fall under ASIC jurisdiction as well. Now Ooki token or whatever it is obviously. 00:16:42:04 - 00:17:09:01 Cas Piancey I guess the point I'm driving at here is do you think this is like I'm wondering if this if half of the story is about, you know, these cryptocurrencies doing clearly illegal things and getting having to face consequences. But the other half seems to be that regulators are just kind of like bobbing for apples, like they're there, they're just going in there and trying to get a hold of whatever they can and and stake a claim on it right now. 00:17:09:06 - 00:17:23:12 Cas Piancey And there doesn’t seem to be any kind of semblance of wait. It makes sense that the SEC is going after this and it makes sense that the CFTC is going after this. It kind of seems like whoever finds it first and throws their flag on it wins. 00:17:23:12 - 00:17:43:12 Bennett Tomlin So I think there's a couple of things going on here. One is that there is like this turf war currently going on between the CFTC in the FCC over who gets de facto regulatory control over crypto. Both will end up regulating different parts no matter what, but one is likely to kind of be the primary or de facto regulator, at least in America. 00:17:44:02 - 00:18:08:12 Bennett Tomlin This controversy has led to a bunch of bills in Congress. We talked about this a little bit. When Nikhilesh was on here, Sam Bankman-Fried and FDX were huge proponents of the CFTC being the new de facto crypto regulator. I tried to reach out to them to see if that is still true. After this enforcement action. But if you contact their contact email address, they tell you to file a support ticket and they'll get back to you soon. 00:18:08:25 - 00:18:13:07 Bennett Tomlin I didn't really need support, so I kind of stopped there. 00:18:13:07 - 00:18:34:08 Cas Piancey And this is I know what you're going through that I just want to do a little explaining here and that I think Ben and I both suffer from constant frustrations when it comes to getting in touch with any of these companies. And it's not strictly cryptocurrency companies. It is finance in general. It is all these tech companies. They just. 00:18:34:08 - 00:18:35:16 Bennett Tomlin Energy utilities. 00:18:35:26 - 00:18:52:20 Cas Piancey None of them want to answer questions. None of them want to answer questions. I have. I tried to reach out to the CDB. Q I tried to reach out to West Kap. Those guys decided they didn't didn't really need to talk to me. Fair enough. But like, gosh, it would just be nice if some of these companies decided to open up and be honest a little bit. 00:18:52:20 - 00:18:55:13 Cas Piancey Anyway, I apologize, please. Yeah, no, that's fine. 00:18:55:13 - 00:19:12:23 Bennett Tomlin And so I think, like, there's this ongoing turf war, there's a whole bunch of money being spent to try to declare a winner. And I think the CFTC knew they had a really strong case in the first half of X rate when it was clearly controlled by the Corp. They were able to get that settlement and they knew they were going to be able to lock DAOn that part. 00:19:13:02 - 00:19:33:27 Bennett Tomlin So then they saw it as an opportunity because they could clearly show that this behavior was wrong before and that these people were willing to sign off and say, Yeah, this was wrong before and after was the same kind of behavior. They hoped that by like getting that agreement on the first half, they could immediately parlay it into the second half and gain a broader breath of control than they could originally. 00:19:34:03 - 00:20:11:29 Bennett Tomlin And this is why you have like Summer Messenger in her dissent to the complaint saying that like this is an example of regulation by enforcement. This is the CFTC trying to go outside of their rule making process to establish a new piece of turf of domain and even makes the argument that, like the liability they're trying to extend from, like this unincorporated association, that their legal theory is based on a couple of like state level law cases and doesn’t necessarily apply to the authority granted to the CFTC by the CEA, the Commodities Exchange Act, and even continues to go on and make two other points, which I think are important and one that we already 00:20:11:29 - 00:20:37:08 Bennett Tomlin talked about, which is that this would make it so that anyone in cryptocurrency is disincentivized from participating in governance, even if your participation would be to say, for example, vote for a proposal that would make your protocol more compliant, more legal, or doing the right thing. Making that vote would still make you a participant and liable even if that vote like let's say that vote fails, then the illegal thing happens. 00:20:37:08 - 00:21:09:25 Bennett Tomlin You're voting despite voting against the illegal thing could still be considered participating in the DAO and make you liable for the actions of the DAO. Her other point was that the CTA, the commodities exchange Act, already gives the CFTC the ability to pursue agents who were aiding and abetting the violation of these laws and she believes that, like Kistnerand Bean and bZeroX LLC could very clearly be pursued under that existing statutory authority and so sees the going after the DAO as a whole. 00:21:09:25 - 00:21:27:27 Bennett Tomlin And so it just those key individuals as exactly what you're saying, the CFTC taking a chance, taking a stab and trying to get a bigger piece than perhaps they're supposed to. And they're hoping if they get it quick, if they slide in on this week, little protocol with like basically no total value locked that no one cares about they can get it here. 00:21:27:27 - 00:21:33:08 Bennett Tomlin They can kind of start locking that out in the bigger picture of the American crypto regulatory sphere. 00:21:34:01 - 00:22:00:27 Cas Piancey Yeah, I, I think and this is again, you know, we find ourselves frustrated with regulators. It's a common theme on this show. I think in finance in general, I get that they're in a very difficult position in terms of in terms of budgets and how effective they've been in years previous, which kind of makes them not as effective now. 00:22:01:09 - 00:22:23:14 Cas Piancey And I just I understand they're caught between a rock and a hard place. It's just disheartening when you see stuff that you kind of even want to be like, Well, this makes sense. They're going after this really crappy, horribly formed, like unincorporated association that's doing all kinds of things that they shouldn't be doing. And you're still able to be like, But DAOs this even make sense on every level? 00:22:23:14 - 00:22:44:05 Cas Piancey And you can't necessarily justify it. And we're on their side like if anyone in cryptocurrency is, it's like us. So I don't know, it's yeah, it's disheartening, but I, I think what's the, the last question I have and pretty much coming at this from the this the same headspace as our audience hopefully on this one because I haven't been following it too much. 00:22:45:13 - 00:22:51:22 Cas Piancey What do you think is the best and worst case scenarios for the end result of this this action? 00:22:52:00 - 00:23:17:25 Bennett Tomlin Well, I think the worst case scenario is kind of something I already alluded to, which is that this becomes kind of the new normal and that the CFTC and later other agencies find themselves more comfortable pursuing DAOs and more specifically pursuing people who voted in the governance process for DAOs. And if they're able to get like the penalty where those individuals can like no longer trade commodities and things like that, that is a really serious penalty for some of this. 00:23:17:25 - 00:23:38:13 Bennett Tomlin Right. And so, like in the case of like bZeroX there's like student blockchain clubs and stuff that had some governance tokens and participated in decisions and things like that. And so are you going to ban a bunch of college students who are doing like this experiment and unchain governance from ever participating in cryptocurrency again, from ever being a commodity trader, from everything like that? 00:23:38:21 - 00:23:55:14 Bennett Tomlin And are you going to start applying that to a whole bunch of DAOs and protocols as you go DAOn the list and you pursue all those individuals? That's the worst case scenario, right, is that they really take it through to that full conclusion and go after even the smallest fish they can find. The more likely scenarios which I think are going to end up clues to. 00:23:55:14 - 00:24:20:18 Bennett Tomlin The best case scenario is that they got this settlement against Bean Kistner and bZeroX LLC. I expect that to continue to stand the Ooki DAO was barely a going concern as is is was very much a forgotten protocol. I don't I hadn't even realized that P6 had rebranded at any point, right? Like this was not at the top of most people in cryptocurrencies mind. 00:24:21:22 - 00:24:45:19 Bennett Tomlin And so I expect it'll continue to get smaller and less and less important and more and more push to the periphery with fewer and fewer people willing to take their chances participating in it. I think that then we're going to see a whole bunch of arguments over whether or not the service was proper and then a whole bunch of arguments likely over whether or not into the arguments the CFTC has tried to make are legally appropriate. 00:24:45:19 - 00:24:59:21 Bennett Tomlin And I think there's a good chance we'll see some larger players in cryptocurrency, larger than P6, that is, intercede in this case and offer to provide assistance because they they are incentivized to make sure that this doesn’t become the new normal. And so what. 00:24:59:23 - 00:25:16:25 Cas Piancey We think we've been seeing a lot of that as well from whether it's after X or Coinbase. But a lot of these a lot of these organizations have been both lobbying and putting up defense funds for for for stuff getting prosecuted against. 00:25:17:10 - 00:25:41:12 Bennett Tomlin So yeah. And so I think just very basically at the best level, this is going to it's going to be a forcing function that's going to force a clearer answer on certain questions about regulatory authority and like regulatory jurisdiction between like the CFTC and the FCC in the United States. We're going to get a more clear answer and what the CFTC's current limits are. 00:25:41:21 - 00:26:06:09 Bennett Tomlin And I think that this may also change some of the lobbying efforts by cryptocurrency industry participants, because they may no longer see the CFTC as the friendlier regulator. So I do want to add that one of the main people pushing that has been Sam Bankman-Fried and ftx and the way they profit is by offering a registered version of what this smart contract was doing. 00:26:06:18 - 00:26:32:24 Bennett Tomlin Right. And sure, Alameda profits a lot from DEFI and from this kind of same bullshit. But even when asked to describe that kind of thing, SBF has a tendency to give answers that make defi look bad. So it is possible that this will strengthen FTX’s desire to have the CFTC as the primary regulator if they think that it will basically force anyone interested in this kind of derivatives or margin trading into their platform. 00:26:33:00 - 00:27:04:26 Cas Piancey Yeah, I'm fair. Could be the case. I think most of crypto currency advocates don't. I don't they don't necessarily see Coinbase or FTX and Alameda as like the good guys. I think they just see them as people. Yeah. And providing a very liquid pool of money for people to trade with. So I anything else you think should be added? 00:27:04:27 - 00:27:23:22 Bennett Tomlin No, I think this is just going to be a really interesting example for us to pay attention to as this case progresses over what's likely to be many months to kind of and like as we head into midterms and we see more and more jostling between the regulatory agencies to kind of pay attention to that interplay, to kind of figure out who's going to end up leading the charge. 00:27:24:12 - 00:27:54:10 Cas Piancey Yeah. On that note, you know, hit the like subscribe, you know, leave a review all that. If you do each one of those. So we are announcing officially the crypto critic's corner DAOn for each time you leave a like a review or you sub we will give you one vote in the new government, the crypto critic's corner governance token, which will allow you to trade on crypto critic's corner exchange futures contracts for the crypto critic's corner coin. 00:27:54:22 - 00:28:04:03 Cas Piancey But that's neither here nor there right now. Just, you know, hit that like subscribe button and please God, let the CFTC know that I'm joking. 00:28:05:03 - 00:28:10:19 Bennett Tomlin The important thing to remember is that Cas Coin is enforcement proof.