munchee-the-sec-and-utility-tokens

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Munchee, the SEC, and Utility Tokens Author: John V. Eagan Pub. Date: 2019 Product: SAGE Business Cases DOI: https://dx.doi.org/10.4135/9781526467843 Keywords: utility, security and classification, security, Securities and Exchange Commission, ethers, coining, restaurants Disciplines: Business & Management, Entrepreneurship, Strategic Management, Entrepreneurial Finance, Business Law Access Date: January 4, 2023 Publishing Company: SAGE Publications: SAGE Business Cases Originals City: London Online ISBN: 9781526467843 © 2019 SAGE Publications: SAGE Business Cases Originals All Rights Reserved.

1. 2. Abstract Munchee, Inc. is a company that created a peer-to-peer food review platform based on blockchain technology. Food reviewers were to be compensated with tokens that could be used at restaurants. In July 2017 the Security and Exchange Commission (SEC) released guidance on initial coin offerings (ICOs) that indicated that some tokens issued in an ICO may be clas- sified as a security. In their white paper, Munchee argued that their tokens were utility tokens and not a security under the Howey test. Munchee launched a token offering in October 2017. The SEC contacted Munchee and Munchee ceased their ICO and returned investor funds. The SEC issued a cease-and-desist order that indicated that Munchee had violated securities laws in their token offering. The primary issue in this case is how students can craft a token to satisfy the “utility token” exception to classifying a blockchain token as a security. Case Learning Outcomes By the end of this case study, students should be able to: understand the application of the Howey test by the Security and Exchange Commission (SEC) to cryptographic tokens; and understand the issues raised by the “utility token” exception to classification of a token as a security. The Resources tab includes a glossary of technical terms. Background Munchee, Inc., a Delaware-licensed corporation based in San Francisco, was founded in 2015 to build the Munchee network, a food review platform. Munchee described itself in a public announcement in BitcoinTalk as “Yelp meets Instagram.” Munchee is addressing the USD 54.8 billion marketspace of people eating out. The primary competition in the food review business at the time of the Munchee initial coin offering (ICO) was Yelp, founded in 2004. Yelp, a USD 3.2 billion company with USD 704 million in annual revenue, had 135 million cumulative reviews as of August 2017. Foursquare, Google Places, Michelin Guide, OpenTable, SAGE © John Vincent Eagan 2019 SAGE Business Cases Page 2 of 15 Munchee, the SEC, and Utility Tokens

and Zagat also provide online food reviews, but these other sites were nowhere near as large as Yelp. As the eleventh most visited site on the web, according to SEMrush, industry analysis often grouped Yelp with Facebook, TripAdvisor, Foursquare, Yellow Pages, and MapQuest. Existing restaurant reviews focus on the entire dining experience, not only on the food itself. Munchee pro- vides visual search results on dishes, rather than on restaurants, along with prices, reviews, and dish ratings. Munchee uses a machine learning algorithm to discover user preferences and suitable reviewers for peer re- view. On the Munchee platform, food lovers and photographers take pictures and videos of their food and then review the food on Munchee and other social media. Customers search by dish or cuisine with side-by-side information about price, reviews, and dish ratings. Customers pin the results to try the restaurant in person, and can click the order button to have food delivered. In 2017, Munchee customer retention tactics included: following other users and being followed, in-app gamification, accumulating points, and obtaining rewards. The two problems with centralized food reviews that Munchee seeks to address are: (a) manipulation to se- cure advertising; and (b) the predisposition of people with negative reviews to post more than others. The Munchee white paper cited the study by Luca and Zervas (2015) that found 16% of the reviews in Boston were filtered by Yelp in 2014 to attempt to reduce review manipulation. At the same time, Yelp itself has been sued for review manipulation. In one example the Ninth Circuit Court in 2014 ruled that Yelp could lower a business rating based on whether the business advertised on Yelp. The judge wrote that, “[a]s Yelp has the right to charge for legitimate advertising services, the threat of economic harm that Yelp leveraged is, at most, hard bargaining” ( Levitt v. Yelp, Inc. , 2014). Yelp denied the practice, stating that it used an automated system to determine ratings from reviews. Munchee sought to address this problem, real or perceived, by creating a decentralized peer review process for creating food review posts. A peer review can approve or flag a post. A flag may indicate spam or inap- propriate content. An approval shows that all required fields are correctly listed and includes a check-in at the restaurant and a user-generated photo. Users must review the validity of other posts to earn permission to create their own post and garner tokens (the MUN token, discussed below). Users only earn tokens upon successful review of their post by other users. This peer review process was projected to take seven to ten days. Machine learning would elect suitable reviewers based on location, food preference, and related crite- ria. A smart contract would keep an audit trail of submissions and a second smart contract would keep the MUN token record. SAGE © John Vincent Eagan 2019 SAGE Business Cases Page 3 of 15 Munchee, the SEC, and Utility Tokens

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MUN Token As seen above, the proposed MUN tokens were projected to be a component on the Munchee peer review process. The MUN open-source cryptographic token was to be a native cryptocurrency of the Munchee net- work. MUN was an ERC20 digital token issued on the Ethereum blockchain. The MUN was projected to be of fixed supply, fractionally divisible, and non-inflationary, transferable, and tradable on cryptocurrency ex- changes within thirty days of the ICO. Only a portion of the MUN token was projected to become liquid in the immediate term. The MUN token would be issued to Munchee, the restaurants, and users through an Ethereum smart contract. The MUN token would enable peer-to-peer transactions in the Munchee ecosystem. Munchee and restau- rants would make advertising payments to each other. Users would make in-app purchases from Munchee and receive rewards from Munchee. Restaurants would receive token payments for food and services from users and pay token rewards to users. There were further token incentives for content creators within this process. In each seven- to ten-day period the top 20% of users (in terms of review volume) would be rewarded additional MUN tokens. High-quality content contributors (top 20%) would also be rewarded with extra MUN tokens. Top reviewers were to be de- termined based on the accepted reviews, total number of likes, and pins in a period. Users could also earn MUN tokens for new users that joined and contributed to the platform though a referral process. The MUN tokens for these various payments were retrieved from Munchee’s company reserve of MUN. In this model Munchee argued that end users would benefit from peer review over false review sources and in tokens for activity in the mobile app, which could be redeemed for products and services at partner business- es or restaurants. Restaurants would benefit from the reduced fees to credit card agencies and knowing that their advertising dollars were going towards real reviews. The Munchee ecosystem would also be monetized through in-app advertising and 10–15% commissions on food delivery. Figure 1 , from the Munchee white paper (Munchee, 2014), shows a model of how the ecosystem would serve to increase the value of MUN. SAGE © John Vincent Eagan 2019 SAGE Business Cases Page 4 of 15 Munchee, the SEC, and Utility Tokens

Figure 1. MUN Value Model Source : Munchee (2014). Munchee proposed to use a proof-of-stake consensus algorithm for MUN as opposed to the proof-of-work consensus algorithm used by the Bitcoin network. Ethereum was moving to a proof-of-stake consensus algo- rithm in late 2017 as well. However, Munchee had not completely worked out the Munchee network consen- sus mechanism at the time of the token offering. There were no other firms offering a “blockchain-based food review incentivized platform” at the time of the Munchee token offering (Munchee, n.d.). SAGE © John Vincent Eagan 2019 SAGE Business Cases Page 5 of 15 Munchee, the SEC, and Utility Tokens

Munchee Roadmap Munchee did not have a fully working product at the time of their 2017 token offering, but the Munchee team had issued a white paper on October 16, 2017. Munchee first distributed its closed beta app in the fourth quar- ter of 2016, the iOS app in the second quarter of 2017 and an Android app in the fourth quarter of 2017. The Munchee white paper reported 3,500 Instagram followers and 16,000 Facebook followers in October 2017. The two-year roadmap for Munchee is presented in Table 1 . Table 1. Munchee Roadmap Quarter Planned feature completion or launch date 2017 Q4 Cryptotoken planning and issuance Cryptotoken pre-sale and sale event (ultimately canceled) 2018 Q2 Improve Munchee mobile app Backend, UX/UI, and restaurant database 2018 Q3 Begin development of Ethereum Smart contract for integration of MUN token in Munchee app Launch user acquisition and marketing campaigns 2018 Q4 Start of development of Smart contract to record reviews on Ethereum network Begin setting up in-app wallets for end-users 2019 Q1 Third-party security audits Food delivery partnership agreements 2019 Q2 Release a new website just for restaurant owners/managers Build web-based wallets for restaurants to facilitate advertisement SAGE © John Vincent Eagan 2019 SAGE Business Cases Page 6 of 15 Munchee, the SEC, and Utility Tokens

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Source : Munchee (2014). Munchee Team Based on their LinkedIn profiles (as of December 2017), Munchee founders and principals are: • Sanjeev Verma, PhD, co-founder. Verma holds a PhD in Electrical and Computer Engineering from the University of Toronto. He has been on the technical staff of Bell Labs, a senior research engineer with Nokia, and a mobile security architect for Samsung. He has twelve granted and eight pending U.S. patents; • Chelsea Lam, co-founder, Product Marketing Lead. Lam holds a BA in Marketing and Entrepreneur- ship from San Jose State University. Lam was previously a marketing consultant at VMware and a Hi Touch analyst for Google; • Nghi Bui, Chief Technical Officer and co-founder. Bui was a PhD candidate in Information Systems at Singapore Management University. Bui has been employed as a software engineer at Atlassian NS and a senior Backend Engineer at Cho Tet; and • Kyle Bunthuwong, Community Manager. Bunthuwong holds a BA in sociology from UC Berkeley and has worked in sales and marketing since 2013. Although the Munchee team seemed new to blockchain, the Munchee pitchdeck (Munchee, n.d.) listed a number of individuals as advisors with experience in crypto, including: • Loi Luu, co-founder of Kyber Network and Smartpool; • Nick Ayton, #21 on Rise Top 100 Blockchain people. Ayton has written extensively on blockchain topics and advised a number of funds on crypto investments; • Addison Huegel, formerly of the Ethereum Foundation & Kyber Network. Ethereum is the second most important cryptocurrency and the Ethereum Foundation has served to promote and extend the Ethereum platform; Integration of second Smart contract in Munchee app 2019 Q3 Integrate food delivery on Munchee platform SAGE © John Vincent Eagan 2019 SAGE Business Cases Page 7 of 15 Munchee, the SEC, and Utility Tokens

• Bryan Pham, co-founder and CTO of Cloudtenna; • Andrew J. Chapin, co-founder and CTO of Benja/BenjaCoin; • Min Kim, Chief of Staff of Civic. Civic is an attempt to use blockchain to create secure identities and Know Your Customer products. The Civic ICO raised over USD 33 million in its 2017 ICO with very little marketing; and • Christina Gagnier, legal counsel, a partner at Gagnier Margosian, LLP, where she focused on privacy and intellectual property Munchee Token Offering The Munchee ICO was announced in early October 2017. The Munchee ICO was marketed in cryptocurrency investment seminars, Twitter, Facebook, BitcoinTalk.org, the Munchee blog, the Munchee website, and on YouTube seminars, but not to restaurants. On or about October 25, 2017, Munchee posted on Facebook, “199% GAINS on MUN token at ICO price! Sign up for PRE-SALE NOW!” (Securities and Exchange Com- mission, 2017b). Munchee also offered MUN tokens to people who promoted the MUN ICO. On October 9, 2017 Munchee announced on Twitter that it was joining the Bancor network. The Bancor ICO took place in the summer of 2017. The purpose of the Bancor protocol is to allow anyone to create and man- age a liquid, viable token. In the Bancor protocol, tokens hold other tokens in a reserve balance that facilitates liquidity. This model allows a party to purchase or sell tokens through the smart contract, without a party on the other side. In October and November 2017, Munchee offered and sold MUN tokens. The Munchee goal was to raise USD 15 million to improve its existing app and to recruit users to buy advertisements, write reviews, sell food, and make other transactions using the MUN token. Munchee created 500 million MUN tokens and stated that no further tokens would be created. Munchee of- fered 225 million of the 500 million for the ICO. The remaining 275 million would be used for paying rewards, paying employees and advisors, and future advertising. The white paper also stated that Munchee would in- sure that MUN tokens were tradable on secondary markets within 30 days of the token offering. Munchee would also agree to buy and sell MUN tokens with its reserve holdings and they might also burn tokens. SAGE © John Vincent Eagan 2019 SAGE Business Cases Page 8 of 15 Munchee, the SEC, and Utility Tokens

The MUN tokens were available for purchase worldwide (with some exceptions), including the United States. The Munchee white paper expressly excluded China, Iran, North Korea, the Sudan, Syria, and the Crimea region of the Ukraine, from the token sale. ICOs were illegal in China at the time of the Munchee offering and the Munchee white paper referred to the other countries as “restricted jurisdictions,” presumably referring to sanctions imposed on those countries. Munchee established two sale periods for MUN tokens, a token pre-sale and the main sale. Purchasers in the early stages were offered a discount of 10% and 15%. Munchee also offered a 5% referral bonus during both sale events. Munchee accepted bitcoin and ether as payments. The exchange rate at the main sale was 1 ether (ETH) or 0.05 bitcoin (BTC) to 4,500 MUN. The value of ETH was approximately USD 303 and BTC was approximately USD 6,393 on October 31, 2017. This implies a sale price of the MUN of approximately USD 0.67. According to the website icodata.io, the average sale price of recent (as of January 2018) ICOs in 2017 was USD 3.00 and the median was USD 0. Figure 2 below shows the distribution of ICO token sale prices in 2017. Figure 2. ICO Token Sale Prices 2017 SAGE © John Vincent Eagan 2019 SAGE Business Cases Page 9 of 15 Munchee, the SEC, and Utility Tokens

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Allocation of Funds The funds raised by the token sale were to be allocated as follows: • 35% for marketing; • 40% to hire people for the development team; • 15% for maintenance of the MUN token ecosystem; and • 10% for legal services. The allocation of tokens held in reserve was to be as follows: • facilitating advertising transactions in the future—185,000,000 MUN; • in-app rewards—12,000,000 MUN; • bounty promotion—18,000,000 MUN; • referral bonuses—11,250,000 MUN; and • the team and advisors—33,750,000 MUN; team and advisors had a lock-up period of 6 months. July 2017 SEC Guidance on ICOs The year 2017 was a boom year for cryptocurrency and ICOs. The market value of cryptocurrency rose from USD 17 billion in January 2017 to more than USD 613 billion in December 2017. ICOs raised more than USD 4 billion in 2017. Against this background the SEC issued guidance in July 2017 stating that the tokens in 2016 The DAO token offering were a security and subject to registration under U.S. securities laws (Secu- rities and Exchange Commission, 2017a). The SEC applied the Howey test to The DAO tokens. Under the Howey test an “investment contract” is one that involves: (1) an investment of money; (2) from an expectation of profits; (3) arising from a common enterprise; (4) depending solely on the efforts of a promoter or third par- ty. However, the SEC guidance did state that not every cryptographic token is necessarily a security. On September 25, 2017 the SEC announced two initiatives. One was the creation of a Cyber Unit in the En- forcement Division. The other initiative was to establish a Retail Strategy Task Force to “identify misconduct impacting retail investors” (“SEC Announces,” 2017). One of the tasks of the Cyber Unit was to address “vi- olations involving distributed ledger technology and initial coin offerings” (“SEC Announces,” 2017). One of SAGE © John Vincent Eagan 2019 SAGE Business Cases Page 10 of 15 Munchee, the SEC, and Utility Tokens

the first acts of the Cyber Unit was to file an emergency court order to freeze assets of Plexcorps, saying that it defrauded investors with its PlexCoin ICO. Plexcorps had raised USD 15 million after “falsely promising a 13-fold profit in less than a month,” (“SEC Emergency,” 2017) according to the SEC. In January 2018 the SEC issued a cease-and-desist order against the ICO of Krops, a firm registered in Hong Kong. In January 2018 the SEC filed suit against AriseBank for making false statements and selling securities without registration. On December 11, 2017, SEC Chair Jesse Clayton issued the following statement on tokens: Following the issuance of the 21(a) Report, certain market professionals have attempted to highlight utility characteristics of their proposed initial coin offerings in an effort to claim that their proposed tokens or coins are not securities. Many of these assertions appear to elevate form over substance. Merely calling a token a “utility” token or structuring it to provide some utility does not prevent the token from being a security. Tokens and offerings that incorporate features and marketing efforts that emphasize the potential for profits based on the entrepreneurial or managerial efforts of others con- tinue to contain the hallmarks of a security under U.S. law. (emphasis added; Clayton, 2017) Chair Clayton went on to highlight the difference between tokens that do and do not qualify as securities through the metaphor of a book club. A key question for all ICO market participants: “Is the coin or token a security?” As securities law practitioners know well, the answer depends on the facts. For example, a token that represents a participation interest in a book-of-the-month club may not implicate our securities laws, and may well be an efficient way for the club’s operators to fund the future acquisition of books and facilitate the distribution of those books to token holders. In contrast, many token offerings appear to have gone beyond this construct and are more analogous to interests in a yet-to-be-built publishing house with the authors, books and distribution networks all to come. It is especially troubling when the promot- ers of these offerings emphasize the secondary market trading potential of these tokens. (emphasis added; Clayton, 2017) In a speech in at Northwestern Law School in January 2018 Clayton stated that Legal advice (or in the cases I will cite, the lack thereof) surrounding ICOs helps illustrate this point. … First, and most disturbing to me, there are ICOs where the lawyers involved appear to be, on the SAGE © John Vincent Eagan 2019 SAGE Business Cases Page 11 of 15 Munchee, the SEC, and Utility Tokens

one hand, assisting promoters in structuring offerings of products that have many of the key features of a securities offering, but call it an “ICO,” which sounds pretty close to an “IPO.” On the other hand, those lawyers claim the products are not securities, and the promoters proceed without compliance with the securities laws… Second are ICOs where the lawyers appear to have taken a step back from the key issues—includ- ing whether the “coin” is a security and whether the offering qualifies for an exemption from registra- tion—even in circumstances where registration would likely be warranted. These lawyers appear to provide the “it depends” equivocal advice, rather than counseling their clients that the product they are promoting likely is a security. Their clients then proceed with the ICO without complying with the securities laws because those clients are willing to take the risk. With respect to these two scenarios, I have instructed the SEC staff to be on high alert for approach- es to ICOs that may be contrary to the spirit of our securities laws and the professional obligations of the U.S. securities bar. (Roberts, 2018) Observers felt that the last statement indicated that not only was the SEC going after ICOs, but also attorneys that advised them. Also following the SEC 21(a) report the securities law plaintiffs’ bar initiated several class actions against ICOs, including Dynamic Ledger Solutions, initiator of Tezos, a USD 232 million ICO, ATBCOIN, initiator of a USD 20 million ICO, and Centra Tech, initiator of a USD 30 million ICO. This is a more serious consideration because the plaintiff’s bar has greater resources and more incentives to sue for selling unregistered securities than the SEC. This is particularly true given the spectacular 2017 increase in the ETH and BTC used to buy into various ICOs. State regulators also began litigating against ICOs. The Texas State Securities Board in January 2018 filed a cease-and-desist orders against UK based BitConnect as well as AriseBank. In January 2018 the Massa- chusetts Securities Division charged Caviar with selling unregistered securities in its ICO, even though Caviar stated it only sold tokens to non-U.S. residents. The state considered Caviar’s restrictions not to be strong enough to prevent purchases by U.S. residents. SAGE © John Vincent Eagan 2019 SAGE Business Cases Page 12 of 15 Munchee, the SEC, and Utility Tokens

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Munchee’s Legal Strategy for Its ICO The Munchee white paper stated that they had consulted with legal counsel and reviewed the SEC July 2017 guidance and the Howey test and concluded that “as currently designed, the sale of MUN utility tokens does not pose a significant risk of implicating federal securities laws” (emphasis added; Munchee, 2014). Howev- er, the Munchee white paper did not provide such a legal analysis. Nevertheless, the Munchee white paper stated that based on this undisclosed legal analysis, the MUN tokens, “were not and would not be registered or filed under the securities laws or regulations of any jurisdiction. Further, as this is a sale of utility tokens, it is not being provided through any of the exemptions under the United States Securities Act.” The Munchee white paper continued to qualify this statement by providing that “Munchee Inc.’s representations and secu- rities assessment is not a guarantee that the SEC or any other regulatory authority will not determine the tokens to be securities subject to registration MUN token began on or about October 31, 2017.” SEC Response to MUN Token Offering On November 1, 2017, Munchee stopped selling MUN tokens hours after being contacted by the SEC. Munchee had not delivered any MUN tokens by this time and the company immediately returned approxi- mately USD 60,000 (about 200 ether) to the 40 purchasers. In its written cease-and-desist order the SEC deemed that Munchee had violated Sections 5(a) and 5(c) of the Securities Act and ordered that “Pursuant to Section 8A of the Securities Act, Respondent Munchee cease and desist from committing or causing any violations and any future violations of Sections 5(a) and (c) of the Securities Act” (Securities and Exchange Commission, 2017b). The SEC did not impose any civil penalties on Munchee taking into consideration the “remedial acts promptly undertaken by Respondent and cooperation afforded the Commission staff.” In sum, Munchee attempted to circumvent the classification of its token as a security by appealing to the utility token exception. This approach was nevertheless immediately shut down by the SEC. SAGE © John Vincent Eagan 2019 SAGE Business Cases Page 13 of 15 Munchee, the SEC, and Utility Tokens

1. 2. 3. 4. 5. 6. Discussion Questions Discuss the “expectations of profits” leg of the Howey test as applied to the MUN token offering. What was the significance of the Munchee ICO marketing campaign for the SEC analysis? What are the implications of the SEC view on Munchee token sale for the use of SAFT promoted by CoinList (e.g., the Filecoin SAFT sale, one of the largest ICOs of 2017)? What legal weight would you assign to the SEC order and Clayton’s statements? How would you develop a Munchee utility token under this SEC guidance? Is the MUN token more similar to debt or equity? What difference does that make for the securities law analysis of the MUN token? Further Reading As of January 2018, there were no cases or law review articles even mentioning ICOs. A law review article in draft form is: Rohr, J., & Wright, A. (2017, December). Blockchain-based token sales, initial coin offerings, and the democ- ratization of public capital markets. University of Tennessee Knoxville College of Law, Legal Studies Research Paper No. 338. This “ongoing memo” raises many interesting questions, but the memo is more focused on the use of various securities law registration exemptions and ICOs as opposed to the utility coin exception: Hanks, S., Stephenson, A., Leo, H., Ostrow, J., & Campanelli, J. (2017, November 26). How ICOs can comply with corporate and securities laws: More questions than answers. Retrieved from https://www.crowd- check.com/sites/default/files/Securities%20law%20issues%20relating%20to%20ICOs%20Nov%2026.pdf For a discussion of utility coins before the SEC guidance, see: Van Valkenburgh, P. (2016, January 25). Framework for securities regulation of cryptocurrencies. Coin Cen- ter . Retrieved from https://www.coinbase.com/legal/securities-law-framework.pdf SAGE © John Vincent Eagan 2019 SAGE Business Cases Page 14 of 15 Munchee, the SEC, and Utility Tokens

References Clayton, J. (2017, December 11). Statement on cryptocurrencies and initial coin offerings. Retrieved from https://www.sec.gov/news/public-statement/statement-clayton-2017-12-11 . Levitt v. Yelp, Inc. , 765 F.3d 1123 (9 th Cir 2014). Luca, M. , & Zervas, G. (2015, July 20). Fake it till you make it: Reputation, competition, and Yelp review fraud. Retrieved from http://people.hbs.edu/mluca/fakeittillyoumakeit.pdf Munchee. (2014, July 15). Munchee: A cryptocurrency operated file storage network (Munchee white paper). Retrieved from https://s3.amazonaws.com/munchee-docs/Munchee+White+Paper.pdf Munchee. (n.d.). Munchee: The world’s first decentralized blockchain-based food review incentivized platform (Munchee pitchdeck). Retrieved from https://s3.amazonaws.com/munchee-docs/Munchee+Pitch+Deck.pdf Roberts, J. (2018, January 23). SEC Chair blasts lawyers over ‘disturbing’ ICOs. Fortune . Retrieved from http://fortune.com/2018/01/23/sec-ico-cryptocurrency/ SEC announces enforcement initiatives to combat cyber-based threats and protect retail investors. (2017, September 25). U.S. Securities and Exchange Commission . Retrieved from https://www.sec.gov/news/press- release/2017-176 SEC emergency action halts ICO scam (2017, December 4). U.S. Securities and Exchange Commission . Re- trieved from https://www.sec.gov/news/press-release/2017-219 Securities and Exchange Commission. (2017a, July 25). Report of investigation pursuant to Section 21(a) of the Securities Exchange Act of 1934: The DAO. Release No. 81207. Retrieved from https://www.sec.gov/liti- gation/investreport/34-81207.pdf Securities and Exchange Commission. (2017b, December 11). In the matter of Munchee Inc., order instituting cease-and-desist proceedings pursuant to Section 8a of The Securities Act of 1933, making findings, and imposing a cease-and-desist order. Administrative Proceeding File No. 3-18304. Retrieved from https://www.sec.gov/litigation/admin/2017/33-10445.pdf https://dx.doi.org/10.4135/9781526467843 SAGE © John Vincent Eagan 2019 SAGE Business Cases Page 15 of 15 Munchee, the SEC, and Utility Tokens

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