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“The advent of blockchain technology, with all of its promise for disrupting existing business,
economic, and even governmental and social models, more immediately has disrupted
traditional models of capital markets activity, as well as the sleep of many a securities
regulator. Initial coin offerings (also known as ICOs, token sales, token generation events,
or TGEs) are increasingly displacing venture capital fundraising and initial public offerings
as a favored means of raising capital and funding the development of product and service
offerings. Whether driven by well-intentioned technologists, financial professionals
or scammers, burgeoning technological capabilities and the ability to build and leverage
network effects have frequently outpaced legal understanding and compliance.”

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