January 29, 2022
The SEC must revise this proposal to make clear that it is not intended to, in effect, prohibit the creation and deployment of mere code for peer-to-peer token trading or websitesincluding even mere block explorersthat merely provide information about the interactions that have occurred or can occur through such code together with information about how to interact with such code. There is no way mere coders or mere website operators can register with FINRA, track the identities and trades of AMM systems occurring on decentralized autonomous blockchain systems or otherwise comply with the ATS/ exchange reporting and registration regime, and therefore, if applied to such persons, this new rule would be banning a vast swathe of technologies and free speech regarding those technologies, which is beyond the SECs authority and would constitute an unconstitutional violation of our civil and human rights.