fbpx
Connect with us

CryptoSpace

Token issue considerations: Why Howey Test is ineffective for Blockchain and Crypto space?

Published

on

Howey Test has no place in Blockchain and Cryptocurrency space and why SEC has to change the rules before other countries take over the Blockchain space. Switzerland is already pushing the envelope to become global Blockchain Hub.
Highlight and Share any text
Initial Coin Offerings (ICOs) were the craze in the world of cryptocurrencies during 2017. While it may seem like they have died down, the fact is they are still out there.

If you are a company that is looking to raise the money using ICO route, you may have wondered as to the accounting and tax implications. At least, the real businesses will have to ask the questions about legality, accounting, and tax issues before they go onto raise the money. Only companies that are trying to scam people will ignore these aspects.

In this article, we will try to talk about the accounting and tax considerations from a business perspective (not individual tax, for individual tax considerations, check out our FBAR and FATCA article and Individual FBAR and FATCA Guide here).

Because this topic is quite broad, we will break it down to the following content to understand it piece by piece.

Content:

Is it a coin or a token?

coin or tokenA coin denotes an ‘exchange value’, much like a US dollar.  You can use the coin for products and services.  For instance, if you hold a dollar bill in your pocket, it doesn’t do anything unless you use it to buy a product or service or invest.  Similarly, a coin does not offer anything on its own blockchain unless the holder exchanges it for something.

Bitcoin is an example of a coin. Litecoin and Ethereum also are native coins of their respective blockchains. Ethereum assumes additional features than a coin because of its ability to execute smart contracts and facilitating Initial Coin Offerings (ICO) and may qualify as a coin and a token (depending on who you are talking to).

Token, on the other hand, is designed to be more than mere ‘exchange of value’. For instance, a token can grant you:

  • Access to services on its blockchain platform
  • Rights to profits from the business
  • Speculative trading opportunities
  • Discounts to certain features on the platform
  • May grant voting rights
  • Master nodes, a new way of locking of the certain number of tokens to generate dividends in the form of native tokens or paid out in coins

It is important to note that although a token may have one or more of the above-listed functionalities, it is not required that a token offers all of the above functionalities to qualify as a token, it does, however, has to offer more than mere ‘exchange of value’.

In summary, a coin can be regarded as ‘cash i.e., exchange of value’ while a token can be regarded as ‘cash i.e., exchange of value + functionality’. 

In summary, a coin can be regarded as ‘cash i.e., exchange of value’ while a token can be regarded as ‘cash i.e., exchange of value + functionality’.

Why is it important to distinguish a token from a coin?

Sec RegulationsAuthorities are trying to apply regulations that are as old as landline phones to a technology landscape that deals with voice activated-face recognizing-thumb printing smartphone era. Just as many of the old era thriller plots would not work in the age of smart-phones, trying to apply regulations that are not designed for the technological revolution such as blockchain will not work.

However, within the current framework of regulations, it is important for the startups and established organizations to be vigilant and avoid triggering a regulatory nightmare.

One way to minimize tripping security regulations is to determine whether what you are offering through your ICO qualifies as a coin or utility token or security token.

One way to minimize tripping security regulations is to determine whether what you are offering through your ICO qualifies as a coin or utility token or security token.

How to structure the token sale and best strategies?

The whole ICO area is at its infancy.  Even those who claim to be ‘experts’ are in a learning phase.  This does not spare you from the need to seek professional legal counsel help before launching an ICO.

The legal counsel will look at various aspects that are specific to your offering to determine whether or not your ICO will result in issuing security tokens or utility tokens.

While the literature is exhaustive, we have put together a summary that compares a utility token with the security token and contrasts with fiat and coin.

utility token over security token

Legal counsel can help with determination of whether a token issued in the ICO leans toward a utility token or a security token based on the characteristics, some of which are referenced in the above table.

While the above Howey test has been used extensively thus far, SEC has recently been cracking down on ICOs that issued tokens recharacterizing them as ‘security offering’. This trend will continue until a complete shakedown of ICOs. The good news, if there is any, is that SEC has not been pursuing criminal charges, rather they have been settling with penalties (although severe).

For the most part, Howey test could be easily challenged by SEC and it is an onerous process to counter SEC’s allegations and companies have to be absolutely sure that what they are offering are indeed utility tokens and not security tokens.

What structure fits your criteria will depend on what you are trying to accomplish. For instance:

  • If you are working on a project that relies heavily on the mass adoption of the technology itself, you might be better off issuing a utility token
  • If you are looking to raise capital in the traditional sense but want to avoid the complications of a traditional IPO, you might be looking to issue security tokens

It is important to note that your intentions have very little to do with how the tokens will ultimately be treated unless you structure your ICO to match your intended purpose with the required professional help.

  1. Howey test and its application to blockchain space

When it comes to following SEC guidelines, most ICOs provide a document that shows where they fall within the Howey Test in determining whether their token should be treated as a security by the SEC.

Howey Test looks at three main considerations:

  1. Investment of money;
  2. The existence of a common enterprise, and
  3. Expectations of profits.

We believe this model of determining the nature of tokens is really an outdated one.  Below you will find our opinion on whether or not Howey test applies to tokens and why it is an ineffective method of determination for the blockchain space.

Rule 1: Investment of money

Money Investment Security Tokens

Tokens:  Satisfies; Although digital currencies are regarded as ‘commodities’, the argument has been placed that those that intend to purchase tokens in a crowdsale have to first exchange fiat in order to procure digital currencies and later exchange such digital currency for tokens and accordingly this first rule will be met.

Why Howey test may limit blockchain space?

Both the Commodities Commission and IRS have regarded Bitcoin as ‘commodity’; Ethereum also resembles features of a commodity although it is a utility token in our opinion, both of which do not satisfy the definition of ‘money’.  However, for the purpose of applying the Howey test, most companies consider Fiat and Digital currency as satisfying the definition of ‘money’. While this is a conservative approach, we think there is a need for clarification;

                  Rule 2: Investment in a common enterprise

Tokens: Yes, this rule is met because, generally speaking, individuals are investing into one ‘identified’ entity; See comments below.

Why Howey test may limit blockchain space?

While in the traditional stock market, investors play a passive role and still earn a share in profits and ownership, it is not entirely so in the blockchain/crypto space.

Investors can increase the demand for tokens of a given enterprise by:

– HODLing (holding to create scarcity in the market and thus increasing the demand)

– Creating hype in the market, this market is in its infancy is very susceptible to the hype (in the form of exaggeration and/or misinformation)

– Writing articles about the project

– Creating support groups and awareness campaigns, both online and offline

As you can see, although the common enterprise controls the profitability of the project by their performance, it is not a sole determinant of the success of the platform (and thus the change in the value of the investment);

We live in a world of shared economy and this also means that millennials not only take part in investing a novel idea, they also take part in its success. Accordingly, applying draconian rules of ‘passive’ investment into an identifiable enterprise to determine whether a token is a security or utility token does more harm than good.

Rule 3: Expectation of profits from the investment

Tokens: Depends; If the expectation of profit is based only on the success of the platform and eventual utility of token in exchange of SERVICES or features on the platform, then the expectation of profits criteria falls into a gray area and such token structure may be regarded as ‘utility token’.

If the expectation of profit is based on a promise of a share in ownership and/or profits and/or equity

and/or voting rights, then token qualifies as security.

Why Howey test may limit blockchain space?

Strictly speaking, this criterion applies to all classes of assets on the blockchain: Coins, utility tokens and security tokens alike.  Those who are investing into these classes are investing in the hope of an increase in value or utility or demand, all of which represent ‘expectation of profits’, in our view.

However, when this line of thought is applied, the whole blockchain (and ICO) space can be stifled.

An immediate overhaul of the regulations is required to enable the growth of blockchain technology space while providing a legal framework to curb bad players.

SEC is your friend, not a foe, a secrete route to avoid needing registering with SEC

US Securities Exchange Commission (SEC) understands that imposing unrealistic rules will not stop the innovation.  What it facilitates is the ‘migration of intellectual capital’ to more friendlier jurisdictions.  This is one of the main reasons why SEC has taken a ‘do no harm’ position.  While ‘do no harm’ is the right direction, it is not a deterministic one.

SEC has launched a helpdesk to help companies figure out whether their offering will be regarded as security or not. Advice will be provided by the help desk on ‘facts and circumstances’ basis’. Address for the help desk is: FinTech@sec.gov

SEC has a dedicated page for emerging FinTech.

SEC also has an exemption to raise capital without needing registration. Under Rule 506(c), a company can broadly solicit and generally advertise the offering and still be deemed to be in compliance with the exemption’s requirements if:

  • The investors in the offering are all accredited investors; and
  • The company takes reasonable steps to verify that the investors are accredited investors, which could include reviewing documentation, such as W-2s, tax returns, bank and brokerage statements, credit reports and the like.

Purchasers of securities offered pursuant to Rule 506 receive “restricted” securities, meaning that the securities cannot be sold for at least six months or a year without registering them.

Being security is not all that bad

While a major part of this article dealt with an ICO tripping security laws and overburdening regulations, there are many companies that are working on solutions when a company deliberately wants to go into an ICO to issue security tokens.  In other words, instead of avoiding being security, some companies may choose to issue a security token.

One such company that is working on solutions in the security tokens space is Polymath.  Their very slogan to market is “securities token platform”.  They want to help the companies with the issuance of security tokens that comply with SEC regulations without the underlying costs. They offer security token launch service to companies that have no legal knowledge as Polymath team will handle the legal side of issuing security tokens.  We anticipate many more service offerings in this space in the coming months and years.

A recent one that we reviewed is called WeOwn (CHX). Own’s Company representative explains their platform as, “We see ourselves as a service and not just an issuance platform. Whilst we do offer and manage primary issuance of financial asset backed tokens, we provide much more services after the issuance event: we manage investor and shareholder data (on our DSR), we manage the dividend disbursements, we create and generate tax and financial reports for both issuers and investors, and we support and manage corporate actions and other events.”

If Own’s vision comes to fruition – the whole complicated and unnecessarily cumbersome capital raising business could become as simple as tapping your smartphone (a bit of exaggeration but you get the point).

We at Cryptotapas believe that Security Token Offerings will storm the capital market in the coming years.  We will inevitably get guidance from the authorities and we will enter into an era of tokenization.  We will ultimately move from raising billions without guidance to raising Trillions of dollars using recognized, institutional platforms.  This will be part of Blockchain promise that will come to pass within the next 3-5 years, in our opinion.

Recently, SEC has proposed that they revisit the existing rules and regulations to facilitate the FinTech space. Switzerland has already started making progress in building a framework that facilitates FinTech space. Many other countries will follow the suite and Howey Test (and similar stock market rules) may be a thing of the past for the Blockchain space soon.

Thank you for reading this article.

Subscribe to be notified for new updates in Crypto and Free eBooks!
Subscribers get our upcoming copy of ‘STAYING RELEVANT’, an essential primer from Cryptotapas for FREE!
Staying Relevant by Cryptotapas
Buy us a Coffee: Keep information FREE. We do not sell what we research. A small tip from you can help us bring you more content like this for FREE.

BTC: 37kJr9PodRHzsG5u1ZfKkfYpHFSZrS8s9n 

If you are thinking to open KuCoinKucoin Referralaccount, please consider using our referral link.

IMPORTANT DISCLAIMER

Everything in this article is an opinion, not an advice of any kind. This material has been prepared for general informational purposes only and it is not intended to be relied upon as accounting, tax, investment, legal or other professional advice. Please consult with a professional for specific advice.

CryptoTapas does not endorse or guarantee the accuracy of the information and claims made in respective publications referenced in this database.

About the author

RK Reddy holds two Masters degrees, one in Accounting and another in Business Administration with over 15 years of experience in the financial services industry.

RK Reddy is an ardent fan of Blockchain and Cryptocurrencies. You can see the excitement about this new technology in every article on Cryptotapas.com. Sometimes this excitement leads to an overly optimistic view. Guilty as charged. RK Reddy says what may seem like an ‘overly optimistic expectation’ today may become an everyday norm in 5-10 years; look at the history of cars or airplanes, Blockchain and Cryptocurrencies belong to a similar frame of reference.”  Of course, that is just his opinion.

CryptoSpace

Transforming Data Center Infrastructure With Blockchain

Published

on

Blockchain Infrastructure

Cryptocurrency – just hearing the name – can spark discussion topics on how innovative and controversial it is. However, nowadays, there seems to be a consensus that blockchain – the technological backbone of every form of cryptocurrency – is the former. The latter part of the discussion comes from the fact that cryptocurrency is still new, and needs more improvement, before it can actually be considered a wildly-accepted type of commercial (public) currency.

On the bright side, companies like Google and Goldman Sachs have already started to invest in various blockchain firms. And, it’s expected that sometime in the future, more big-name companies will follow suit, if cryptocurrency succeeds. Therefore, data centers and cloud hosting services must be ready to serve these new blockchain-based companies, as well as their needs, in the coming years.

So, you may be wondering: How did we get here? 

How Did It Start?

Modern blockchain started in 2008 with Bitcoin, which is a peer-to-peer Electronic Cash System. This white paper was a form of cryptocurrency that could live on a distributed network without any centralized authority; and blockchain is the technical backbone of that system, or a distributed digital ledger or database for it. No central authority will be able to manipulate the blockchain, since the whole network contributes to its creation and maintenance.

How It Works

In blockchain, two parties will make a transaction, to which they advertise it to the network. Then, various network nodes pick up multiple transactions, and arrange them into blocks. Afterwards, miners will use computers to add this block to the ledger (or blockchain).

Now, in order to add these blocks to the blockchain, the task requires a lot of computing power. Why? Because each of these blocks come with a sort of attached mathematical puzzle. And, to solve these puzzles, they need computing resources. But don’t worry: these puzzles are what miners are interested in, because they’re usually rewarded with tokens, just for adding a block to the blockchain.

Before the existence of blockchain though, business transaction would’ve been made through a trusted third-party company (i.e. a bank or a government institution), in order to guarantee the integrity of a transaction between two parties. However, blockchain eliminates that need by opening up the possibility for business transactions between parties worldwide, without the need for any financial or government institutions to step in. 

What Blockchain Means For GPUs

The need for blockchain means elevated demand for graphical processing units (or GPUs). As blockchain calculates, miners will have to provide enough computing power for it. And, as cryptocurrencies and blockchain-based applications become more popular, the higher the demand for computing power. That’s where GPUs come in, since blockchain-based calculations are best performed on these units. 

Data centers and cloud-hosting services will also have to look into AMD and NVIDIA graphics cards, in order to better serve the blockchain market; however, these graphics cards can be pricey. And, they’ll have to better optimize their infrastructure to be GPU-compatible.

Concerns?

The most controversy that cryptocurrency has faced is its vulnerability to possible hacking schemes. One can argue that there are major concerns about blockchain hackers taking – or planning to take – advantage of the fact that cryptocurrency doesn’t have enough protection yet to sustain itself, in case of a security breach that can cost millions.

Concerns on cybersecurity for data centers, in that case, seems to have spawned from cryptocurrency market’s promise of immense riches and overnight successes, to where anyone – including bad actors and hackers – will create an ever-growing threat in the cyber realm.

“One example of hacking of cryptocurrency was in January of 2018, when hackers were able to steal more than $500 million (or £380 million) worth of cryptocurrency from the Tokyo-based cryptocurrency exchange Coincheck,” adds Barnard. “Thus, that story, to this day, serves as a warning to what can happen, if cryptocurrency is unchecked. And, this story has many people concerned about whether cryptocurrency is safe to invest in or not.”

Conclusion

As you can see, data centers will have to go above and beyond to better accommodate the growing trend of cryptocurrency. And, to do so, they’ll need a good functioning digital infrastructure, to handle blockchain systems and increasing data processing demands.

This need for the right data center infrastructure is also increasing, since blockchain is expected to greatly impact the following:

  • Finance
  • Healthcare
  • Government
  • Transportation
  • Manufacturing
  • Medicine
  • Logistics
  • Other various industries 

Thus, it’s absolutely necessary for data center service providers to stay competitive, when it comes to such changes in technology, including blockchain. Ultimately, with an up-to-date infrastructure for blockchain to work on, data centers will be able to be sustainable, regardless of any changes and or developments made in the tech world for many years to come.

Author’s Bio: Katherine Rundell is a writer and editor at UK Writings and Academized. In her spare time, she likes to travel to different states, give special talks in various business training courses, read her favorite books (ranging in different genres).

Thank you for reading and sharing this article. We appreciate you.

Stay safe and healthy!

Top 5 Cryptocurrencies 2020

IMPORTANT DISCLAIMER

Everything in this article is an opinion, not an advice of any kind. This material has been prepared for general informational purposes only and it is not intended to be relied upon as accounting, tax, investment, legal or other professional advice. Please consult with a professional for specific advice.

We do not endorse or guarantee the accuracy of the information and claims made.

All product and company names are trademarks™ or registered® trademarks of their respective holders. Use of them does not imply any affiliation with or endorsement by them.

 

Continue Reading

CryptoSpace

5 Best Crypto Movies To Learn Crypto From

Published

on

Crypto Movies

Bitcoin has been around for 10 years. As a result, there are many people who will keep tabs on it and cheer for its modern successes. So today, we want to celebrate along with crypto fans by bringing you a fun article about the topic.

If you thought that cryptocurrency is all business, business, business – well, in actuality, crypto has also made its way into cinema. Yes, in this article, we’ll show you the 5 best movies that involve Bitcoin, crypto, and blockchain. And, the good news is, you don’t have to read really long articles that talk about crypto, when you can watch a fun movie instead!

So if you want to gain a bigger understanding on what Bitcoin is, and why it’s so important in today’s world… or if you want to educate others on why Bitcoin is NOT something out of a science fiction movie (no pun intended), then check out these 5 great movies.

Cryptopia: Bitcoin, Blockchains And The Future Of The Internet (2020)

Cryptopia Bitcoin Blockchains and the Future of the InternetCryptopia is an ideal film for novice cryptocurrency people. So, if you’re a newbie in the crypto world, or want to brush up on your crypto skills, then check out this documentary. 

This film is a deep-dive into the crypto world, and it doesn’t shy away from explaining the good things about crypto, as well as the negative parts of it. Yes, crypto can be both a Godsend and a curse, depending on how you look at the narratives you’ll listen you in the documentary. In hindsight, the movie will explore the story of bitcoin, and how it has managed to evolve through the years with its ongoing promises that crypto is “the future.”

So, whether you’re a skeptic, or you want to learn more about crypto, you’ll get to see both sides of the debate – as a better alternative to regular currency in the future, or a financial disaster in the making. Either way, this documentary will answer any questions that you might have about crypto.

The Rise And Rise Of Bitcoin (2014)

The Rise and Rise of BitcoinEver wondered how cryptocurrency became a thing? Then check out The Rise and Rise of Bitcoin! The film covers the stories of some of the early adopters of Bitcoin, including Gavin Andresen who was famous for communicating directly with Satoshi Nakamoto to help him create better technology. (By the way, Nakamoto is mostly famous for authoring the Bitcoin white paper, and for devising the first blockchain database.

Overall, this movie was one of the major productions to cover the main points, in regards to how Bitcoin and its assets were created to begin with.

The Second Target (2019)

The Second TargetThe Second Target was written by Graham Holliday, and stars Athen Walton. The movie follows a group of local crypto thieves now having their eyes set on their latest target. They kidnap a detective they think is on their case, but end up kidnapping the wrong guy. To make matters worse, the son of the kidnapped man teams up with a stranger, and they plot to stop the thieves’ second heist and save the kidnapped man.

While you’ll be immersed in the action, you’ll be learning the basics of what crypto is.

Trust Machine: The Story Of Blockchain (2018)

Trust Machine understands that almost a decade has passed, since the crypto world has transformed things. Since its existence came to be, many different cryptocurrencies have been created, with a small percentage of them expected to stand the test of time after the dust settles. While some people are still skeptical about the concept of cryptocurrencies, there are some parts of the world where people actually use cryptocurrencies as a way to buy things. However, other places have faced significant problems, as a result of exchanging goods with crypto within the industry.

Crypto (2019)

Crypto MovieCrypto, despite its panning from critics, has garnered somewhat of a fanbase. With a stellar star cast like Alexis Bledel, Luke Hemsworth, and Jeremie Harris, it’s hard to not see this movie. And, with a thriving fanbase, this movie is not only for movie fans, but also for crypto fans. 

The story follows an anti-money laundering agent (Beau Knaff) who reunites with an old friend who’s now into mining cryptocurrency. Now, with a potato farm being on the verge of being repossessed, the two soon investigate a gallery, which may be tied into a multi-million-dollar money laundering scheme. 

It’s action-packed, and it has you cheering for the protagonists as you follow the story from beginning to end.

BONUS: Throwback Movie – Inside Job (2010)

Now, while the film doesn’t directly involve Bitcoin or blockchain, it’s a good appetizer for learning what they are. And, it’s a must-watch!

Inside Job covers the actions that made Bitcoin a household name in the first place. The movie sells the concept as a type of currency that can’t be manipulated, controlled, or corrupted by any government. 

However, the main topic of the documentary involves the late-2000s financial crisis. In 5 parts, the film will cover how changes in the policy environment and banking practices only added more fuel to the fire, rather than stop the crisis in its tracks. 

Critically acclaimed, and winning an Academy Award for Best Documentary, Inside Job will have you on the edge of your seat, as it takes you through the financial crash. All information in this documentary, as well as its controversial topic, are understandable for most audiences, regardless if you know about cryptocurrency or not. 

Conclusion

So, there you have it! That was our list of movies to check out, if you’re in the mood for learning about cryptocurrency. If you want to go down the rabbit hole about the topic, or if you’re in the mood for something different than your usual shows and movies, then head over to Netflix, online, or anywhere where movies are sold, and check out our picks on the best movies about crypto.

We hoped you enjoyed our list, and made it a movie night tonight! As you’ll see in these selected films, they’ll show you how cryptocurrency has changed people’s lives in so many ways than one, and has no plans of stopping. So, get out your popcorn, and take some good notes about crypto! 

Author Bio:

Kristin Herman is a writer and editor at Best essay writers. As a marketing writer, she blogs about the latest trends in digital marketing. In her spare time, she coaches up-and-coming marketers on how to perfect their advertising practices in the ever-evolving market.

For movie crypto movies: Crypto Movie Database

Thank you for reading and sharing this article. We appreciate you.

Stay safe and healthy!

Top 5 Cryptocurrencies 2020

IMPORTANT DISCLAIMER

Everything in this article is an opinion, not an advice of any kind. This material has been prepared for general informational purposes only and it is not intended to be relied upon as accounting, tax, investment, legal or other professional advice. Please consult with a professional for specific advice.

We do not endorse or guarantee the accuracy of the information and claims made.

All product and company names are trademarks™ or registered® trademarks of their respective holders. Use of them does not imply any affiliation with or endorsement by them.

Continue Reading

CryptoSpace

Cryptocurrency Market Wrap

Published

on

Crypto news

Cryptocurrency news

Bitcoin hits a new all-time high.

Bitcoin just hit a new all-time high, surpassing the last all-time high of $19,783.21 on Dec. 18, 2017.

According to coingecko Bitcoin hit $19,860 on Nov 30, 2020.


Bitcoin’s attracts Mainstream media

As bitcoin hits its new all-time high, the mainstream media, The New York Times steps forward to cover the news and calls this time the rise is very less of a bubble this time around.


Bitfinex hackers move 5000 BTC in the midst of new highs

The hackers of Bitfinex who stole 119,756 BTC back in August 2016 have just moved 5045 BTC, worth $97 Million, to various addresses as the bitcoin prices reach all-time high since 2017.

A total of 14 transactions were sent as caught by btcparser.com


Venezuelan army turns to Bitcoin mining operations to overcome the country’s failing economy.

“Digital Assets Production Center of the Bolivarian Army of Venezuela” was inaugurated by the Venezuelan army.


No power supply to crypto miners in Yunnan province.

According to the Chinese crypto reporter Colin Wu, most of the miners have reported  that the authorities have passed the orders to shut the power being supplied to the Crypto Miners in Yunnan, which happens to be the third largest mining province in china.


Winklevoss twins on CNBC said that bitcoin is Gold 2.0, and it could disrupt gold.  When BTC reaches Gold’s market cap of $9 trillion each BTC will be worth $500,000.


Michael Sonnenshein, managing partner at Grayscale, says many public companies are adding bitcoin to their balance sheet.

Thank you for reading and sharing this article. We appreciate you.

Stay safe and healthy!

Top 5 Cryptocurrencies 2020

IMPORTANT DISCLAIMER

Everything in this article is an opinion, not an advice of any kind. This material has been prepared for general informational purposes only and it is not intended to be relied upon as accounting, tax, investment, legal or other professional advice. Please consult with a professional for specific advice.

We do not endorse or guarantee the accuracy of the information and claims made.

All product and company names are trademarks™ or registered® trademarks of their respective holders. Use of them does not imply any affiliation with or endorsement by them.

Continue Reading

Trending