CTF Written Submission

RE: Request for Meeting – Decentralized Physical Infrastructure

June 17, 2025
  • The document requests the SEC to clarify that digital assets distributed as payment for services or as reward incentives within DePIN ecosystems do not constitute investment contracts under U.S. federal securities laws.
  • It urges the SEC to provide a clear framework for DePIN ecosystems that do not meet the Howey test, emphasizing that participants in these systems are not making an investment of money, nor are they investing in a common enterprise.
  • The document highlights the need for regulatory clarity to foster innovation and adoption of DePIN technology, which decentralizes physical infrastructure deployment, operation, and management.

Last Reviewed or Updated: June 18, 2025