The key for US compliance is to build a form of consumptive utility before the sale and never talk to your actual or potential buyers about the things they want to talk about (future prices, exchange listings). Look at IMVU’s no action letter for the kind of guidance US lawyers have been giving but nobody has been able to talk about. The SEC publicly agreed and I can confirm it matches the guidance given to many projects.

Huh. Okay, I'll take your word on it, I haven't done the research. Is this still a project you're actively working on, or have you moved on to other things?

Its really hard to reply to your leading questions when you're looking for controversy, or put your past troubled experience with token projects onto me (or trying to rationalize a pivot)

Token projects are just SaaS businesses with limited memberships that inherit transferability and settlement on a distributed ledger.

They're also extremely lucrative to sell in the primary market and the blockchain component sells itself.