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The new hotness is “governance tokens” where no money is raised and tokens are dumped into a yield farm. The tokens have no utility or rights, just the ability to vote on governance. These tokens are worth billions of dollars in total. Example token launched this way https://www.coingecko.com/en/coins/yearn-finance

These launches side step many aspects of the Howie Test such as “an investment of money”. I’m unsure that the SEC would win in court against these.

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