Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Re: TNT-Wrapped Bitcoin
Dear Sir/Madam,
We respectfully submit this request for a no-action letter to permit the sale of “TNT-Wrapped Bitcoin,” in light of the recent approval of Bitcoin-backed ETFs by the SEC. As you are aware, the SEC has recently granted permission to BlackRock and Fidelity to offer ETFs backed by Bitcoin. In these instances, 1,000 Bitcoin ETF shares in a Fidelity brokerage account represent fractional ownership of a Bitcoin wallet belonging to BlackRock, the ETF issuer.
In today’s cryptocurrency market, various “wrapped Bitcoin” digital tokens, such as the Cardano-Wrapped Bitcoin1 (cBTC), also represent fractional ownership of a Bitcoin wallet, which serves as the underlying asset backing the cBTC cryptocurrency. These Cardano-Wrapped Bitcoins are identical in all respects to the SEC-approved Bitcoin-backed ETF security sold by Fidelity.
We are requesting a no-action letter to allow the sale of our novel TNT-Wrapped Bitcoin. Our rationale is that several "wrapped" Bitcoin products are already being offered for sale (e.g., https://wbtc.network/), and we wish to ensure the legality of such offerings before introducing TNT-Wrapped Bitcoin to the public. Alternatively, if registration is required prior to offering this product for sale, such as through an S-1 registration2, we request guidance on the necessary steps. As detailed in the attached white paper, TNT-Wrapped Bitcoin operates on the same principles as the aforementioned approved ETFs and Cardano-Wrapped Bitcoin. Specifically, it represents fractional ownership of a Bitcoin wallet that is fully convertible into the underlying Bitcoin asset upon the request of TNT-Wrapped Bitcoin holders.
In addition, unlike cBTC and other competing alternatives, TNT-Wrapped Bitcoin aligns with the regulatory framework established for Bitcoin ETFs, providing investors with the same level of security, transparency, and convertibility. Our approach ensures compliance with all applicable regulations, including providing regulators with full access to all TNT trades so that FINRA can detect insider trading, and ensuring full anti-money laundering (AML) compliance as required by the governing regulatory body under which these fractional shares will be sold and traded in the future.
Please find the attached white paper for your review, which provides a comprehensive explanation of the structure, functionality, and compliance measures of TNT-Wrapped Bitcoin.
We appreciate your consideration of this request and look forward to your favorable response. Should you require any additional information or clarification, please do not hesitate to contact us.
Thank you for your time and attention to this matter.
Sincerely,
Joseph Mark Haykov
Managing Partner, HH Research and Management, LLLP
This is our white paper, long and technical: TNT White Paper3
Same information – as an interview – still being worked on – ignore the AI-generated sample videos – but the script provides a lot of information: https://haykov.substack.com/p/interviewpresentation
1https://www.binance.com/en/square/post/945519
2https://www.law.cornell.edu/wex/form_s-1
3Go to: https://www.tntcoin.green-coin.org, then click on the red “TNT” button below “Money”
The acronym DIBIL, which stands for "Dogma-Induced Blindness Impeded Literacy," encapsulates a significant sociocultural phenomenon where rigid adherence to specific beliefs or ideologies leads to a decline in critical thinking, ultimately resulting in impeded literacy or functional illiteracy. This concept highlights the detrimental effects of dogma on individuals' ability to engage with diverse perspectives, analyze information objectively, and develop independent thought processes.
Breakdown of the Term
Dogma-Induced Blindness: This component of the acronym refers to the cognitive and perceptual narrowing that occurs when individuals are unwilling or unable to see beyond the confines of their ingrained beliefs. Such blindness fosters resistance to new ideas and a lack of openness to alternative viewpoints, effectively creating an intellectual echo chamber.
Impeded Literacy, or Illiteracy: The term "Impeded Literacy" underscores the paradoxical outcome of this blindness, resulting in a form of functional illiteracy. Individuals affected by DIBIL may possess basic reading and writing skills but lack the deeper literacy skills needed to critically engage with texts, discern fact from fiction, and synthesize complex information.
Impact and Implications
DIBIL serves as a warning against the perils of intellectual stagnation that arise from rejecting more accurate theories due to theory-induced blindness, which is inevitably dogma-induced. This can result in a real-world behavioral outcome akin to the Dunning-Kruger effect, where individuals blinded by dogma overestimate their abilities due to false assumptions about how things work, despite experts knowing these assumptions to be incorrect. DIBIL underscores the importance of fostering open-mindedness and critical literacy in education and society. It prompts educators, policymakers, and individuals to reflect on the value of encouraging curiosity, debate, and continuous learning, which are essential to combating the insidious effects of dogma-induced intellectual limitations.
Understanding and addressing the causes and consequences of DIBIL enables societies to create environments where diverse ideas thrive and individuals are equipped with the skills necessary to navigate the complexities of the modern world. By championing these values, communities can foster intellectual growth and resilience, paving the way for a more informed and adaptable society.