LETTER TO PROSPECTIVE INVESTORS: TNT-COINS
Dear Prospective Investor,
We invite you to consider TNT-Coins—an opportunity to hold a legally defined, fractional claim on glacier-fed water rights. In an environment marked by economic uncertainty, persistent inflation, and mounting environmental pressures, TNT-Coins offer a direct, clearly delineated property interest recorded on a transparent blockchain ledger. By combining tangible resource ownership with secure, verifiable transaction records, TNT-Coins provide a stable, inflation-resistant alternative asset backed by a fundamental, non-substitutable resource.
Why Water Is the Ultimate Asset
Water is indispensable for human life and economic stability. Unlike many commodities that can be substituted or engineered away, water’s essential nature is non-negotiable. Long-standing observations confirm that as freshwater sources diminish and demand intensifies, water’s relative value strengthens over time. Its critical role in health, agriculture, industry, and sustainable development ensures it remains crucial, regardless of technological advances or shifts in market sentiment.
While renewable energy and material recycling can mitigate dependencies on other commodities, water’s function in sustaining life and production is unmatched. Glacier-fed water, specifically, is rare, high-quality, and historically stable in worth—attributes that set it apart from any currency or speculative asset class.
TNT-Coins: Tangible, Legally Secured Ownership
Each TNT-Coin represents a fraction of enforceable U.S. property rights to glacier-fed water in New Hampshire, USA. Unlike tokens tied to corporate performance or purely speculative ventures, TNT-Coins anchor your holding in established property law. Their ownership records reside on an immutable, blockchain-based ledger, ensuring you can independently verify your holdings, confirm transaction histories, and trust the system’s integrity.
A Hedge Against Inflation and Market Volatility
As central banks expand money supplies, traditional currencies often lose purchasing power. Typical investments rarely provide true immunity from inflation. TNT-Coins, by contrast, are tied directly to an essential, increasingly scarce resource. They do not rely on corporate earnings or transient market enthusiasms. Instead, TNT-Coins reflect the inherent value of clean, vital water—a resource that gains relative worth as availability declines. By holding TNT-Coins, you secure a stake in a commodity whose significance grows with global demand, offering a logical means to preserve wealth against economic uncertainties that diminish the stability of other asset classes.
Global Relevance and Societal Significance
Clean, abundant water transcends borders and cultures. Its necessity unites economies from the Middle East to Asia, Europe to the Americas. TNT-Coins are not just another asset; they represent a cornerstone resource whose stewardship is increasingly prioritized in a world facing environmental challenges. Aligning your investment with such a resource situates you at the forefront of responsibility, sustainability, and long-term value creation.
More Reliable Than Digital Speculation and Traditional Commodities
More Reliable Than Bitcoin: Bitcoin’s value swings with market sentiment. TNT-Coins rest on legal property interests in an essential resource not subject to speculative hype.
More Essential Than Gold: Gold may store value, but cannot sustain life. Water’s enduring importance places TNT-Coins in a uniquely robust position.
Safer Than Stablecoins: Stablecoins rely on trust in reserves. TNT-Coins are grounded in transparent property rights and legal frameworks, reducing opacity and increasing verifiable authenticity.
Flexibility and Participation for Investors
If and when extraction begins, you may have options:
Physical Water Access: Potential deliveries of pristine glacier-fed water.
Revenue Sharing: If shareholders agree to commercial extraction, you could share in resultant income streams.
Influence Over Resource Stewardship: Your input can help guide future extraction strategies and decision-making.
(Please note: Dividends, physical deliveries, and extraction activities depend on future shareholder votes, regulatory approvals, and market conditions; none are guaranteed.)
Transparency, Compliance, and Accountability
TNT-Coins adhere to U.S. property law and conform to SEC no-action letter guidelines, providing a solid, legally sound and ethically transparent framework. We recommend consulting independent legal and financial advisors to ensure TNT-Coins align with your investment objectives and comfort level.
Conclusion: Own the Resource That Endures
In a world of shifting economic landscapes and inflationary headwinds, TNT-Coins offer not speculation, but an asset rooted in necessity, legality, and verifiable quality. We encourage you to scrutinize our claims, review our materials, and engage with our team. Every step toward TNT-Coins is backed by logic, factual clarity, and an essential resource no future technology can replace.
A DEEPER (WONKY-THEORETICAL) DIVE
Dear Prospective Investor,
We invite you to consider TNT-Coins—an opportunity to hold a fractional claim on glacier-fed water rights, a resource of verified essentiality for human life and economic stability. Today’s landscape is marked by economic uncertainty, consistent inflationary pressures, and well-documented environmental challenges. Against this backdrop, TNT-Coins provide a direct, legally defined property interest recorded on a transparent blockchain ledger.
This structure not only lessens dependence on counterparties but, when evaluated through maximum likelihood reasoning applied to the best available evidence, proves comparatively more resilient to inflation than any readily accessible alternative asset. By securing a stake in a fundamental, non-substitutable resource, TNT-Coins align with conditions that, under logical scrutiny and supported by historical and empirical observations, are most likely to preserve or even enhance real value over time.
Unlike options hinging on corporate performance or institutional intermediaries, TNT-Coins are grounded in a tangible, inherently necessary commodity. This approach is not speculative enthusiasm but a reasoned, evidence-based method of owning an asset whose worth does not rest on ephemeral market sentiment. Instead, it reflects enduring principles: scarcity, essentiality, and legally recognized property rights that together form a stable cornerstone for long-term economic security.
Why Water Is the Ultimate Asset
Water is fundamental to life and global stability. Unlike many commodities that can be substituted, refined, or replaced through technological advances, water’s essential role cannot be engineered away. Current data—declining freshwater reserves, increasing demand, and growing environmental stresses—indicates that water’s relative value will continue to rise over time. It is not only critical for human health, agriculture, and food production but also integral to manufacturing, industry, and sustainable economic development.
While energy may be sourced from wind, solar, or geothermal innovations, and metals can be substituted or recycled, no known technology can replace water’s unique qualities. Glacier-fed water, in particular, is notably scarce and verifiably pure—low in contaminants, naturally mineral-rich, and distinguished by its exceptional quality. In a world grappling with escalating scarcity, these specific water rights represent a form of enduring worth that is likely to surpass the long-term value of conventional currencies or speculative assets.
TNT-Coins: Tangible, Legally Secured Ownership
Each TNT-Coin represents a fractional claim to glacier-fed water rights in New Hampshire, USA. These rights are anchored in established U.S. property law, ensuring that your stake in the underlying resource is both tangible and legally enforceable. Unlike speculative tokens or shares that depend on corporate performance, TNT-Coins grant direct, documented property interests.
All transactions are recorded on a blockchain-based, immutable, and transparent ledger, enabling you to verify your holdings, review ownership history, and independently confirm the system’s integrity. This integration of legal frameworks with verifiable, state-of-the-art record-keeping provides enhanced reliability, clarity, and peace of mind—ensuring that your investment in TNT-Coins stands on a solid foundation of real assets and well-defined legal rights.
A Hedge Against Inflation and Market Volatility
As central banks continue to expand money supplies, historical patterns show that conventional currencies often lose purchasing power. Traditional investments seldom achieve genuine resilience against inflation’s steady erosion. By contrast, TNT-Coins, tied directly to a fundamental resource—freshwater—whose demand and scarcity are poised to outstrip inflationary pressures, offer a more robust safeguard.
Rather than depending on corporate profits or the shifting sentiments of financial markets, TNT-Coins anchor your investment in an asset supported by enduring global necessity. As freshwater reserves diminish and its value naturally appreciates, TNT-Coins provide a rational, evidence-based strategy for preserving wealth against the economic upheavals and volatility that undermine other asset classes.
Global Relevance and Cultural Significance
Across arid regions in the Middle East seeking assured water access, inflation-prone economies in need of assets independent of currency fluctuations, and sustainability-driven investors in Europe and Asia, TNT-Coins present a broadly applicable, empirically grounded solution. Water’s universal importance transcends borders and cultural distinctions. It is not simply another commodity; it is a cornerstone of human well-being, economic stability, and ethical stewardship for future generations.
More Reliable Than Digital Speculation and Commodities
More Reliable Than Bitcoin: Bitcoin’s value often hinges on market sentiment and hype. By contrast, TNT-Coins derive their worth from glacier-fed water—a vital, irreplaceable resource whose significance does not shift with investor moods.
More Essential Than Gold: While gold can hedge against inflation, it cannot sustain life. Water, on the other hand, remains an indispensable necessity for human survival and economic productivity, offering enduring worth regardless of evolving technologies or shifting economic landscapes.
Safer Than Stablecoins: Stablecoins rest on confidence in often-opaque reserves. In contrast, TNT-Coins are backed by transparent property rights and a legally robust framework. The underlying asset—crystal-clear, glacier-fed water rights—is directly verifiable, minimizing dependence on external assurances and reducing uncertainty about the asset’s true value.
Flexibility and Control for Investors
TNT-Coins provide the flexibility to respond as circumstances evolve. Should the time come to consider water extraction, you hold explicit, legally recognized rights under U.S. law. By majority vote among TNT-Coin holders, shareholders may decide whether and when to commence extraction. In such a scenario, the majority of TNT-Coin owners can collectively determine how best to utilize their water rights:
Receive Physical Water: Access deliveries of glacier-fed water, elevating daily life through a resource of unmatched purity and taste.
Earn Dividends: Should the majority opt for commercial extraction, shareholders can share in resulting revenues, ensuring that any income reflects a democratic, owner-driven decision process.
Influence the Future: Your vote and voice actively shape the direction of water extraction strategies and long-term plans, fostering a participatory model that respects each stakeholder’s perspective.
Transparency, Compliance, and Accountability
TNT-Coins are fully compliant with U.S. property law and adhere to SEC no-action letter guidelines, forming a robust, ethically transparent framework. We strongly encourage you to conduct independent verification and consult with qualified legal and financial advisors before making any decisions. By ensuring every step meets strict legal and regulatory standards, TNT-Coins maintain a foundation of trust, clarity, and accountability.
Your Rational Path to Essential Security
By investing in TNT-Coins, you are not pursuing speculative gains. Instead, you are securing a stake in one of humanity’s most essential resources. This approach stands in contrast to marketing hype or hidden complexities, offering both logical clarity and legal integrity. Importantly, TNT-Coins require no leap of faith: every claim can be independently verified.
To confirm our ownership and the validity of our resource rights:
Property Records: Review official land records demonstrating that we own the freshwater source at 10 Farr Road in Pittsburgh, New Hampshire.
Licensing Confirmation: Check directly with the New Hampshire licensing board for evidence of the valid water extraction license associated with this well site.
These verifications enable you to confirm each aspect of your investment’s foundation. In doing so, TNT-Coins deliver a rational, evidence-supported path to long-term security—rooted in a tangible resource that the world cannot afford to replace.
Conclusion: Own the Resource That Defines Life
In an environment of constant change and economic uncertainty, TNT-Coins offer you the opportunity to secure a stake in a fundamentally indispensable resource. Their value is anchored in tangible, legally recognized property rights and inflation-resistant fundamentals, rather than speculative hopes or shifting market sentiment.
We encourage you to verify every claim. Explore the TNT-Coins website, request detailed derivations, and consult independent experts. Ask the hard questions—our framework is designed to withstand rigorous scrutiny. Each step you take toward TNT-Coins rests on logical reasoning, robust legal underpinnings, and a resource no future technology or innovation can supplant.
By choosing TNT-Coins, you are not merely acquiring an asset; you are aligning with enduring principles of health, sustainability, and genuine long-term security.
What is the Market Value of TNT-Water Coins?
For rational investors who value simplicity and prefer enjoying life rather than constantly managing portfolios, active investing is simply not an option. This is not an opinion, but an immutable fact—one as unassailable as the Earth’s roughly spherical shape or the arithmetic truth that 2+2=4, assuming a sufficient number of countable objects.
The certainty that active investing guarantees losses for retail investors does not rest on a contested theory. Instead, it is anchored in a fundamental accounting identity—an arithmetic truth that cannot be false. This fact is unassailable, independent of empirical testing, and as permanent as the foundational truths of mathematics.
If you have not read Bill Sharpe’s 1991 short paper, The Arithmetic of Active Management, it is a must-read for any investor. In this seminal work, the Nobel Prize-winning economist and inventor of the Capital Asset Pricing Model (CAPM) demonstrates a mathematical certainty: all investors collectively hold the market portfolio M by definition.
Passive Investors: By holding M, passive investors achieve returns equal to M, minus minimal fees—often just a few basis points per year for standard index funds.
Active Investors: By definition, active investors deviate from M. Collectively, their returns must underperform M by the sum of their costs—transaction fees, research expenses, taxes, and other frictional trading costs.
This is not an empirical guess or a hypothesis. It is a straightforward arithmetic fact ensuring that, after costs, active investing is a negative-sum game for the average retail investor.
The situation worsens when you consider the inherent informational disadvantage that retail investors face against better-informed institutional players. Large institutions possess superior data, faster execution capabilities, and advanced predictive models, placing retail traders at a systemic disadvantage.
This disparity matters because active trading is not just negative-sum after costs; it is also zero-sum before costs. For any active trader to outperform the market by even a penny, another active trader must underperform by that exact amount. This zero-sum nature arises from simple arithmetic: as a group, all active traders together still hold the entire market portfolio.
Consider the popular platform Robinhood, which offers “free” trading. Robinhood can afford this because it sells “retail order flow” to sophisticated hedge funds like Citadel. The less-informed retail investor is not competing against another novice, but against one of the most resourceful, well-informed entities on Wall Street. Under such conditions, a less-informed trader’s odds of making money on a stock trade are negligible—slimmer, indeed, than beating John McEnroe at tennis during his prime.
Overwhelming evidence supports this reality. From the success of John Bogle’s Vanguard funds—where over half of all invested money now sits in passive index strategies—to decades of data showing that mutual funds and hedge funds collectively fail to outperform the market, the conclusion is clear. Hedge funds not only pay for “dumb retail flow” but consistently profit from it, capturing returns directly from less-informed traders.
Given these facts, no rational retail investor would choose active trading. Passive investing emerges as the logical path. Having established this foundational truth, we now turn our attention to an alternative asset class: fractional water rights. Specifically, we will consider how fractional water rights—such as TNT-Coins—could fit into a passive asset allocation strategy. We will compare their risk and return characteristics to stocks, bonds, real estate, commodities, and various stores of value, including gold, cryptocurrencies, and stablecoins. In short, we will explore whether fractional water rights can provide a stable, inflation-resistant foundation that complements a rational, passive investment approach.
Why Invest at All?
Investing involves sacrificing current purchasing power—measured by the unit-of-account role of money—to secure greater purchasing power in the future. Accordingly, when selecting investments, all else being equal, we favor those with more certain future cash flows over those offering less certainty. This preference is fundamentally about ensuring that the wealth we defer using today will be worth more in real terms tomorrow.
Focusing on real (inflation-adjusted) returns rather than nominal returns is crucial. What ultimately matters is not the nominal dividends or interest we receive, but whether the future purchasing power of our investment income exceeds the purchasing power we forego today. In simpler terms, the central purpose of investing is to enhance future consumption—not merely to hold assets with abstract nominal gains.
Consider that most traditional investments (apart from certain inflation-oriented options like gold, silver, or specific cryptocurrencies) generate income or cash flows denominated in fiat currencies, such as the U.S. dollar. Empirical evidence consistently shows that investments with more predictable, lower-risk cash flows—like high-quality government bonds—offer lower yields, while assets with riskier, less certain cash flows must compensate investors with higher yields to attract capital.
This explains why corporate bonds universally yield more than government bonds, and why the earnings yield on the S&P 500 correlates strongly with bond yields. Markets tend to normalize risk-adjusted returns, meaning that after accounting for uncertainty, most alternatives provide roughly comparable expected outcomes.
Given these dynamics, where do fractional water rights fit? Beyond serving as potential inflation hedges—much like gold, silver, or certain digital assets—fractional water rights might also function as income-producing assets, akin to stocks or bonds under certain conditions. How do they measure up in terms of risk and return against these established categories? The answer involves assessing their inherent stability, the fundamental necessity of water, and the long-term security of legally defined property interests that may generate stable, inflation-resistant cash flows or preserve value over time.
In the following sections, we explore how fractional ownership of glacier-fed water rights can complement a rational, passive investment approach. We will compare their characteristics to those of stocks, bonds, real estate, commodities, and other alternative assets, aiming to understand their place in a well-balanced, forward-looking portfolio.
The Asset
The asset offered for sale is an existing, licensed water source located at 10 Farr Road, Pittsburgh, NH. This source is licensed by the state to extract 360,000 gallons of glacier-fed, pristine spring water per day, in perpetuity. It’s important to note that while no liquid market currently exists for this type of water (unlike carbon credit markets, for example), companies such as Poland Spring (Nestlé) and other water bottlers have historically established private, contract-based agreements with landowners for comparable water sources.
Illustrative Valuation Considerations
Let’s consider a rough, illustrative estimate: assume that each extracted gallon could be sold at approximately 4 cents per gallon per day (subject to further validation and investor verification). At this rate, one gallon extracted daily across an entire year generates about $15 per year (4 cents x 365 days ≈ $14.60, rounded up to $15). Note that this is a wholesaler’s price; the retail price for a basic, no-name gallon of spring water at a large retailer often exceeds $1.
How do we conceptually value this perpetual stream of water? Standard financial models for inflation-hedged assets suggest that commodities whose relative purchasing power is expected to keep pace with or exceed general inflation rates can command higher valuation multiples. In our case, the reasoning is as follows:
Perpetual Availability: The water source is licensed to produce a fixed amount of water indefinitely.
Inflation Hedge Through Relative Purchasing Power: Given increasing scarcity and demand, the relative price of pristine glacier-fed water is likely to at least keep pace with inflation, if not exceed it, thereby preserving or enhancing its real value over time.
By applying a hypothetical multiple—a “water-right” price-to-earnings (P/E) ratio of about 50—to the annual “cash flow” derived from one gallon of water, we are conceptually illustrating how stable, inflation-hedged assets can command substantial valuation multiples. In our scenario, each gallon is assumed to generate $15 per year indefinitely, and we posit that the real value of water does not diminish with inflation. Under these conditions, assigning a P/E of 50 implies a notional valuation of $750 ($15 x 50) per gallon of annual extraction.
To be clear, while referencing a P/E ratio and perpetual bond analogy suggests ties to standard financial theory, this example primarily serves as a heuristic. Consider that long-term U.S. Treasury Inflation-Protected Securities (TIPS) currently yield around 2%. A perpetual income stream matched to that yield—if viewed as a perfect inflation hedge—would indeed justify a price roughly equal to the annual payment divided by the yield. Thus, $15 per year at a 2% real yield corresponds to a $750 value. This parallels the reasoning behind applying a “P/E of 50” (since a 2% yield equates to a 50x multiple) to a stable, inflation-adjusted flow of value.
Of course, actual market valuations would depend on direct, verifiable data—contractual agreements with bottlers or other users, proven market demand, and investor due diligence. The key point is that water’s unique position as a non-substitutable, inflation-resistant resource supports the conceptual plausibility of such valuation multiples.
This figure, while illustrative, is a ballpark estimate and should be regarded as a preliminary reference. Although current cash flow may be limited until formal extraction and distribution arrangements are established, glacier-fed spring water stands apart. Unlike synthetic methods that yield clean but not equivalently mineral-rich or pure water, authentic glacier-fed spring water’s exceptional quality can command a market premium. Over time, as demand intensifies and freshwater resources remain finite, the argument for stable, inflation-hedged valuations becomes more compelling for a unique, irreplicable commodity like glacier-fed spring water.
Supply Constraints and Long-Term Advantages
As freshwater demand grows due to population increases, climate change, and industrial requirements, and as transportation costs for water continue to decline, the scarcity of natural, high-quality sources like ours becomes more pronounced. This inelasticity of supply makes such water rights a potentially more effective long-term inflation hedge than many other commodities or assets. Unlike energy or metals that can be substituted, water remains uniquely essential and fundamentally irreplaceable, positioning glacier-fed water rights at the pinnacle of inflation-resistant, fundamental-value assets.
ADDITIONAL PITCH: FRESHWATER RIGHTS—THE ASSET THAT TRANSCENDS MARKET VOLATILITY
Subject: The Enduring Value of Freshwater Rights—A More Reliable Asset Than Any Currency or Crypto
Dear Visionary Investor,
In an era where market sentiments swing unpredictably and once-stable assets falter, one resource remains beyond dispute: clean, abundant freshwater. Unlike stocks, cryptocurrencies, or even stablecoins—all of which depend on trust, sentiment, or underlying reserves—freshwater rights anchor your wealth in a fundamental, non-negotiable necessity.
Why Freshwater Rights Stand Apart
Universally Essential: The demand for water is as old as civilization itself. Unlike most commodities—whose value hinges on trends or opinions—water’s role is tied directly to life, health, and infrastructure. Every community, industry, and government recognizes its critical importance.
Robust Against Inflation and Scarcity: As global inflation challenges purchasing power, freshwater retains or even increases its relative value. It cannot be replaced by technology, engineered away, or made obsolete. Scarcity intensifies its importance, ensuring that water rights inherently gain value as other assets suffer from inflation’s erosive effects.
Unmatched by Gold, Crypto, or Stablecoins:
More Vital Than Gold: Gold can store value, but it does not sustain life. Water is indispensable for every function of human society.
More Reliable Than Crypto: Cryptocurrencies depend on market sentiment and can experience extreme volatility. Water rights, by contrast, are grounded in physical reality, insulating them from speculative frenzies.
More Certain Than Stablecoins: Stablecoins rely on trust in their custodial reserves and can face regulatory or liquidity risks. Water rights rest on tangible property, governed by longstanding legal frameworks, beyond the reach of fleeting market anxieties.
Predictable, Inflation-Resistant Returns
By leasing freshwater rights to agricultural, industrial, or municipal clients, you can earn stable, inflation-adjusted revenues. Unlike assets that waver with economic cycles, freshwater’s essential role and finite supply help preserve its purchasing power over time. This stable foundation means your stake in freshwater rights need not fear the uncertainties of market sentiment or speculative bubbles.
A Hedge Against All Competing Investments
As demand for water grows—spurred by population increases, industrial needs, and environmental shifts—investors who secure freshwater rights early stand to benefit as prices rise. Public policies and institutional funds increasingly recognize water’s central importance, underscoring its enduring worth.
A Logical Choice for the Future
Freshwater is not a gamble. It is the foundation of global stability, immune to short-term sentiment and speculation. Owning freshwater rights is not merely a financial decision; it is an alignment with global necessity and enduring value.
Take Action Today
Visit [Your Website] or contact our advisors to learn more about how fractional freshwater rights can fortify your portfolio. Invest in water. Invest in life. Invest in an asset whose value transcends market volatility and economic upheavals.
Sincerely,
HH Research and Management, LLLP
This Isn’t Just an Investment—It’s a Legacy
Freshwater rights protect the future of your family, community, and the world at large. By choosing to invest in what humanity cannot replace, you secure more than returns—you secure a foundation for future generations.
P.S.
SEC No-Action Letter Request
Office of Chief Counsel
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: Request for No-Action Letter Regarding Fractional Ownership of Water Rights
Dear Sir or Madam:
On behalf of HH Research and Management, LLLP (the “Company”), we respectfully request that the staff of the U.S. Securities and Exchange Commission (“SEC”) confirm that it will not recommend enforcement action under the Securities Act of 1933, the Securities Exchange Act of 1934, or any other federal securities laws in connection with the Company’s proposed issuance and subsequent transfer of fractional ownership interests in specific water rights.
Core Assertion:
These fractional interests represent tangible, state-law-governed property rights—specifically, fractionalized claims to freshwater resources. They do not satisfy any of the criteria commonly used to define a “security” under federal law. Our approach aligns with longstanding legal precedent and recent SEC guidance, including no-action letters such as TurnKey Jet, Inc. (April 3, 2019) and Pocketful of Quarters, Inc. (July 25, 2019), which clarify when digitally represented, fractionalized assets lie outside the securities framework.
I. Legal and Conceptual Framework
Under SEC v. W.J. Howey Co., 328 U.S. 293 (1946), an instrument must meet three conditions to be considered a security:
An investment of money,
In a common enterprise,
With an expectation of profits primarily from the efforts of others.
The Company’s fractionalized water rights (“TNT-Coins”) meet none of these conditions:
No Common Enterprise:
Fractional owners hold pro-rata interests in a tangible, static asset—water rights—without pooling their interests into a profit-oriented venture. They stand as individual property holders, not participants in a unified entrepreneurial scheme.No Reliance on Managerial Efforts for Profit:
The value of these water rights does not hinge on any promoter’s or manager’s future actions. Historically, direct interests in natural resources that are not dependent on managerial efforts do not constitute securities. See SEC v. C.M. Joiner Leasing Corp., 320 U.S. 344 (1943); Woodward v. Terracor, 574 F.2d 1023 (10th Cir. 1978).No Expectation of Profits from Enterprise Activities:
TNT-Coins promise no dividends, returns on investment, or speculative appreciation. They are analogous to mineral or timber rights—assets valuable due to their inherent nature, not the entrepreneurial activities of others. United Housing Foundation, Inc. v. Forman, 421 U.S. 837 (1975), confirms that mere property interests, devoid of profit expectations from third-party efforts, fall outside the definition of securities.
II. Nature of the Asset: Fractional Water Rights
The Company holds exclusive water rights associated with a property in Pittsburgh, New Hampshire. These rights, like mineral or timber entitlements, are discrete legal interests recognized under state property law. See Rodriguez v. Banco Cent. Corp., 990 F.2d 7 (1st Cir. 1993). Currently, no extraction occurs and no revenue is generated. The Company’s role is passive, providing a stable structure to hold and transfer these rights. Nothing in this arrangement suggests the entrepreneurial or profit-driven elements needed to transform property interests into securities.
III. Alignment with Recent SEC No-Action Precedents
Our stance aligns with recent SEC no-action letters that clarify the status of digitally represented and fractionalized assets:
TurnKey Jet, Inc. (April 3, 2019): The SEC concluded that tokens were not securities because they offered immediate utility, were not marketed for profit, and did not depend on managerial efforts. Similarly, TNT-Coins serve as direct records of ownership, not speculative instruments.
Pocketful of Quarters, Inc. (July 25, 2019): The SEC found no enforcement action was warranted because the tokens conveyed no expectation of profits and served as a medium within a closed system. Similarly, TNT-Coins function as a transparent registry of property claims without inducing profit-driven incentives.
These precedents follow the SEC’s FinHub guidance, emphasizing that the absence of profit expectations and reliance on managerial efforts are key factors in excluding digital assets from securities classification.
IV. Technological Medium: TNT-Coins and Blockchain
TNT-Coins utilize blockchain technology for recording ownership. This medium enhances transparency and security but does not change the asset’s legal character. See Noa v. Key Futures, Inc., 638 F.2d 77 (9th Cir. 1980).
Under ESIGN and UETA, electronic records and signatures carry the same legal weight as their traditional counterparts. Smart contracts function as modern equivalents of deeds or private agreements, improving reliability without introducing securities-like features.
V. Marketing Practices and Public Disclosures
The Company will ensure all marketing materials:
Present TNT-Coins strictly as fractional property interests in water rights.
Omit references to ROI, dividends, or profit, thereby avoiding any implication of speculative returns.
Emphasize enforceability under state property law rather than investment potential.
This approach ensures no purchaser is misled into believing TNT-Coins represent a common enterprise or a vehicle for profit generation.
VI. Future Commercial Activities and Securities Considerations
If circumstances change—for instance, if water extraction begins and profit distributions arise—such developments might create an expectation of returns from managerial efforts. In that scenario, the Company will reevaluate its regulatory obligations. Before undertaking any activity that could bring TNT-Coins within the scope of securities laws, we commit to registering the offering or obtaining the necessary approvals (e.g., filing an S-1 registration statement). At present, TNT-Coins remain property-based interests, not instruments tied to profit-making endeavors.
VII. Conclusion and Request for No-Action Relief
Given the facts and relevant case law:
TNT-Coins represent fractional ownership of tangible water rights, historically and legally recognized as property interests rather than securities.
They fail the Howey test and align with recent no-action letters (e.g., TurnKey Jet, Pocketful of Quarters) that confirm non-profit-seeking, utility- or property-based digital assets do not constitute securities.
The Company remains prepared to comply with securities regulations should future activities alter TNT-Coins’ character to resemble investment contracts.
Accordingly, the Company respectfully requests that the SEC staff confirm it will not recommend enforcement action under federal securities laws for the proposed issuance and transfer of TNT-Coins. This conclusion follows logically and legally from the asset’s static, tangible nature, the absence of profit-driven components, and established precedents affirming the property-law status of such interests. See Tcherepnin v. Knight, 389 U.S. 332 (1967).
Sincerely,
[Your Name]
[Your Title]
HH Research and Management, LLLP
[Contact Information]
In a world overflowing with compromises, there exists a rare treasure untouched by human interference—a gift from glaciers that have shaped the Earth for millennia. This treasure is not just water—it is life itself, distilled into its purest, most natural form. And for a select few, it is a treasure they can own.
Welcome to TNT-Coins, your gateway to the world’s most pristine glacier-fed spring water. Sustainably sourced from a protected reservoir in New Hampshire, this is not just water; it is nature’s perfection, delivered directly to you or shared with the world’s most discerning clientele.
The Water That Elevates Life
Not all water is created equal. While desalination and industrial filtration may produce “drinkable” water, they cannot replicate the purity, natural balance, or life-giving minerals of true glacier-fed spring water.
The Difference is in the Source:
Our water is naturally filtered over centuries through glacier sediment and pristine rock formations. The result? A liquid as pure as the snow it once was, rich in minerals that nourish the body and invigorate the soul.
Unmatched Purity: Free from contaminants, pollutants, and processing.
Naturally Balanced Minerals: Supporting optimal hydration, cellular health, and longevity.
Crisp, Fresh Taste: A sensory experience that elevates every sip.
Studies suggest that high-quality, mineral-rich water can improve hydration at the cellular level, support organ function, and enhance overall vitality. TNT-Coins allow you to secure not just an investment, but a resource that enhances life itself.
A Luxury Product for a Discerning Few
True luxury is about more than exclusivity—it is about owning something irreplaceable. In a world where water tables are depleting and natural sources are disappearing, glacier-fed spring water has become the ultimate symbol of prestige and sophistication.
TNT-Coins Make It Yours:
When you invest in TNT-Coins, you own more than a share of water rights. You own a stake in one of the last remaining sources of truly untouched water, sustainably producing 360,000 gallons daily in perpetuity.
A Product That Defines a Lifestyle:
For the Home: Receive direct deliveries of glacier-fed water, elevating your family’s hydration to a new standard of purity.
For Entertaining: Serve a product so rare and refined that it transforms any occasion into an unforgettable experience.
For Legacy: Pass down ownership of this finite treasure to future generations, ensuring their access to life’s purest resource.
Own What Cannot Be Replaced
The world may produce more water through technology, but it cannot create what nature perfected over millennia. Desalinated water and industrial processes may quench thirst, but they lack the vitality, flavor, and balance of true spring water. In a world of “good enough,” TNT-Coins give you access to the best water nature has to offer.
A Timeless Investment:
Sustainably Managed: The reservoir is protected under strict state regulations to ensure it remains renewable forever.
Blockchain Verified: Every share is recorded transparently, guaranteeing your ownership is secure.
Dual Benefits: Enjoy the choice of physical water deliveries or dividends from global sales.
For Health, For Life, For Legacy
Water is the essence of life. It fuels every cell, supports every system, and connects us to the natural world. TNT-Coins represent a unique opportunity to own not just any water, but the finest water on Earth. By drinking it, you nurture your body. By owning it, you secure your future.
Life-Enhancing Benefits of Glacier-Fed Spring Water:
Supports Cellular Health: Naturally balanced minerals improve hydration, promoting energy and longevity.
Purifies the Body: Free from impurities, it enhances detoxification and nutrient absorption.
Elevates the Mind: The crisp, clean taste refreshes the senses, transforming a daily necessity into a moment of luxury.
This isn’t just water—it’s an investment in vitality. While others settle for processed or desalinated alternatives, TNT-Coin holders access a product that rejuvenates the body and elevates the spirit.
The Exclusive Nature of TNT-Coins
By 2044, clean, natural water will be the world’s most coveted resource. But even in a world of scarcity, glacier-fed water will remain rare, sustainable, and luxurious. TNT-Coins ensure that this treasure is not only accessible—it is yours to own.
Why TNT-Coins Are Different:
1. Ownership That Lasts Forever:
Each TNT-Coin represents a fractional share of the reservoir, tied to its perpetual daily production of 360,000 gallons.
2. Luxury With Transparency:
Blockchain technology ensures every decision and transaction is visible, fostering trust and accountability.
3. Sustainability and Regulation:
Strict oversight by the New Hampshire licensing board guarantees that extraction remains sustainable and environmentally sound.
4. Choice of Benefits:
Receive physical deliveries of the world’s cleanest water.
Earn dividends from the sale of this premium product to luxury markets.
Secure Your Share Today
There are only so many TNT-Coins. As the world’s demand for premium water grows, this opportunity becomes rarer by the day. Don’t just drink life’s purest water—own it.
Learn More:
Visit tnt.money or contact [Contact Information] to reserve your TNT-Coins today.
this is how you tell if this is the correct version, the one to publish. it has the marketing plan. This is not part of the web site, Dec 19, 2024.
Refined Marketing Plan for TNT-Coins
Core Objective:
Position TNT-Coins as a credible, property-based asset class anchored in legally enforceable freshwater rights. Emphasize non-security status, inflation resilience, and ESG alignment to appeal to responsible, long-term stakeholders. Leverage the investor letter’s factual, reasoned tone to attract institutions, fintech platforms, and exchanges that value regulatory clarity and stable assets.
Phase 1: Foundational Setup (2 Months)
Key Deliverables:
Compliance and Documentation:
Finalize the SEC no-action letter reference and highlight its key points in a succinct compliance overview.
Prepare a comprehensive white paper articulating TNT-Coins’ property-law basis, stable nature, and ESG benefits. Include a direct link to the investor letter for prospective partners to see transparent, rational reasoning.
Create a concise compliance FAQ and a “TNT-Coins Essentials” document, emphasizing no speculative language, no ROI promises, and the formal property rights structure.
Marketing Collateral:
Refine the investor letter into an institutional-grade pitch deck, stressing TNT-Coins’ stable, inflation-resistant asset profile.
Develop educational materials (infographics, short explainer videos) explaining TNT-Coins in plain language: fractional water rights, legally documented, and verifiable by independent record checks.
Produce co-branding templates for future partner campaigns that maintain factual, neutral language and avoid profit-based marketing.
Technical Preparation:
Complete APIs and integration guides for exchanges and fintech platforms.
Ensure TNT-Coins’ user interfaces are intuitive, secure, and fully auditable.
Conduct internal training for business development and compliance teams to guarantee consistent, informed messaging.
Rationale:
This groundwork ensures that when we approach partners, we come prepared with robust documentation, a proven legal stance (no-action letter), and accessible educational materials. Every piece reinforces the narrative that TNT-Coins are straightforward property interests, not speculative securities.
Phase 2: Initial Outreach—Crypto Exchanges (First 3 Months)
Priority Targets:
Coinbase (USA/Global): Known for regulatory compliance and institutional offerings.
Kraken (USA/Global): Emphasizes trust, user security, and regulatory clarity.
Binance (Global): Broad global reach, but approach after establishing credentials with more compliance-focused exchanges.
KuCoin, Gate.io (Asia/Global): Potential for later-stage listings once credibility is established.
Strategy:
Start with Coinbase and Kraken, which prioritize legal clarity and non-security assets. These platforms understand U.S. regulatory nuances and will appreciate the no-action letter and property-based narrative.
Present TNT-Coins as the “next category” of stable digital assets: real property rights recorded on blockchain, immune to speculative hype.
Contact Methods and Messaging:
Use LinkedIn to identify Business Development and Listing Managers.
Send a tailored outreach email referencing the no-action letter and emphasizing that TNT-Coins are factual property interests. Attach the investor letter as a transparent demonstration of TNT-Coins’ rational, evidence-based positioning.
Offer a brief call to discuss technical integration and highlight TNT-Coins’ stable semantics, legal certainty, and ESG story.
Follow-Up:
If no response in 5 business days, send a gentle reminder.
Offer to host a short Q&A or webinar for their team, focusing on compliance and risk mitigation—an angle these exchanges value.
Rationale:
By starting with compliance-oriented exchanges, we build credibility and trust. Listing on a recognized, regulation-conscious platform sets a precedent that can facilitate future listings on other exchanges.
Phase 3: Outreach to Banks and Fintech Platforms (Months 3-6)
Priority Targets:
JP Morgan, Goldman Sachs (Institutional): Focus on stability, legal integrity, and inflation resilience for their alternative assets divisions.
Revolut, Robinhood, SoFi (Retail Fintech): Emphasize simplicity, ESG appeal, and easy adoption for a younger, socially conscious audience seeking non-traditional safe havens.
Strategy:
Begin with JP Morgan and Goldman Sachs for institutional endorsement. Their due diligence requires a credible legal basis and a clear value proposition. TNT-Coins’ non-speculative, factual narrative aligns with their need for stable, long-term solutions.
Once established with institutional endorsements, approach retail fintechs highlighting that TNT-Coins are an easy-to-understand, verifiable, stable resource holding—ideal for users wary of market volatility.
Contact Methods and Messaging:
Reach out to heads of alternative investments or product innovation teams via professional networks or mutual industry contacts.
Email Template: Introduce TNT-Coins as fractional claims to a tangible, inflation-proof resource—freshwater rights. Attach the investor letter and the no-action letter summary to quickly convey regulatory clarity and non-security status.
Host private briefings or online demos showing how TNT-Coins integrate seamlessly into existing product offerings.
Follow-Up and Relationship Building:
If no response in 7 business days, follow up with a short video demonstration or invite them to a private online seminar with ESG experts and legal advisors.
Offer ongoing support, technical guidance, and co-marketing opportunities once integrated.
Rationale:
Banks and fintechs want sustainable, credible assets. Showing TNT-Coins as legally certain, stable, and ESG-compliant addresses their key concerns. Institutional acceptance paves the way for fintech distribution and broader adoption.
Phase 4: Joint Campaigns and Long-Term Education (4-6 Months+)
Objectives:
Leverage early integrations or listings to launch co-branded campaigns that highlight TNT-Coins’ unique, compliance-first story.
Conduct educational webinars, blog series, and social media Q&As with partner platforms to deepen market understanding of TNT-Coins’ non-speculative, inflation-resistant character.
Campaign Tactics:
Co-Branded Content:
Joint blog posts with exchanges explaining why TNT-Coins are a “new category” of property-based digital assets.
Podcasts or short interviews featuring legal experts affirming TNT-Coins’ property law status.
Educational Webinars:
Invite respected financial analysts or ESG specialists for panel discussions.
Present the no-action letter context, reassure that TNT-Coins are not subject to securities regulations, and highlight independent verification steps.
Social Media and Targeted Ads:
LinkedIn campaigns targeting institutional investors with factual posts linking to the investor letter.
Short, factual YouTube explainers (avoiding any hype), clarifying TNT-Coins’ stable role in portfolios.
Retail Outreach via Fintechs:
Insert short educational “modules” in fintech apps explaining TNT-Coins as fractional property rights.
Provide step-by-step guides and FAQs within partner platforms to ensure user understanding.
Monitoring and Analytics:
Track engagement (click-through rates, webinar attendance, average viewing time) to refine messaging.
Collect feedback from partners and their user bases to continuously enhance clarity and dispel any doubts about TNT-Coins’ nature.
Implementation Tools and Timeline
Key Tools:
LinkedIn Sales Navigator: Identify and reach decision-makers at target institutions.
Professional Introductions & Industry Events: Secure warm leads and credibility.
Analytics Dashboards: Monitor outreach performance, adjust strategies as needed.
Timeline:
Phase
Duration
Key Actions
1: Prep
2 months
Finalize compliance docs, white paper, training
2: Exchanges
3 months
Submit listing proposals, follow up, Zoom Q&As
3: Banks/Fintechs
3-4 months
Present stable property interests, integrate solutions
4: Joint Campaigns
4-6 months+
Co-branded content, webinars, social outreach
Conclusion:
This refined marketing plan builds on the reasoned tone of the investor letter and the factual, legally secure position of TNT-Coins. By targeting compliance-focused exchanges first, then established financial institutions, and finally fintech platforms, we create a pipeline of credibility. Every communication emphasizes TNT-Coins’ non-speculative, tangible nature, anchored by property law and verified by no-action and investor letters. The end goal: firmly entrench TNT-Coins as a recognized, stable, and inflation-resistant property interest in the evolving digital asset landscape.