I do not see you state the name of the law firm you paid to provide you legal advice. Rather you named a the law firms that composed the working document you linked to. I am asking for the name of the law firm that has advised you that you are not subject to the Howey test. If you wish to decline to provide it, that is your prerogative. I don't believe you have consulted any law firm. I believe you are bullshitting.

Sorry. I am not the altcoin police. Do what ever you want. I guess some people have a criminal mindset and wish for jail time.