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Call it how you want penalty,bonus it doesn't matter 15m of ICN are for free it costed 0$ in real cash.
Someone can dump them for 10% of ICO value and he is still with profit from that.
While $ investor selling below 22000 sat will take loss.
We will see when trading will start how it will work.
Lisk used the same ICO model and we didn't see such an impact on the price. Why would it be different this time?