This is the SEC definition and in my opinion this is exactly what you are offering
The term equity security is hereby defined to include any stock or similar security, certificate of interest or participation in any profit sharing agreement, preorganization certificate or subscription, transferable share, voting trust certificate or certificate of deposit for an equity security, limited partnership
That is not even close to what the Legends Room is doing and I cannot understand how you could view it that way especially after reading that. The legal team has already been over this.
If you define this as a security you must view a car, a house, a boat, a Gym membership, a private club membership (which I have), and many other things as a security. That is just ridiculous.