Achieving the equivalent outcome of token distribution and investor funding of developer efforts via a different mechanism is effectively synonymous with looking past form to function (i.e. "economic reality") to me, but I'm neither a prosecutor, nor a judge, nor a jury.
I’m not clear if you also intended your reasoning as quoted to also apply to the proposed idea wherein a company could take investment in exchange for shares which are securities. Then launch a decentralized ledger with a pre-mine but never sell those pre-mined tokens until it had completed all its managerial efforts. It is suggested that the said tokens would not be investment securities when sold, because there is no ongoing development by the issuer after an investor buys them. So it side-steps the Howey Test. Of course the shares remain securities, but the tokens are not. The company can then distribute the dividends to the shareholders. It is a different structure, because the investors in the shares get dividend income instead of capital gains. The investors in the shares never receive tokens.
I had no such intent.
I'm pretty sure we have discussed before that if the developer can really stop ongoing development (also whatever other "efforts") and have the platform succeed then it seems plausible. That's a big 'if' though.
For example, in the case of Steem, there is an enormous amount that remains to be done if the platform has any chance of attracting a much larger user base, and no one seems all that interested in doing it besides the original developer. So I think your suggestion, while quite possibly legal, would likely fail in the market for practical reasons in this particular case (given the current state of the platform, etc.). I guess maybe one could imagine that the original developers step away in 10-20 years (or more) and then investors get their return? Seems a bit of a stretch, but possible. It's even slower liquidity than VC.