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Entries by Sam Miller

Blockchain utility tokens: throwing the baby out with the (securities regulation) bathwater?

Insight Sam Miller Sam Miller · August 07, 2019
The digital asset roadshow continued this last week with The July 30th Senate Banking, Housing and Urban Affairs Committee hearing on virtual currencies and online market places, convened to hear “…how Congress should regulate digital currencies and blockchain technologies in the online financial market…”. Just a

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Facebook’s Libra, cryptocurrency and the Token Taxonomy Act: much needed blockchain innovation reform or fear of the giants?

Insight Sam Miller Sam Miller · July 24, 2019
Although Capitol Hill and not Mount Olympus, one could be forgiven for mistaking the Facebook Libra co-creator and Calibra CEO, David Marcus’s July 17th, 2019 testimony before the House Committee on Financial Services for a page out of Greek mythology. If one were to be dramatic, one could say that this was no more an exercise in regulatory

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The End of Fine Art Experts? A Few Lessons Learned From The Recent Agnes Martin Litigation

Insight Sam Miller Sam Miller · July 18, 2019
Picture this. The Picasso that always hung in your childhood livingroom; a gift to your grandfather from a grateful gallery owner, liberated as your grandfather’s 264th Infantry Regiment worked its way through France in the dying days of World War II. As the years passed, and family generations moved on, the family puts the Picasso up for

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Warhol, Prince and a Case of Vanity Perhaps Not-So-Fair: Even Fine Art Colossuses Need Inspiration

Insight Sam Miller Sam Miller · July 10, 2019
What could be more flattering than arguably the greatest pop fine artist of all time copying your work? Well fine art photographer, Lynn Goldsmith, apparently wasn’t all too flattered when she saw Andy Warhol’s ‘Prince Series’ (of the singer, once known as “The Artist Formerly Known As Prince” or that

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FinCEN, Tokens and Money Transmission: A Redux

Insight Sam Miller Sam Miller · June 03, 2019
We wrote recently about money transmitters and the state of regulation for token-driven businesses. On May 9th, 2019, the Financial Crimes Enforcement Network (FinCEN) put a number of these questions to rest in its guidance entitled “Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual

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Blockchain and Money Transmission: A New Horizon for Token-Driven Startups?

Insight Sam Miller Sam Miller · April 09, 2019
Tokens, security tokens, cryptocurrency, or however you wish to define the digital asset which distributed ledger technology has now allowed us to pull from ether, puts issuers and exchangers of this value within the cross-hairs of both Federal and State money transmitter regulation. The question becomes then whether token-driven blockchain

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Is There any Utility Left in Utility Tokens? The SEC Speaks

Insight Sam Miller Sam Miller · April 08, 2019
Unusually expressive on this topic, the Securities and Exchange Commission released two publications April 3rd, the first its “Framework for ‘Investment Contract’ Analysis of Digital Assets”, and the second a ‘no-action letter’ in favor of TurnKey Jet, Inc. Both were hailed as milestones for the SEC in dealing

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Rimon Law Welcomes Corporate Attorney Sam Miller as Partner in its Los Angeles Office

News Sam Miller Sam Miller · April 02, 2019
Los Angeles- Rimon Law welcomes corporate finance Partner Sam Miller to the firm’s Los Angeles office. Mr. Miller joins Rimon from Arent Fox, where he was a member of its corporate finance team and co-head of its Blockchain Group. Mr. Miller’s practice is focused on Mergers & Acquisitions (M&A) and corporate finance, with

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