Have PoW blockchains become less resource intensive?

More than a couple of people have asked for an update to a popular post published 14 months ago.

What has changed?

Before we begin, a quick reminder: the basic security model behind proof-of-work (PoW) blockchains is to make it economically costly to successfully rewrite the chain’s history. Finite resources, whether it is in the form of electricity or semiconductors, have to be consumed.

Therefore, a PoW chain such as Bitcoin, cannot simultaneously be secure and inexpensive to operate. Because if it was inexpensive to operate it would also be inexpensive to successfully attack.

proof of work, ethereum, mining, blockchain
Source: Crypviz

Bitcoin

For Bitcoin, Bitmain announced its S17e system which can churn out 64TH/s.  Each machine consumes ~2880 watts at the wall.  The first of these units are scheduled to be shipped to customers in November (however other less powerful variants shipped during the summer).

The current Bitcoin hashrate has been oscillating around 100 million TH/s the past few weeks.  

[Source: Blockchain.info]

If the entire network was comprised of the unreleased S17e-based machines, there would be around 1.56 million of them. In a given year these would gulp down about 39.4 billion kWh. But we know that is not the case yet. Thus, this will serve as our lower bound.

Bitmain is also shipping several other newly released systems, including the T17e.  Like its cousin above, the T17e also consumes about ~2880 at the wall. But it is not as efficient per hash: creating only 53 TH/s with the same amount of electricity.  

Why manufacture and sell two (or more) different machines that draw roughly the same amount of power?  

Cost.  the T17e costs $1665 and the S17e is $2483. The target market for the T17e is supposedly for miners who have low or no electricity costs.

How many T17e’s would it take to generate the 100 million TH/s network hashrate?  About 1.88 million; or an additional 300,000 more machines than the S17e.

A quick pause. these types of bulk purchases are not idle speculation. In the middle of last summer, during a two-week period of time, the equivalent of 100,000 mining machines was added to the Bitcoin network (likely early variants of the S17). This is a reversal from last November, wherein the equivalent of ~1.3 million S9s were taken offline during one month.

Again, we know that in practice that there are many more less efficient miners still online.  But crunching the numbers, 1.88 million machines each pulling in 2.88 kWh over one entire year results in…  ~47.6 billion kWh annually.

Another Bitmain machine purchasable today is the new T17 that generates 40 TH/s, drawing about 2200 watts at the wall.  It would take about 2.5 million of these to generate the Bitcoin hashrate all while consuming…  ~48.2 billion kWh per year.

To be thorough, Bitmain released the S9 SE in July which generates 16 TH/s, drawing 1280 watts.  It’s unclear how many of these have been sold but if the entire network was comprised of these: 6.25 million would need to be used.  And they would collectively guzzle ~70 billion kWh. This would be a plausible upper bound.

For comparison, if Bitcoin (T17) were its own country it would at minimum consume roughly the same amount of electricity as Romania or Algeria. If the network were comprised of just S9 SE’s, that’d be about the energy footprint of Austria. In either case, very little is value is produced in return… aside from memes and lots of social media posts. And no, despite historical revisionism by maximalists, “hodling” is not what Bitcoin was originally designed for.

As mentioned in the previous post: no other payment system on earth uses the same amount of electricity, let alone aggregate number of machines, as a PoW coin network. That is a dubious distinction.  

In looking at my previous post you will see a similar figure.  In August 2018, using the (older) S9 machine (~13 TH/s) as a baseline, the Bitcoin network consumed about ~50.5 billion kWh / year.1 Some of these types of machines (like the S9 SE) are still on.

Thus whenever you hear a PoW promoter claim that:  

  • Bitcoin doesn’t use much electricity; or
  • Bitcoin’s electricity usage will naturally decline over time; or
  • Bitcoin is more efficient than traditional payment systems

You can rightly tell them all of those claims are empirically false. In fact, the only way for the resource demands of a PoW coin to decline is if there was a long decline in the coin price.

What do taxpayers – who underwrite the state-owned utility companies – get in return for subsidizing these energy guzzlers? New economic zones of growth and prosperity?

Nope.  According to Chainalysis, in a given day more than 90% of activity on the Bitcoin network is simply movement from one intermediary to another. 2 Coin trading is by far the largest category.

Image

And since most of these coin intermediaries increasingly require some form of KYC / AML compliance, the Bitcoin network has morphed into a expensive permissioned-on-permissionless network that has the drawbacks of both and the benefits of neither. There is no point in using PoW in a network in which all major participants are known: Sybils no longer exist.

A common refrain by PoW promoters is, Christmas lights and set-top boxes also consume huge amounts of energy!

First of all, that’s a whataboutism.  But it also ignores how several Bitcoin mining manufacturers have actually tried to embed chips into these wares.

For instance:

  • Bitmain has a couple of routers called the Antrouter that will mine either BTC or LTC for you.  
  • Bitfury has marketed Bitcoin mining light bulbs.

As you can imagine, a fixed unit of labor eventually becomes unprofitable once difficulty levels increase.  It’s the same fundamental problem that faced the 21.co toasters. Thus neither of these took off (the light bulb didn’t ship) even though retail users often keep both their home routers and living room lights on all day.   Historically PoW equipment becomes e-waste fast and the last thing consumers want is embedded e-waste that guzzles electricity.3

We haven’t even touched on other PoW coins such as Ethereum, Bitcoin Cash, or Monero…  but it is worth pointing out that nearly all of the money going to miners via the block reward is value leaking from the system, either to semiconductor manufacturers or state-owned utilities.

This isn’t idle speculation either, as Nvidia counted on massive consumption of its GPUs in early 2018 which didn’t materialize due to the crash in coin prices. This led to a glut of high-end GPUs in its channel partners, which hit Nvidia’s bottom line and was later reflected by a 50% decline in share prices (the same phenomenon impacted AMD too):

Source: TechSpot

Apart from a couple of small investments, the value that a couple of semiconductor manufacturers or a clique of state-owned utilities receives via mining is money that is not being invested towards developing the chain itself.    

And some of these mining manufacturers have privatized gains at the expense of taxpayers. For instance, Bitfury, used its political connections to obtain cheap land in the Republic of Georgia where it setup massive mining farms:

 “The efforts have given Georgia, with 3.7 million people, a dubious distinction. It is now an energy guzzler, with nearly 10 percent of its energy output gone into the currency endeavor.”  

In Kyrgyzstan, 45 “crypto” mining firms consumed more energy than three local regions combined:  

“[They] consumed 136 megawatts of electricity, which is more than the amount consumed by three Kyrgyzstan regions: Issyk-Kul, Talas and Naryn.”  

Uzbekistan’s Ministry of Energy has introduced a new bill that would dramatically increase the electricity price to miners who are viewed as being “very energy intensive.”

We could probably create an entire post on these types of stories too.

At least Bitcoin is “decentralized,” right?

While the farms may be geographically dispersed to areas with the cheapest electricity, the mining pools, mining manufacturers, and other infrastructure participants are a small and centralized enough group that they can fit into a hotel for regular conferences.

Source: Twitter

Time to look at other chains.

Bitcoin Cash

Because it is nearly identical to Bitcoin (albeit with a few changes such as a larger block size), we can pretty much do the same set of calculations as we already did above.

Source: BitInfoCharts

Unlike Bitcoin, Bitcoin Cash has seen a dramatic decline in hashrate since it peaked at over 5 million TH/s earlier in the summer. It is now oscillating around 2.5 million TH/s.

For Bitcoin Cash, with a Bitmain S17e system, remember it generates 64TH/s and consumes ~2880 watts at the wall. If the entire network was comprised of the unreleased S17e-based machines, there would be around 40,000 of them. In a given year these would use about 985 million kWh. This will serve as our lower bound.

Bitmain’s S9 SE generates 16 TH/s, drawing 1280 watts. It’s unclear how many of these have been sold but if the entire network was comprised of these: ~156,000 would need to be used. And they would collectively use ~1.75 billion kWh. This would be a plausible upper bound.

Not counting e-waste, that would put the energy usage of Bitcoin Cash somewhere around 150, between Benin and The Bahamas. Compared with last year (when it was around 122), this decline is largely due to the nearly 60% price decline in BCH. This once again illustrates that hashrate follows price (e.g., miners expend capital chasing seigniorage).

Ethereum

Coupled with “the thirdening” in February (in which block rewards declined from 3 to 2 ETH), and an overall decline in ETH prices, hashrate also declined over the past year:

Source: Etherscan

According to Coinwarz, the hashrate is oscillating around 200 TH/s, about 1/3 it was when the previous article was written.

A proposed ASIC from Linzhi that hasn’t been built or shipped aims to generate 1400 MH/s with an electricity consumption level of 1 kWh. As the story goes:

To put those figures in perspective, NVIDIA’s GTX TitanV 8 card is now one of the most profitable piece of equipment on the ethash algorithm, able to compute 656 MH/s at an energy consumption level of 2.1 kWh, according to mining pool f2pool’s miner profitability index.

There are a couple of other ASICs on the market including one from Innosilicon and another from Bitmain. The previous post looked at the same Innosilicon A10 on the market, so to simplify things and because the Bitmain machine is roughly just as efficient, let’s reuse it here.

The A10 generates 485 MH/s and consumes ~850 W. The Ethereum network is around 200,000,000 MH/s. That’s the equivalent of 412,371 A10 machines.

Annually these would consume about 3.1 billion kWh per year. Around 132, about as much as Senegal or Papua New Guinea.

If we used the GTX TitanV 8 card, as described in the article above, we find that 304,878 GPUs would be used. These would consume 5.6 billion kWh per year. That’d be around the same amount that Mongolia does annually.

This is one of the reasons why Ethereum is transitioning over to proof-of-stake. As Vitalik Buterin said last year:

I would personally feel very unhappy if my main contribution to the world was adding Cyprus’s worth of electricity consumption to global warming.

Will the nebulously defined “DeFi” on an actual proof-of-stake system change the usage dynamics in the future?4

Litecoin

Litecoin, better known as Bitcoin’s other testnet, has seen its hashrate decline along with its price.

Source: BitInfoCharts

For simplicity sake, let’s call it an even 300 TH/s which coincidentally it was at 14 months ago too. CoinWarz says it is also currently around that, who are we to argue with them?

As mentioned in the previous article, Bitmain’s L3+ is still around. It generates ~500 MH/s with ~800 watts. A slightly more powerful L3++ is on the market as well.

There are the equivalent of about 600,000 L3+ machines generating hashes.

As an aggregate:

  • A single L3+ will consume 19.2 kWh per day
  • 600,000 will consume 11.5 million kWh per day
  • Annually: 4.2 billion kWh per year

It would be placed around 124th, between Moldova and Cambodia.

According a distributor, the Antminer L3++ specifications:

  1. Hash Rate: 580 MH/s ±5%
  2. Power Consumption: 942W + 10% (at the wall, with APW3 ,93% efficiency, 25C ambient temp)

If only L3++’s were used, the outcome would be about the same. 5

This consumption is pretty absurd once we factor in things like how there is only a couple of active developers who basically just merge changes from Bitcoin into Litecoin.6 In other words, one of the largest PoW networks has very few users or developers, yet consumes the same amount of energy as Moldolva. How is that a socially useful innovation?

Note: an easy way to double-check our math on this specific one: the price of LTC is nearly the same today as it was 14 months ago. Ceteris paribus, miners will expend capital no higher than the coin price, to ‘win’ the seigniorage.

Monero

In terms of mining, it appears that several decisions makers (administrators?) in the Monero world really dislike ASICs. So much so that they routinely coordinate forks that include “ASIC-resistant” hashing algorithms. Stories like this are mostly just PR because we know that any PoW coin with a high enough value, will eventually become the target of an ASIC design team.7

Source: BitInfoCharts

From the chart above, you can clearly see when the forks occurred that added “ASIC-resistance.”

Compared with the previous article, the hashrate has declined by about 1/3rd to about 325 MH/s. And it is believed that most of this hashrate is generated by GPUs and CPUs.

There are lots of how-to guides for building a Monero mining rig. Rather than getting into the weeds, based on this crazy 12-card Vega build, the user was able to generate 28,100 hashes/sec and consume 1920 watts. That’s about 2341 hashes per card (more than 10% faster than the one used in the previous article).

That’s about 138,829 GPUs each sipping 160 watts. Altogether these consume 194 million kWh annually. That’s likely a lower bound for GPU mining.

If we reused the Vega 64 mentioned in the previous article, there would be about 162,500 GPUs at the current hashrate. These would consume around 228 million kWh annually.

Not surprisingly, coupled with the “ASIC-resistant” fork and a coin price decline of nearly 50%, this resulted in about 1/3 energy used from the previous year. But this is still not an upper bound because it is likely that CPUs contribute to a non-insignificant portion of the hashrate via persistent botnets and cryptojacking.

Based on the same electricity consumption chart as the others, Monero would be placed somewhere above Grenada and the Mariana Islands. Perhaps a bit higher if lots of CPUs are used. Remember, this is called CPU-cycle theft for a reason.8

Conclusion

In aggregate, based on the numbers above, these five PoW coins likely consume between 56.7 billion kWh and 81.8 billion kWh annually. That’s somewhere around Switzerland on the low end to Finland or Pakistan near the upper end. It is likely much closer to the upper bound because the calculations above all assumed little energy loss ‘at the wall’ when in fact there is often 10% or more energy loss depending on the setup.

This is a little lower than last year, where we used a similar method and found that these PoW networks may consume as much resources as The Netherlands. Why the decline? All of it is due to the large decline in coin prices over the preceding time period. Again, miners will consume resources up to the value of a block reward wherein the marginal cost to mine equals the marginal value of the coin (MC=MV).9

This did not include other PoW coins such as Dash, Ethereum Classic, or Bitcoin SV… although it is likely that based on their current coin value they each probably consume less than either Litecoin or Bitcoin Cash.

Thus to answer the original question at the beginning, the answer is no.

PoW networks still consume massive amounts of electricity and semiconductors that could otherwise have been used in other endeavors. Some of these power plants could be shut down entirely. PoW-based cryptocurrencies crowd out and bid up the prices of semiconductor components.10 Apart from a few stories designed to pull on our heartstrings, little evidence exists (yet) for PoW coins creating socially useful economic output beyond moving coins from one intermediary to another.

And because most coins are mined via single-use ASICs, they generate large amounts of e-waste which leaks value from towards a small clique of semiconductor manufacturers and (mostly) state-owned utilities, neither of whom typically contribute back to the coin ecosystem.11 Will this change in the next 14 months?

Related links

Endnotes

  1. I – and many others – have written about this before. PoW mining is a Red Queen’s race — miners are incentivized via block rewards to expend additional capital on mining, but the total reward available to miners is fixed. Thus while chip efficiency may increase each generation, miners as a whole increase capital outlays for equipment rather than reduce. []
  2. According to The Token Analyst, nearly 7% of all mined bitcoins reside in exchanges. []
  3. Another way some have used to describe Bitcoin is an ASIC-based proof-of-stake. But really it is DPOS but not with the “D” that you may be thinking. Since mining equipment rapidly depreciates (with a typical lifespan of less than 18 months), Bitcoin arguably uses depreciating proof-of-stake. []
  4. According to both DappRadar and State of the Dapps, there has been about a marketed increase in “users” and Dapps (although they combine all Dapp platforms, not just Ethereum). []
  5. Although obviously, as in all examples above, there are loses in efficiency as the energy travels from the power plant all the way through the grid and into a home or office. []
  6. If there is only one actual developer maintaining the Litecoin codebase, how is this ‘sufficiently decentralized’ or not an administrator under FinCEN’s definition? Even the “official” foundation is basically out of funds. []
  7. Wouldn’t it be interesting if a few botnet operators or sites like The Pirate Bay were moonlighting as Monero developers, so they could directly benefit from CPU mining? []
  8. Outright theft continually takes place. For instance, a Singaporean allegedly stole $5 million worth of computing power to mine bitcoin and ether, and “for a brief period, was one of Amazon Web Services (AWS) largest consumers of data usage by volume.” []
  9. See Bitcoins: Made in China and The Marginal Cost of Cryptocurrency by Robert Sams []
  10. During the most recent bubble, DRAM prices soared in part because of demand from cryptocurrency mining. []
  11. Emin Gün Sirer has done a good job explaining this ‘leakage.’ Recommend watching his Devcon 5 presentation on Athereum. []

Book review: The Truth Machine

A friend of mine sent me a copy of The Truth Machine which was published in February 2018.  Its co-authors are Michael Casey and Paul Vigna, who also previously co-wrote The Age of Cryptocurrency a few years ago.

I had a chance to read it and like my other reviews, underlined a number of passages that could be enhanced, modified, or even removed in future editions.

Overall: I do not recommend the first edition. For comparison, here are several other reviews.

This book seemed overly political with an Occupy Wall Street tone that doesn’t mesh well with what at times is a highly technical topic.

I think a fundamental challenge for anyone trying to write book-length content on this topic is that as of 2018, there really aren’t many measurable ‘success’ stories – aside from speculation and illicit activities – so you end up having to fill a couple hundred pages based on hypotheticals that you (as an author) probably don’t have the best optics in.

Also, I am a villain in the book. Can’t wait?  Scroll down to Chapter 6 and also view these specific tweets for what that means.

Note: all transcription errors are my own. See my other book reviews on this topic.

Preface

on p. x they write:

The second impact is the book you are reading. In The Age of Cryptocurrency, we focused primarily on a single application of Bitcoin’s core technology, on its potential to upend currency and payments.

Would encourage readers to peruse my previous review of their previous book. I don’t think they made the case, empirically, that Bitcoin will upend either currency or payments. Bitcoin itself will likely exist in some form or fashion, but “upending” seems like a stretch at this time.

On p. xi they write in a footnote:

We mostly avoid the construct of “blockchain” as a non-countable noun.

This is good. And they were consistent throughout the book too.

Introduction

They spent several pages discussing ways to use a blockchain for humanitarian purposes (and later have a whole chapter on it), however, it is unclear why a blockchain alone is the solution when there are likely other additional ways to help refugees.

For instance, on p. 3 they write:

Just as the blockchain-distributed ledger is used to assure bitcoin users that others aren’t “double-spending” their currency holdings – in other words, to prevent what would otherwise be rampant digital counterfeiting – the Azraq blockchain pilot ensures that people aren’t double-spending their food entitlements.

But why can’t these food entitlements be digitized and use something like SNAP cards? Sure you can technically use a blockchain to track this kind of thing, but you could also use existing on-premise or cloud solutions too, right?  Can centralized or non-blockchain solutions fundamentally not provide an adequate solution?

On p. 4 they write:

Under this new pilot, all that’s needed to institute a payment with a food merchant is a scan of a refugee’s iris. In effect, the eye becomes a kind of digital wallet, obviating the need for cash, vouchers, debit cards, or smartphones, which reduces the danger of theft (You may have some privacy concerns related to that iris scan – we’ll get to that below.) For the WFP, making these transfers digital results in millions of dollars in saved fees as they cut out middlemen such as money transmitter and the bankers that formerly processed the overall payments system.

Get used to the “bankers” comments because this book is filled with a dozen of them. Intermediaries such as MSBs and banks do take cuts, however they don’t really dive into the fee structure. This is important because lots of “cryptocurrency”-focused startups have tried to use cryptocurrencies to supposedly disrupt remittances and most basically failed because there are a lot of unseen costs that aren’t taken into account for.

Another unseen cost that this book really didn’t dive into was: the fee to miners that users must pay to get included into a block.  They mention it in passing but typically hand-waved it saying something like Lightning would lower those costs.  That’s not really a good line of reasoning at this stage in development, but we’ll look at it again later.

On p. 6 they write:

That’s an especially appealing idea for many underdeveloped countries as it would enable their economies to function more like those of developed countries – low-income homeowners could get mortgages, for example; street vendors could get insurance. It could give billions of people their first opening into the economic opportunities that the rest of us take for granted.

That sounds amazing, who wouldn’t want that?  Unfortunately this is a pretty superficial bit of speculation.  For example, how do street vendors get insurance just because of the invention of a blockchain?  That is never answered in the book.

On p. 7 they write:

The problem is that these fee-charging institutions, which act as gatekeepers, dictating who can and cannot engage in commercial interactions, add cost and friction to our economic activities.

Sure, this is true and there are efforts to reduce and remove this intermediation. The book also ignores that every cryptocurrency right now also charges some kind of fee to miners and/or stakers. And with nearly all coins, in order to obtain it, a user typically must buy it through a trusted third party (an exchange) who will also charge a markup fee… often simultaneously requiring you to go through some kind of KYC / AML process (or at least connect to a bank that does).

Thus if fee-charging gatekeepers are considered a problem in the traditional world, perhaps this can be modified in the next edition because these type of gatekeepers exist throughout the coin world too.

On p. 8 they list a bunch of use-cases, some of which they go into additional detail later in the book. But even then the details are pretty vague and superficial, recommend updating this in the next edition with more concrete examples.

On p. 9 they write:

Silicon Valley’s anti-establishment coders hadn’t reckoned with the challenge of trust and how society traditionally turns to centralized institutions to deal with that.

There may have been a time in which the majority of coders in the Bay area were “anti-establishment” but from the nearly 5 years of living out here, I don’t think that is necessarily the case across the board. Recommend providing a citation for that in the future.

On p. 10 they write:

R3 CEV, a New York-based technology developer, for one, raised $107 million from more than a hundred of the world’s biggest financial institutions and tech companies to develop a proprietary distributed ledger technology. Inspired by blockchains but eschewing that lable, R3’s Corda platform is built to comply with banks’ business and regulatory models while streamlining trillions of dollars in daily interbank securities transfers.

This whole paragraph should be updated (later in Chapter 6 as well):

  • The Series A funding included over 40 investors, not 100+.
  • The ‘community’ version of Corda is open sourced and available on github, so anyone can download, use, and modify it. There is also a Corda Enterprise version that requires a license and is proprietary.
  • While initially eschewing the term “blockchain,” Corda is now actively marketed as a “blockchain” and even uses the handle @cordablockchain on Twitter, on podcast advertisements, and in public presentations.1
  • I am unaware of any current publicly announced project that involves streamlining trillions of dollars in daily interbank securities transfers. Citation?

On p. 10 they briefly mention the Hyperledger Project.  Recommend tweaking it because of its own evolution over the years.

For example, here is my early contribution: what is the difference between Hyperledger and Hyperledger.

On p. 11 they write:

While it’s quite possible that many ICOs will fall afoul of securities regulations and that a bursting of this bubble will burn innocent investors, there’s something refreshingly democratic about this boom. Hordes of retail investors are entering into early stage investment rounds typically reserved for venture capitalists and other professional.

This paragraph aged horribly since the book was published in February.

All of the signs were there: we knew even last year that many, if not all, ICOs involved overpromising features and not disclosing much of anything to investors. As a result, virtually every week and month in 2018 we have learned just how much fraud and outright scams took place under the guise and pretext of the “democratization of fund raising.”

For instance, one study published this summer found that about 80% of the ICOs in 2017 were “identified scams.” Another study from EY found that about 1/3 of all ICOs in 2017 have lost “substantially all value” and most trade below their listing price.

Future versions of this book should remove this paragraph and also look into where all of that money went, especially since there wasn’t – arguably – a single cryptocurrency application with a real user base that arose from that funding method (yet).

On p. 11 they write:

Not to be outdone, Bitcoin, the grandaddy of the cryptocurrency world, has continued to reveal strengths — and this has been reflected in its price.

This is an asinine metric. How exactly does price reflect strength? They never really explain that yet repeat roughly the same type of explanation in other places in this book.

Interestingly, both bitcoin’s price and on-chain transaction volume have dramatically fallen since this book was first published. Does that mean that Bitcoin weakened somehow?

On p. 12 they write:

Such results give credence to crypto-asset analysts Chris Burniske and Jack Tatar’s description of bitcoin as “the most exciting alternative investment of the 21st century.”

Firstly, the Burniske and Tatar book was poorly written and wrong in many places: see my review

Secondly, bitcoin is a volatile investment that is arguably driven by a Keynesian beauty contest, not for the reasons that either book describes (e.g., not because of remittance activity).

On p. 12 they write:

The blockchain achieves this with a special algorithm embedded into a common piece of software run by all the computers in the network.

To be clear: neither PoW nor PoS are consensus protocols which is implied elsewhere on page 12.

On p. 12 they write:

Once new ledger entries are introduced, special cryptographic protections make it virtually impossible to go back and change them.

This is not really true. For coins like Bitcoin, it is proof-of-work that makes it resource intensive to do a block reorganization. Given enough hashrate, participants can and do fork the network. We have seen it occur many times this year alone. There is no cryptography in Bitcoin or Ethereum that prevents this reorg from happening because PoW is separate from block validation.2

On p. 13 they write:

Essentially, it should let people share more. And with the positive, multiplier effects that this kind of open sharing has on networks of economic activity, more engagement should in turn create more business opportunities.

These statement should be backed up with supporting evidence in the next edition because as it stands right now, this sounds more like a long-term goal or vision statement than something that currently exists today in the cryptocurrency world.

On p. 13 they mention “disintermediation” but throughout the book, many of the cryptocurrency-related companies they explore are new intermediaries. This is not a consistent narrative.

On p. 14 they write:

If I can trust another person’s claims – about their educational credentials, for example, or their assets, or their professional reputation – because they’ve been objectively verified by a decentralized system, then I can go into direct business with them.

This is a non sequitur. Garbage in, garbage out (GIGO) — in fact, the authors make that point later on in the book in Chapter 7.

On p. 15 they write:

Blockchains are a social technology, a new blueprint for how to govern communities, whether we’re talking about frightened refugees in a desolate Jordanian output or an interbank market in which the world’s biggest financial institutions exchange trillions of dollars daily.

This is vague and lacks nuance because there is no consensus on what a blockchain is today. Many different organizations and companies define it differently (see the Corda example above).

Either way, what does it mean to call a blockchain “social technology”? Databases are also being used by refugee camp organizers and financial infrastructure providers… are databases “social technology” too?

Chapter 1

On p. 17 they write:

Its blockchain promised a new way around processes that had become at best controlled by middlemen who insisted on taking their cut of every transaction, and at worst the cause of some man-made economic disasters.

This is true and problematic and unfortunately Bitcoin itself doesn’t solve that because it also has middlemen that take a cut of every transaction in the form of a fee to miners. Future editions should add more nuance such as the “moral hazard” of bailing out SIFIs and TBTF and separate that from payment processors… which technically speaking is what most cryptocurrencies strive to be (a network to pay unidentified participants).

On p. 18 they write:

Problems arise when communities view them with absolute faith, especially when the ledger is under control of self-interested actors who can manipulate them. This is what happened in 2008 when insufficient scrutiny of Lehman Brother’s and other’s actions left society exposed and contributed to the financial crisis.

This seems to be a bit revisionist history. This seems to conflate two separate things: the type of assets that Lehman owned and stated on its books… and the integrity of the ledgers themselves. Are the authors claiming that Lehman Brother’s ledgers were being maliciously modified and manipulated? If so, what citation do they have?

Also a couple pages ago, the authors wrote that blockchains were social technology… but we know that from Deadcoins.com that they can die and anything relying on them can be impacted.

Either way, in this chapter the authors don’t really explain how something Bitcoin itself would have prevented Lehman’s collapse. See also my new article on this topic.

On p. 19 they write:

A decentralized network of computers, one that no single entity controlled, would thus supplant the banks and other centralized ledger-keepers that Nakamoto identified as “trusted third parties.”

Fun fact: the word “ledger” does not appear in the Bitcoin white paper or other initial emails or posts by Nakamoto.

Secondly, perhaps an industry wide or commonly used blockchain of some kind does eventually displace and remove the role some banks have in maintaining certain ledgers, but their statement, as it is currently worded, seems a lot like of speculation (projection?).

We know this because throughout the book it is pretty clear they do not like banks, and that is fine, but future editions need to back up these types of opinions with evidence that banks are no longer maintaining a specific ledger because of a blockchain.

On p. 20 they write:

With Bitcoin’s network of independent computers verifying everything collectively, transactions could now be instituted peer to peer, that is, from person to person. That’s a big change from our convoluted credit and debit card payment systems, for example, which routes transactions through a long sequence of intermediaries – at least two banks, one or two payment processors, a card network manager (such as Visa or Mastercard), and a variety of other institutions, depending on where the transaction take place.

If we look back too 2009, this is factually correct of Bitcoin at a high level.3 The nuance that is missing is that today in 2018, the majority of bitcoin transactions route through a third party, some kind of intermediary like a deposit-taking exchange or custodial wallet.4 There are still folks who prefer to use Bitcoin as a P2P network, but according to Chainalysis, last year more than 80% of transactions went through a third party.5

On p. 20 they write:

Whereas you might think that money is being instantly transferred when you swipe your card at a clothing store, in reality the whole process takes several days for the funds to make all those hops and finally settle in the storeowner’s account, a delay that create risks and costs. With Bitcoin, the idea is that your transaction should take only ten to sixty minutes to fully clear (not withstanding some current capacity bottlenecks that Bitcoin developers are working tor resolve). You don’t have to rely on all those separate, trusted third parties to process it on your behalf.

This is mostly incorrect and there is also a false comparison.

In the first sentence they gloss over how credit card payment systems confirm and approve transactions in a matter of seconds.6 Instead they focus on settlement finality: when the actual cash is delivered to the merchant… which can take up to 30+ days depending on the system and jurisdiction.

The second half they glowingly say how much faster bitcoin is… but all they do is describe the “seen” activity with a cryptocurrency: the “six block” confirmations everyone is advised to wait before transferring coins again. This part does not mention that there is no settlement finality in Bitcoin, at most you get probabilistic finality (because there is always chance there may be a fork / reorg).

In addition, with cryptocurrencies like Bitcoin you are only transferring the coins. The cash leg on either side of the transaction still must transfer through the same intermediated system they describe above. We will discuss this further below when discussing remittances.

On p. 20 they write:

It does so in a way that makes it virtually impossible for anyone to change the historical record once it has been accepted.

For proof-of-work chains this is untrue in theory and empirically. In the next edition this should be modified to “resource intensive” or “economically expensive.”

On p. 20 they write:

The result is something remarkable: a record-keeping method that brings us to a commonly accepted version of the truth that’s more reliable than any truth we’ve ever seen. We’re calling the blockchain a Truth Machine, and its applications go far beyond just money.

It is not a “truth machine” because garbage in, garbage out.

In addition, while they do discuss some historical stone tablets, they don’t really provide a metric for how quantitatively more (or less) precise a blockchain is versus other methods of recording and witnessing information. Might be worth adding a comparison table in the next edition.

On p. 21 they write:

A lion of Wall Street, the firm was revealed to be little more than a debt-ravaged shell kept alive only by shady accounting – in other words, the bank was manipulating its ledgers. Sometimes, that manipulation involved moving debt off the books come reporting season. Other times, it involved assigning arbitrarily high values to “hard-to-value” assets – when the great selloff came, the shocking reality hit home: the assets had no value.

The crash of 2008 revealed most of what we know about Wall Street’s confidence game at that time. It entailed a vast manipulation of ledgers.

This was going well until that last sentence. Blockchains do not solve the garbage in, garbage out problem. If the CFO or accountant or book keeper or internal counsel puts numbers into blocks that do not accurately reflect or represent what the “real value” actually is, blockchains do not fix that. Bitcoin does not fix that.

Inappropriate oversight, rubber stamp valuations, inaccurate risk models… these are off-chain issues that afflicted Lehman and other banks. Note: they continue making this connection on pages 24, 28, and elsewhere but again, they do not detail how a blockchain of some kind would have explicitly prevented the collapse of Lehman other other investment banks.

See also: Systemically important cryptocurrency networks

On p. 22 they write:

The real problem was never really about liquidity, or a breakdown of the market. It was a failure of trust. When that trust was broken, the impact on society – including on our political culture – was devastating.

How about all of the above? Pinning it on just one thing seems a little dismissive of the multitude of other interconnecting problems / culprits.

On p. 22 they write:

By various measures, the U.S. economy has recovered – at the time of writing, unemployment was near record lows and the Dow Jones Industrial Average was at record highs. But those gains are not evenly distributed; wage growth at the top is six times what it is for those in the middle, and even more compared to those at the bottom.

If the goal of the authors is to rectify wealth inequalities then there are probably better comparisons than using cryptocurrencies.

Why? Because – while it is hard to full quantify, it appears that on cursory examination most (if not all) cryptocurrencies including Bitcoin have Gini coefficients that trends towards 1 (perfectly unequal).

On p. 23 they write about disinformation in the US and elsewhere.  And discuss how trust is a “vital social resource” and then mention hyperinflation in Venezuela. These are all worthy topics to discuss, but it is not really clear how any of these real or perceived problems are somehow solved because of a blockchain, especially when Venezuela is used as the example. The next edition should make this more clear.

On p. 29 they write:

On October 31, 2008, whil the world was drowning in the financial crisis, a little-noticed “white paper” was released by somebody using the pen name “Satoshi Nakamoto,” and describing something called “Bitcoin,” an electronic version of cash that didn’t need state backing. At the heart of Nakamoto’s electronic cash was a public ledger that could be viewed by anybody but was virtually impossible to alter.

One pedantic note: it wasn’t broadly marketed beyond a niche mailing list on purpose… a future edition might want to change ” a little-noticed” because it doesn’t seem like the goal by Nakamoto was to get Techcrunch or Slashdot to cover it (even though eventually they both did).

Also, it is not virtually impossible to alter.7 As shown by links above, proof-of-work networks can and do get forked which may include a block reorganization. There is nothing that technically prevents this from happening.

See also: Interview with Ray Dillinger

On p. 31 they write:

Szabo, Grigg, and others pioneered an approach with the potential to create a record of history that cannot be changed – a record that someone like Madoff, or Lehman’s bankers, could not have meddled with.

I still think that the authors are being a little too liberal with what a blockchain can do. What Madoff did and Lehman did were different from one another too.

Either way, a blockchain would not have prevented data – representing fraudulent claims – from being inserted into blocks. Theoretically a blockchain may have allowed auditors to detect tampering of blocks, but if the information in the blocks are “garbage” then it is kind of besides the point.

On p. 32 they write:

Consider that Bitcoin is now the most powerful computing network in the world, one whose combined “hashing” rate as of August 2017 enabled all its computers to collectively pore through 7 million trillion different number guesses per second.

[…]

Let the record show that period of time is 36,264 trillion trillion times longer than the current best-estimate age of the universe. Bitcoin’s cryptography is pretty secure.

This should be scrapped for several reasons.

The authors conflate the cryptography used by digital signatures with generating proofs-of-work.8 There are not the same thing. Digital signatures are considered “immutable” for the reasons they describe in the second part, not because of the hashes that are generated in the first.9

Another problem is that the activity in the first part — the hash generation process — is not an apples-to-apples comparison with other general computing efforts. Bitcoin mining is a narrowly specific activity and consequently ASICs have been built and deployed to generate these hashes. The single-use machines used to generate these hashes cannot even verify transactions or construct blocks. In contrast, CPUs and GPUs can process a much wider selection of general purpose applications… including serialize transactions and produce blocks.

For example: it would be like comparing a Falcon 9 rocket launch vehicle with a Toyota Prius. Sure they are nominally both “modes of transportation” but built for entirely different purposes and uses.

An additional point is that again, proof-of-work chains can and have been forked over the years. Bitcoin is not special or unique or impervious to forks either (here’s a history of the times Bitcoin has forked). And there are other ways to create forks, beyond the singular Maginot Line attack that the authors describe on this page.10

On p. 33 they write:

Whether the solution requires these extreme privacy measures or not, the broad model of a new ledger system that we laid out above – distributed, cryptographically secure, public yet private – may be just what’s needed to restore people’s confidence in society’s record-keeping systems. And to encourage people to re-engage in economic exchange and risk-taking.

This comes across as speculation and projecting. We will see later that the authors have a dim view of anything that is not a public blockchain. Why is this specific layout the best?

Either way, future versions should include a citation for how people’s confidence level increase because of the use of some kind of blockchain. At this time, I am unaware of any such survey.

On p. 34 they quote Tomicah Tilleman from the Global Blockchain Business Council, a lobbying organization:

Blockchain has the potential to push back against that erosion and it has the potential to create a new dynamic in which everyone can come to agree on a core set of facts but also ensure the privacy of facts that should not be in the public domain.

This seems like a non sequitur. How does a blockchain itself push back on anything directly? Just replace the word “blockchain” with “database” and see if it makes sense.

Furthermore, as we have empirically observed, there are fractures and special interest groups within each of these little coin ecosystems. Each has their own desired roadmap and in some cases, they cannot agree with one another about facts such as the impact larger block sizes may have on node operators.

On p. 35 they write:

If it can foster consensus in the way it has been shown to with Bitcon, it’s best understood as a Truth Machine.

This is a non sequitur. Just because Nakamoto consensus exists does not mean it that blockchains are machines of truth. They can replicate falsehoods if the blocks are filled with the incorrect information.

Chapter 2

On p. 38 they write:

Consider how Facebook’s secret algorithm choose the news to suit your ideological bent, creating echo chambers of like-minded angry or delighted readers who are ripe to consume and share dubious information that confirms their pre-existing political biases.

There are some really valid points in this first part of the chapter. As it relates to cryptocurrencies, a second edition should also include the astroturfing and censoring of alternative views that take place on cryptocurency-related subreddits which in turn prevent people from learning about alternative implementations.

We saw this front-and-center in 2015 with the block size debate in which moderators of /r/bitcoin (specifically, theymos and BashCo) banned any discussion from one camp, those that wanted to discuss ways of increasing the block size via a hardfork (e.g., Bitcoin XT, Bitcoin Classic).

This wasn’t the first or last time that cryptocurrency-related topics on social media have resulted in the creation of echo chambers.

On p. 43 they write:

The potential power of this concept starts with the example of Bitcoin. Even though that particular blockchain may not provide the ultimate solution in this use case, it’s worth recalling that without any of the classic, centrally deployed cybersecurity tools such as firewalls, and with a tempting “bounty” of more than $160 billion in market cap value at the time we went to print, Bitcoin’s core ledger has thus far proven to be unhackable.

There is a lot to unpack here but I think a future edition should explain in more detail how Bitcoin is a type of cybersecurity tool. Do they mean that because the information is replicated to thousands of nodes around the world, it is more resilient or redundant?

Either way, saying that “Bitcoin’s core ledger” is “unhackable” is a trope that should be removed from the next edition as well.

Why? Because when speaking about BTC or BCH or any variant of Bitcoin, there is only one “ledger” per chain… the word ‘core’ is superfluous. And as described above, the word “unhackable” should be changed to “resource intensive to fork” or something along those lines. “Unhackable” is anarchronistic because what the authors are probably trying to describe is malicious network partitions… and not something from a ’90s film like The Net.

Continuing on p. 43 they write:

Based on the ledger’s own standards for integrity, Bitcoin’s nine-year experience of survival provides pretty solid proof of the resiliency of its core mechanism for providing decentralized trust between users. It suggest that one of the most important non-currency applications of Bitcoin’s blockchain could be security itself.

This last sentence makes no sense and they do not expand on it in the book. What is the security they are talking about? And how is that particularly helpful to “non-currency applications of Bitcoin’s blockchain”? Do they mean piggy-backing like colored coins try to do?

On p. 44 they write:

The public ledger contains no identifying information about the system’s users. Even more important, no one owns or controls that ledger.

Well technically speaking, miners via mining pools control the chain. They can and do upgrade / downgrade / sidegrade the software. And they can (and do) fork and reorg a chain. Is that defined as “control”? Unclear but we’ll probably see some court cases if real large loses take place due to forks.

On p. 44 they write:

As such there is no central vector of attack.

In theory, yes. In practice though, many chains are highly centralized: both in terms of block creation and in terms of development. Thus in theory it is possible to compromise and successfully “attack” a blockchain under the right circumstances. Could be worth rephrasing this in the next edition.

On p. 44 they write:

As we’ll discuss further in the book, there are varying degrees of security in different blockchain designs, including those known as “private” or “permissioned” blockchains, which rely on central authorities to approve participants. In contrast, Bitcoin is based on a decentralized model that eschews approvals and instead banks on the participants caring enough about their money in the system to protect it.

This is a bit of a strawman because there are different types of “permissioned” blockchains designed for different purposes… they’re not all alike. In general, the main commonality is that the validators are known via a legal identity. How these networks are setup or run does not necessarily need to rely on a centralized authority, that would be a single point of trust (and failure). But we’ll discuss this later below.

On p. 44 they write:

On stage at the time, Adam Ludwin, the CEO of blockchain / distributed ledger services company Chain Inc., took advantage of the results to call out Wall Street firms for failing to see how this technology offers a different paradigm. Ludwin, whose clients include household names like Visa and Nasdaq, said he could understand why people saw a continued market for cybersecurity services, since his audience was full of people paid to worry about data breaches constantly. But their answers suggested they didn’t understand that the blockchain offered a solution. Unlike other system-design software, for which cybersecurity is an add-on, this technology “incorporates security by design,” he said.

It is unclear from the comments above exactly how a blockchain solves problems in the world of cybersecurity. Maybe it does. If so, then it should be explored in more detail than what is provided in this area of the book.

As an aside, I’m not sure how credible Ludwin’s comments on this matter are because of the multiple pivots that his companies have done over the past five years.11

On p. 45 they write:

A more radical solution is to embrace open, “permissionless” blockchains like Bitcoin and Ethereum, where there’s no central authority keeping track of who’s using the network.

This is very much a prescriptive pitch and not a descriptive analysis. Recommend changing some of the language in the next edition. Also, they should define what “open” means because there basically every mining pool doxxes themselves.

Furthermore, some exchanges that attempt to enforce their terms-of-service around KYC / AML / CTF do try to keep track of who is doing what on the network via tools from Chainalysis, Blockseer, Elliptic and others. Violating the ToS may result in account closures. Thus, ironically, the largest “permissioned” platforms are actually those on the edges of all cryptocurrencies.

See: What is Permissioned-on-Permissionless

On p. 45 they write:

It’s not about building a firewall up around a centralized pool of valuable data controlled by a trusted third party; rather the focus is on pushing control over information out to the edges of the network, to the people themselves, and on limiting the amount of identifying information that’s communicated publicly. Importantly, it’s also about making it prohibitively expensive for someone to try to steal valuable information.

This sounds all well and good, definitely noble goals. However in the cryptocurrency world, many exchanges and custodial wallets have been compromised and the victims have had very little recourse. Despite the fact that everyone is continually told not to store their private keys (coins) with an intermediary, Chainalysis found that in 2017 more than 80% of all transactions involved a third-party service.

On p. 45 they write:

Bitcoin’s core ledger has never been successfully attacked.

They should define what they mean by “attacked” because it has forked a number of times in its history. And a huge civil war took place resulting in multiple groups waging off-chain social media campaigns to promote their positions, resulting in one discrete group divorcing and another discrete group trying to prevent them from divorcing. Since there is only de facto and not de jure governance, who attacked who? Who were the victims?

On p. 45 they write:

Now, it will undoubtedly be a major challenge to get the institutions that until now have been entrusted with securing our data systems to let go and defer security to some decentralized network in which there is no identifiable authority to sue if something goes wrong. But doing so might just be the most important step they can take to improve data security. It will require them to think about security not as a function of superior encryption and other external protections, but in terms of economics, of making attacks so expensive that they’re not worth the effort.

This seems a bit repetitive with the previous couple of page, recommend slimming this down in the next edition. Also, there are several class action lawsuits underway (e.g., Ripple, Tezos) which do in fact attempt to identify specific individuals and corporations as being “authorities.” The Nano lawsuit also attempted to sue “core developers.”

On p. 46 they write:

A hacker could go after each device, try to steal the private key that’s used to initiate transactions on the decentralized network, and, if they’re lucky, get away with a few thousand dollars in bitcoin. But it’s far less lucrative and far more time-consuming than going after the rich target of a central server.

The ironic part of this is that generally speaking, the private keys controlling millions of bitcoins are being housed in trusted third parties / intermediaries right now. In some cases these are stored on a centralized server. In other cases, the cold wallet managed by hosting providers such as Xapo (which is rumored to secure $10 billion of bitcoin) does geographically split the keys apart into bunkers. Yet at some point those handling the mutli-sig do come together in order to move the coins to a hot wallet.12

On p. 47 they write:

It seems clear to us that the digital economy would benefit greatly from embracing the distributed trust architecture allowed by blockchains – whether it’s simply the data backups that a distributed system offers, or the more radical of an open system that’s protected by a high cost-to-payout ratio.

What does this mean? Are they saying to add proof-of-work to all types of distributed systems? It is only useful in the Bitcoin context in order to make it expensive to Sybil attack the network… because participants were originally unknown. Does that same problem exist in other environments that they are thinking of? More clarity should be added in the next edition.

On p. 48 they write:

The idea, one that’s also being pursued in different forms by startups such as Gem of Los Angeles and Blockchain Health of San Francisco, is that the patient has control over who sees their records.

This is one of the difficulties in writing a long-form book on this general topic right now: projects and companies frequently pivot.

For instance, a couple months after the book was published, Gem announced its “Universal Token Wallet,” a product which currently dominates its front page and social media accounts of the company. There have been no health care-related announcements from the company in over a year.

Similarly, Blockchain Health no longer exists. Its CEO left and joined Chia as a co-founder and the COO has joined the Neighborly team.

On p. 50 they write:

It was a jury-rigged solution that meant that the banking system, the centralized ledger-keeping solution with which society had solved the double-spend problem for five hundred years, would be awkwardly bolted onto the ostensibly decentralized Internet as its core trust infrastructure.

I think there are some legitimate complaints to made towards how online commerce evolved and currently exists but this seems a tad petty. As backwards as financial institutions are (rightly and wrongly) portrayed, it’s not like their decision makers sat around in the early ’90s trying to figure out how to make integrating the Web an awkward process.

On p. 50 they write:

Under this model, the banks charged merchants an interchange fee of around 3 percent to cover their anti-fraud costs, adding a hidden tax to the digital economy we all pay in the form of higher prices.

Again, like their statement above: there are some very legitimate gripes to be had regarding the existing oligopolistic payment systems, but this specific gripe is kind of petty.

Fraud exists and as a result someone has to pay for it. In the cryptocurrency world, there is no recourse because it is caveat emptor. In the world of courts and legal recourse, fees are levied to cover customer service including fraud and insurance. It may be possible to build a payment system in which there is legal recourse and simultaneously no oligopolistic rent seeking but this is not explored in the book. Also, for some reason the fee to miners is not brought up in this section, yet it is a real fee users must pay… yet they do not receive customer service as part of it.

Lastly, the Federal Reserve (and other central banks) monitor historical interchange fees. Not all users are charged the ~3% as mentioned in the book.

For instance (see below): Average Debit Card Interchange Fee by Payment Card Network

Source: Statista

On pages 52 and 53 they write uncritically about Marc Andresseen and VCs who have invested in Bitcoin and cryptocurrencies.

a16z, the venture firm co-founded by Andresseen, arguably has a few areas that may be conflicts-of-interest with the various coin-related projects it has invested in and/or promoted the past several years (e.g., investing in coins which are listed on an exchange they also are an investor and board member of such as 0x). Those ties are not scrutinized in a chapter that attempts to create a black and white narrative: that the legacy players are centralized rent-seekers and the VCs are not. When we know empirically that some VCs, including a16z, have invested in what they believe will become monopolies of some kind.

On page 54 and 55 they write about “Code is not law,” a topic that I have likewise publicly presented on.

Specifically they state:

One risk is that regulators, confused by all these outside-the-box concepts, will overreact to some bad news – potentially triggered by large-scale investors losses if and when the ICO bubble bursts and exposes a host of scams. The fear is that a new set of draconian catchall measures would suck the life out of innovation in this space or drive it offshore or underground. To be sure, institutions like the Washington-based Coin Center and the Digital Chamber of Commerce are doing their best to keep officials aware of the importance of keeping their respective jurisdictions competitive in what is now a global race to lead the world in financial technology.

This is word for word what coin lobbyists have been pitching to policy makers around the world for years. Both Coin Center and Digital Chamber of Commerce lobby on behalf of their sponsors and donors to prevent certain oversight on the cryptocurrency market.13 An entire book could probably be written about how specific people within coin lobbying organizations have attempted to white wash and spin the narrative around illicit usage, using carefully worded talking points. And they have been effective because these authors do not question the motivations and agenda these special interest groups have.

Either way, Bitcoin and many other cryptocurrencies were born in the “underground” and even “offshore.” It is unclear what the authors are trying to excuse because if anything, regulators and law enforcement have arguably been very light handed in the US and most regions abroad.

If anything, once a foreign registered ICO or coin is created, often the parent company and/or foundation opens an office to recruit developers in San Francisco, New York, and other US cities. I know this because all the multiple “blockchain” events I have attended overseas the past two years in which organizers explain their strategy. The next edition of this book could explore this phenomenon.

On p. 57 they write:

By The DAO founders’ own terms, the attacker had done nothing wrong, in other words. He or she had simply exploited one of its features.

Excellent point that should be explored in further detail in the next edition. For instance, in Bitcoin there have been multiple CVEs which if exploited (at least one was) could have resulted in changes in the money supply. Is that a feature or a bug?

And the most recent one, found in pre-0.16.3, was partially downplayed and hidden to prevent others from knowing the extent of potential damage that could have been done.

On p. 59 they write:

The dependence on a trusted middleman, some cryptocurrency purists would argue, overly compromises a blockchain’s security function, rending it unreliable. For that reason, some of them say, a blockchain is inappropriate for many non-currency applications. We, however, view it as a trade-off and believe there’s still plenty of value in recording ownership rights and transfers to digitally represented real-world assets in blockchains.

I think this whole section should be reworded to describe:

  1. what types of blockchains they had in mind?
  2. how the legal hooks into certain blockchains behave versus anarchic chains?
  3. being more precise with the term purist… do they mean maximalists or do they mean someone who points out that most proposed use-cases are chainwashing?

On pages 59 and 60 they write:

Permissioned blockchains – those which require some authorized entity to approve the computers that validate the blockchain – by definition more prone to gatekeeping controls, and therefore to the emergence monopoly or oligopoly powers, than the persmissionless ideal that Bitcoin represents. (We say “ideal” because, as we’ll discuss in the next chapter, there are also concerns that aspects of Bitcoin’s software program have encouraged an unwelcome concentration of ownership – flaws that developers are working to overcome.)

It would be beneficial in the next edition to at least walk through two different “permissioned blockchains” so the reader can get an idea of how validators become validators in these chains. By not including them, each platform is painted in the same light.

And because they are still comparing it with Bitcoin (which was designed for a completely different type of use-case than ‘permissioned chains’ are), keep in mind that the way mining (block making) is done in 2018 is very different than when it was first proposed in the 2008 paper. Back then, mining included a machine that did two things: validated blocks and also generate proofs-of-work. Today, those two functions are completely separate and because of the relatively fierce competition at generating hashes, there are real exit and entry costs to the market.

In many cases, this means that both the mining pool operators and hash generators end up connecting their real world government-issued identities with their on-chain activity (e.g., block validation). It may be a stretch to say that there is an outright monopoly in mining today, but there is a definite trend towards oligopoly in manufacturing, block producing, and hash generation the past several years. This is not explored beyond a superficial level in the book.

On p. 60 they write:

Until law changes, banks would face insurmountable legal and regulatory opposition, for example, to using a system like Bitcoin that relies on an algorithm randomly assigning responsibility at different stages of the bookkeeping process to different, unidentifiable computers around the world.

This is another asinine comment because they don’t explicitly say which laws they would like changed. The authors make it sound like the PFMIs are holding the world back when the opposite is completely true. These principals and best practices arose over time because of the systemic impact important financial market infrastructures could have on society as a whole.

Proof-of-work chains, the ones that are continually promoted in this book, have no ability to prevent forks, by design. Anarchic chains like Bitcoin and Ethereum can only provide probabilistic finality. Yet commercial best practices and courts around the world demands definitive settlement finality. Why should commerce be captured by pseudonymous, unaccountable validators maintained in jurisdictions in which legal recourse is difficult if not impossible?

On p. 60 they continue:

But that doesn’t mean that other companies don’t have a clear interest in reviewing how these permissioned networks are set up. Would a distributed ledger system that’s controlled by a consortium of the world’s biggest banking institutions be incentivized to act in the interest of the general public it serves? One can imagine the dangers of a “too-big-to-fail blockchain” massive institutions could once again hold us hostage to bailouts because of failures in the combined accounting system.

This has been one of Michael Casey’s talking points for the past three years. I was even on a panel with him in January 2016 in which he called R3 a “cartelchain,” months before Corda even existed. His justified disdain towards traditional financial institutions — and those involved with technology being developed in the “permissioned” world — pops up throughout this book. I do think there are some valid critiques of consortia and permissioned chains and even Corda, but those aren’t presented in this edition of the book.

He does make two valid observations here as well: regulated commerce should have oversight. That is one of the reasons why many of the organizations developing “permissioned blockchains” have plans to or already have created separate legal entities to be regulated as some type of FMI.

The other point is that we should attempt to move away from recreating TBTF and SIFI scenarios. Unfortunately in some cases, “permissioned chains” are being pitched as re-enabler of that very scenario. In contrast, dFMI is a model that attempts to move away from these highly intermediated infrastructures. See also my new article on SICNs.

On p. 60 they write:

Either way, it’s incumbent upon us to ensure that the control over the blockchains of the future is sufficiently representative of broad-based interests and needs so that they don’t just become vehicles for collusion and oligpolistic power by the old guard of finance.

The ironic part of this statement is — while well-intended — because of economies of scale there is an oligopoly or even monopoly in most PoW-mined coins. It is unclear how or why that would change in the future. In addition, with the entrance of Bakkt, ErisX, Fidelity and other large traditional financial organizations (e.g., the old guard) into the cryptocurrency world, it is hard to see how “permissionless ecosystems” can prevent them from participating.

On p. 61 they write:

As we stated in The Age of Cryptocurrency, Bitcoin was merely the first crack at using a distributed computing and decentralized ledger-keeping system to resolve the age-old problem of trust and achieve this open, low-cost architecture for intermediary-free global transactions.

But as the authors have stated elsewhere: proof-of-work chains are inherently costly. If they were cheap to maintain then they would be cheap to fork and reorg. You cannot simultaneously have a cheap (“efficient”) and secure PoW network… that’s a contradiction.

See:

Chapter 3

On pages 64 and 65 they provide a definition of a blockchain. I think this could be more helpful more earlier on in the book for newer audiences.

A few other citations readers may be interested in:

On p. 66 they write:

That way, no authorizing entity could block, retract, or decide what gest entered into the ledger, making it censorship resistant.

Could be worth referencing Eligius, a pool run by Luke-Jr. that would not allow Satoshi Dice transactions because its owners religious views.14

On p. 67 they write:

These computers are known as “miners,” because in seeking to win the ten-minute payout, they engage in a kind of computational treasure hunt for digital gold.

I understand the need to make simple analogies but the digital gold one isn’t quite right because gold does not have an inflexible supply whereas bitcoin does. I’ve pointed this out in other book reviews and it bears repeating because of how the narrative of e-cash to HODLing has changed over the last few years.1516

Readers may be interested of a few real life examples of perfectly inelastic supplies.

On p. 67 they write:

Proof of work is expensive, because it chews up both electricity and processing power. That means that if a miner wants to seize majority control of the consensus system by adding more computing power, they would have to spend a lot of money doing so.

This is correct. Yet six pages earlier they say it is a “low-cost” infrastructure. Needs to be a little more consistent in this book. Either PoW is resource intensive or it is not, it cannot be both.

On p. 68 they write:

Over time, bitcoin mining has evolved into an industrial undertaking, with gigantic mining “farms” now dominating the network. Might those big players collude and undermine the ledger by combining resources? Perhaps, but there are also overwhelming disincentives for doing so. Among other considerations, a successful attack would significantly undermine the value of all the bitcoins the attacking miner owns. Either way, no one has managed to attack Bitcoin’s ledger in nine years. That unbroken record continues to reinforce belief in Bitcoin’s cost-and-incentive security system.

It’s worth pointing out that there are ways to fork Bitcoin beyond the singular Maginot Line attack. As mentioned above, Bitcoin and many other coins have forked; see this history. Hundreds of coins have died due to lack of interest by miners and developers.

It could also be argued that between 2015-2017, Bitcoin underwent a social, off-chain attack by multiple different groups attempting to exert their own influence and ideology onto the ecosystem. The end result was a permanent fracture, a divorce which the principal participants still lob social media bombs at one another. There isn’t enough room to discuss it here, but the astroturfing actions by specific people and companies in order to influence others is worth looking into as well. And it worked.

On p. 71 they write:

The caveat, of course, is that if bad actors do control more than 50 percent of the computing power they can produce the longest chain and so incorporate fraudulent transactions, which other miners will unwittingly treat as legitimate. Still, as we’ve explained, achieving that level of computing power is prohibitively expensive. It’s this combination of math and money that keeps Bitcoin secure.

I probably would change some of the wording because with proof-of-work chains (and basically any cryptocurrency), there are no terms of service or end user license agreement or SLA. At most there is only de facto governance and certainly not de jure.

What does that mean? It means that we really can’t say who the “bad actors” are since there is no service agreement. Barring an administrator, who is the legitimate authority in the anarchic world of cryptocurrencies? The original pitch was: if miners want to choose to build on another tree or fork, it’s their decision to do so… they don’t need anyone’s permission to validate blocks and attempt to update the chain as they want to. The next edition should explicitly say who or what is an attacker or what a fraudulent transaction is… these are points I’ve raised in other posts and book reviews.

Also, the authors mention that computational resources involved in PoW are “prohibitively expensive” here. So again, to be consistent they likely should remove “low-cost” in other places.

On p. 71 and 72 they write:

In solving the double-spend problem, Bitcoin did something else important: it magically created the concept of a “digital asset.” Previously, anything digital was too easily replicated to be regarded as a distinct piece of property, which is why digital products such as music and movies are typically sold with licensing and access rights rather than ownership. By making it impossible to replicate something of value – in this case bitcoins – Bitcoin broke this conventional wisdom. It created digital scarcity.

No it did not. This whole passage is wrong. As we have seen with forks and clones, there really is no such thing as this DRM-for-money narrative. This should be removed in the next edition.

Scarcity effectively means rivalrous, yet anyone can copy and clone any of these anarchic chains. PoW might make it relatively expensive to do a block reorg on one specific chain, but it does not really prevent someone from doing what they want with an identically cloned chain.

For instance, here is a list of 44 Bitcoin forked tokens that arose between August 2017 and May 2018. In light of the Bitcoin and Bitcoin Cash divorce, lobbying exchanges to recognize ticker symbols is also worth looking into in a future edition.

On p. 73 they write:

Many startups that were trying to build a business on top of Bitcoin, such as wallet providers and exchanges, were frustrated by an inability to process their customers’ transactions in a timely manner. “I’ve become a trusted third party,” complained Wences Casares, CEO of bitcoin wallet and custodial service Xapo. Casares was referring to the fact that too many of his firms’ transactions with its customers had to be processed “off-chain” on faith that Xapo would later settle the transaction on the Bitcoin blockchain.

This is one of the most honest statements in the book. The entire cryptocurrency ecosystem is now dominated by intermediaries.

Interestingly, Xapo moved its main office from Palo Alto to Switzerland days after Ripple was fined by FinCEN for violating the BSA. Was this just a coincidence?

On p. 73 they wrote:

Making blocks bigger would require more memory, which would make it even more expensive to operate a miner, critics pointed out. That could drive other prospective miners away, and leave Bitcoin mining even more concentrated among a few centralized players, raising the existential threat of collusion to undermine the ledger.

This wasn’t really the argument being made by the “small blockers.” Rather, it was disk space (not memory) that was — at the time — perceived as a limitation for retail (home) users in the long run. Yet it has been a moot point for both Bitcoin and Bitcoin Cash as the price per gigabyte for a hard drive continues to decline over time… and because in the past year, on-chain transactions on both chains have fallen from their peak in December 2017.

In practice, the “miners” that that authors refer to are the roughly 15 to 20 or so mining pools that in a given day, create the blocks that others build on. Nearly all of them maintain these nodes at a cloud provider. So there is already a lot of trust that takes place (e.g., AWS and Alibaba are trusted third parties). Because of economies of scale, spinning up a node (computer) in AWS is relatively inexpensive.

It really isn’t discussed much in the book, but the main argument throughout the 2nd half of 2017 was about UASF — a populist message which basically said miners (mining pools) didn’t really matter. Followers of this philosophy emphasized the need to run a node at home. For instance, if a UASF supporter based in rural Florida is attempting to run a node from his home, there could be a stark difference between the uptime and bandwidth capacity he has at home versus what AWS provides.

On p. 74 they write:

Without a tally of who’s who and who owns what, there was no way to gauge what the majority of the Bitcoin community, composed of users, businesses, investors, developers, and miners, wanted. And so, it all devolved into shouting matches on social media.

I wrote about this phenomenon in Appendix A in a paper published in November 2015. And what eventually happened was a series of off-chain Sybil attacks by several different tribes, but especially by promoters of UASF who spun up hundreds — thousands of nodes — and acted as if those mattered.

Future editions should also include a discussion on what took place at the Hong Kong roundtable, New York agreement, and other multilateral governance-related talks prior to the Bitcoin Cash fork.

On p. 74 they write:

A hard-fork-based software change thus poses a do-or-die decision for users on whether to upgrade or not. That’s bad enough for, say, word processing software, but for a currency it’s downright problematic. A bitcoin based on the old version could not be transferred to someone running software that support the new version. Two Bitcoins. Two versions of the truth.

The authors actually accidentally proved my earlier point: that public chains, specifically, proof-of-work chains, cannot prevent duplication or forks. Proof-of-work only makes it resource intensive to do double-spend on one specific chain.

This is one of the reasons why regulated financial organizations likely will continue to not issue long lifecycle instruments directly onto an anarchic chain like Bitcoin: because by design, PoW chains are forkable.

Also, future editions may want to modify this language because there are some counterarguments from folks like Vitalik Buterin that state: because hard forks are opt-in and thus lead to cleaner long-term outcomes (e.g., less technical debt).

On p. 75 they write a lot about Lightning Network, stating:

So, there are no miners’ fees to pay and no limit on how many transaction can be done at any time. The smart contracts prevent users from defrauding each other while the Bitcoin blockchain is used solely as a settlement layer, recording new balance transactions whenever a channel is opened or closed. It persists as the ultimate source of proof, a guarantee that all the “off-chain” Lightning transactions are legitimate.

What is not discussed in this edition is that:

  1. Lightning has been massively hyped with still relatively subdued traction
  2. Lightning is a separate network – it is not Bitcoin – and thus must be protected and secured through other non-mining means
  3. Lightning arguably distorts the potential transition to a fee-based Bitcoin network in much the same way that intermediaries like Coinbase do. That is to say, users are paying intermediaries the fees instead of miners thus prolonging the time that miners rely on block rewards (as a subsidy) instead of user fees.

Also, it bears mentioning that Bitcoin cannot in its current form act as a legal “settlement layer” as it cannot provide definitive settlement finality as outlined in the PFMIs (principle #8).

On p. 75 they write:

The SegWit/Lightning combination was in their minds the responsible way to make changes. They had a duty, they believed, to avoid big, disruptive codebase alterations and instead wanted to encourage innovators to develop applications that would augment the powers of the limited foundational code. It’s a classic, security-minded approach to protocol development: keep the core system at the bottom layer of the system simple, robust, and hard to change – some of the words “deliberately dumb” – and thus force innovation “up the stack” to the “application layer.” When it works you get the best of both worlds: security and innovation.

The authors should revise this because this is just repeating the talking points of specific Core developers, especially the last line.

Empirically it is possible to create a secure and “innovative” platform… and do so with multiple implementations of a specification. We see that in other cryptocurrencies and blockchain-related development efforts including Ethereum. The Bitcoin Core participants do not have a monopoly on what is or is not “security minded” and several of them are vocally opposed to supporting multiple implementations, in part, because of the politics around who controls the BIP process.

In fact, it could be argued that by insisting on the SegWit/Lightning approach, they caused a disruption because in point of fact, the amount of code that needed to be changed to increase the block size is arguably less than what was needed to build, verify, and release SegWit.

It’s not worth wading deep into these waters in this review, but the next edition of this book should be more even handed towards this schism.

On p. 76 they write:

But a group of miners with real clout was having none of it. Led by a Chinese company that both mined bitcoin and produced some of the most widely used mining equipment, this group was adamantly opposed to SegWit and Lightning. It’s not entirely clear what upset Jihan Wu, CEO of Bitmain, but after lining up with early Bitcoin investor and prominent libertarian Roger Ver, he launched a series of lobbying efforts to promote bigger blocks. One theory was that Bitmain worried that an “off-chain” Lightning solution would siphon away transaction fees that should be rightly going to miners; another was that because such payment channel transactions weren’t traceable as on-chain transactions, Chinese miners were worried that their government might shut them down. Bitmain’s reputation suffered a blow when revelations emerged that its popular Ant-miner mining rigs were being shipped to third-party miners with a “backdoor” that allowed the manufacturer-cum-miner to shut its opponents’ equipment down. Conspiracy theories abounded: Bitmain was planning to subvert SegWit. The company denied this and vowed to disable the feature. But trust was destroyed.

There is a lot of revisionism here.

But to start with, in the process of writing this review I reached out and contacted both Roger Ver and separately an advisor at Bitmain. Both told me that neither of the authors of this book had reached out to them for any comment. Why would the authors freely quote Bitcoin Core / SegWit developers to get their side of this debate but not reach out to speak with two prominent individuals from the other side to get their specific views? The next edition should either include these views and/or heavily revise this section of the book.

There are a few other problems with this passage.

Multiple different groups were actively lobbying and petitioning various influential figures (such as exchange operators) during this time period, not just Jihan and Roger. For instance, as mentioned above, the Hong Kong roundtable and New York agreement were two such examples. Conversely, SegWit and UASF was heavily promoted and lobbied by executives and affiliates at Blockstream and a handful of other organizations.

Regarding this “backdoor,” let’s rewind the clock and look at the overt / covert tempest in a teapot.

Last April Bitmain was alleged by Greg Maxwell (and the Antbleed campaign) of having maybe kinda sorta engaged in something called covert mining via Asicboost. Jimmy Song and others looked into it and said that there was no evidence covert was happening. At the time, some of the vocal self-identified “small block” supporters backing UASF, used this as evidence that Bitmain was a malicious Byzantine actor that must be purged from Bitcoinland. At the time, Greg proposed changing the PoW function in Bitcoin in order to prevent covert Asicboost from working.

In its defense, Bitmain stated that while Asicboost had been integrated into the mining equipment, it was never activated… partly because of the uncertain international IP / patent claims surrounding Asicboost. Recently, they announced a firmware upgrade that miners could activate overt Asicboost… a few days after another organization did (called “braiins”).

So why revisit this?

Two months ago Sia released code which specifically blocked mining equipment from Bitmain and Innosilicon. How and why this action is perceived as being fair or non-political is very confusing… they are definitely picking favorites (their own hardware). Certainly can’t claim to be sufficiently decentralized, right?

Yet in this section of the book, they don’t really touch on how key participants within the tribes and factions, represented at the time. Peruse both lists and look at all of the individuals at the roundtable that claim to represent “Bitcoin Core” in the governance process versus (the non-existent) reps from other implementations.

Even though the divorce is considered over, the tribes still fling mud at one another.

For example, one of the signatories of the HK roundtable, Adam Back, is still heckling Bitmain for supposedly not being involved in the BIP process. Wasn’t participation supposed to be “voluntary” and “permissionless”? Adam is also now fine with “overt” Asicboost today but wasn’t okay with it 18 months ago. What changed? Why was it supposedly bad for Bitmain to potentially use it back then but now it’s kosher because “braiins” (Slush) is doing it? That seems like favoritism.

Either way, the book passage above needs to be rewritten to include views from other camps and also to remove the still unproven conspiracy theories.

On p. 76 they write:

Meanwhile, original bitcoin went on a tear, rallying by more than 50 percent to a new high above $4,400 over a two-week period. The comparative performance of the pair suggested that small-block BTC and the SegWit reformers had won.

The next edition should change the wording because this comes across one-sided.

While an imperfect comparison, a more likely explanation is that of a Keynesian beauty contest. Most unsophisticated retail investors had heard of Bitcoin and hadn’t heard of Bitcoin Cash. Bitcoin (BTC) has brand recognition while Bitcoin Cash and the dozens of other Bitcoin-named forks and clones, did not.

Based on anecdotes, most coin speculators do not seem to care about the technical specifications of the coins they buy and typically keep the coins stored on an intermediary (such as an exchange) with the view that they can sell the coins later to someone else (e.g., “a greater fool“).

On p. 77 they write:

Bitcoin had gone through a ridiculous circus, one that many outsiders naturally assumed would hurt its reputation and undermine its support. Who wants such an ungovernable currency? Yet here was the original bitcoin surging to new heights and registering a staggering 650 percent gain in less than twelve months.

The problem with cherry picking price action dates is that, as seen in the passage above, it may not age well.17

For example, during the write-up of this review, the price of bitcoin declined from where it was a year ago (from over $10,000 then down to around $4,000). What does that mean? We can all guess what happened during this most recent bubble, but to act like non-tech savvy retail buyers bought bitcoin (BTC) because of SegWit is a non sequitur. No one but the tribalists in the civil war really cared.

On p. 77 they write:

Why? Well, for one, Bitcoin had proven itself resilient. Despite its civil war, its blockchain ledger remained intact. And, while it’s hard to see how the acrimony and bitterness was an advantage, the fact that it had proven so difficult to alter the code, to introduce a change to its monetary system, was seen by many as an important test of Bitcoin’s immutability.

There are a few issues here.

What do the authors mean by the “blockchain ledger remained intact”? I don’t think it was ever a question over whether or not copies of the Bitcoin blockchain (and/or forks thereof) would somehow be deleted. Might want to reword this in the future.

Segwit2x / Bitcoin Cash proponents were not trying to introduce a change to Bitcoin’s monetary system. The supply schedule of bitcoins would have stayed the same. The main issue was: a permanent block size increase from 1 MB to at least 2 MB. That proposal, if enacted, would not have changed the money supply.

What do the authors mean by “Bitcoin’s immutability”? The digital signatures are not being reversed or changed and that is what provides transactions the characteristic of “immutability.”

It is likely that the authors believe that a “hard fork” means that Bitcoin is not immutable. That seems to conflate “immutability” of a digital signature with finality (meaning irreversibility). By design, no proof-of-work coin can guarantee finality or irreversibility.

Also, Bitcoin had more than a dozen forks prior to the block size civil war.

On p. 77 and 78 they write:

Solid censorship resistance was, after all, a defining selling point for Bitcoin, the reason why some see the digital currency becoming a world reserve asset to replace the outdated, mutable, fiat-currency systems that still run the world. In fact, it could be argued that this failure to compromise and move forward, seen by outsiders as Bitcoin’s biggest flaw, might actually be its biggest feature. Like the simple, unchanging codebase of TCP/IP, the gridlocked politics of the Bitcoin protocol were imposing secure rigidity on the system and forcing innovation up the stack.

This is not what “censorship resistance” means in the context of Bitcoin. Censorship resistance is narrow and specific to what operators of miners could do. Specifically, the game theory behind Nakamoto Consensus is that it would be costly (resource intensive) for a malicious (Byzantine) actor to try and attempt to permanently censor transactions due to the amount of hashrate (proof-of-work) a Byzantine actor would need to control (e.g., more than 50%).

In contrast, what the authors described in this book was off-chain censorship, such as lobbying by various special interest groups at events, flamewars on Twitter, removing alternative views and voices on reddit, and via several other forms.

The “world reserve asset” is a loaded phrase that should be clarified in the next edition because the passage above comes across a bit like an Occupy Wall Street speech. It needs more of an explanation beyond the colorful one sentence it was given. Furthermore, as I predicted last year, cryptocurrencies continue to rely on the unit-of-account of “fiat systems” and shows no signs of letting up in this new era of “stablecoins.”

The authors definitely need to remove the part that says “unchanging codebase of TCP/IP” because this is not true. TCP/IP is a suite of protocol standards and its constituent implementations continue to evolve over time. There is no single monolithic codebase that lies unchanged since 1974 which is basically the takeaway from the passage above.18

In fact, several governing bodies such as IFTF and IAB continue to issue RFCs in order to help improve the quality-of-service of what we call the internet. It is also worth pointing out that their analogy is flawed for other reasons discussed in: Intranets and the Internet. In addition, the next version of HTTP won’t be using TCP.

As far as whether innovation will move “up the stack” remains to be seen but this seems to be an argument that the ends justify the means. If that is the case, that appears to open up a can of worms beyond the space for this review.

On p. 78 there is a typo: “BTH” instead of “BCH”

On p. 78 they write:

That’s what BTC, the original Bitcoin, promises with its depth of talent at Core and elsewhere. BTH can’t access such rich inventiveness because the community of money-focused bitcoin miners can’t attract the same kinds of passionate developers.

Strongly recommend removing this passage because it comes across as a one-sided marketing message rather than a balanced or neutral explanation using metrics. For instance, how active are the various code repositories for Bitcoin Core, Unlimited, and others? The next edition should attempt to measure how to measure “depth.”

For example, Bitmain has invested $50 million into a new fund focused on Bitcoin Cash called “Permissionless Ventures.” 2-3 years from now, what are the outcomes of that portfolio?

On p. 78 they write about permissioned blockchains:

Under these arrangements, some authority, such as a consortium of banks, choose which entities get to participate in the validation process. It is, in many respects, a step backward from Nakamoto’s achievement, since it makes the users of that permissioned system dependent once again, on the say-so of some trusted third party.

This is a common refrain throughout the book: that the true innovation was Bitcoin.

But it’s an apples-to-oranges comparison. Both worlds can and will co-exist because they were designed for different operating environments. Bitcoin cannot provide the same finality guarantees that “permissioned chains” attempt to do… because it was designed to be forkable. That’s not necessarily a flaw because Satoshi wasn’t trying to create a solution to a problem banks had. It’s okay to be different.

On p. 79 they write:

Most importantly, permissioned blockchains are more scalable than Bitcoin’s, at least for now, since their governance doesn’t depend upon the agreement of thousands of unidentified actors around the world; their members can simply agree to increase computing power whenever processing needs rise.

This doesn’t make sense at all. “Permissioned chains” in the broadest sense, do not use proof-of-work. As a result, there is no computational arms race. Not once have I been in a governance-related meeting involving banks in which they thought the solution to a governance-related issue was increasing or decreasing computational power. It is a non sequitur and should be removed in the next edition.

Also, there are plenty of governance issues involving “permissioned chains” — but those are typically tangential to the technical challenges and limitations around scaling a blockchain.

On p. 79 they write:

To us, permissionless systems pose the greatest opportunity. While there may well be great value in developing permissioned blockchains as an interim step toward a more open system, we believe permissionlessness and open access are ideals that we should strive for – notwithstanding the challenges exposed by Bitcoin’s “civil war.”

The authors repeat this statement in a couple other areas in the book and it doesn’t really make sense. Why? Because it is possible for both operating environments to co-exist. It doesn’t have to be us versus them. This is a false dichotomy.

Also, if any of these “permissioned chains” are actually put into production, it could be the case that end users could have “open access” to the platform, with the exception of participating in the validation of blocks. That’s pretty much how most coin users experience a cryptocurrency network today (e.g., via permissioned endpoints on Coinbase).19

On p. 80 they write:

The problem was that Bitcoin’s single-purpose currency design wasn’t ideally suited for these non-currency applications.

A side note maybe worth mentioning in a footnote is that Satoshi did attempt to build a marketplace early on but gave up.

On p. 81 they mention Nick Szabo with respect to smart contracts. Could be worth exploring the work of Martín Abadi which predates Szabo (the idea of distributed programs that perform authorizations predates Szabo’s “smart contracts”).  Mark S Miller has also done work in this area.

On p. 82 they write about Ethereum:

“Android for decentralized apps.” It would be an open platform much like Google’s smartphone operating system, on which people could design any new application they wanted and run it, not on a single company-owned server but in a decentralized manner across Ethereum’s ownerless network of computers.

This is probably not the best analogy because there is a difference between Google Android and Android Open Source Project. One of them includes proprietary tech. Also, Google can and does add and remove applications from the Play store on a regular basis based on its terms and conditions.

Lastly, someone does in fact own each of the computers that constitute the Ethereum blockchain… mining farms are owned by someone, mining pools are owned by someone, validating nodes are owned by someone. And so forth.

On p. 82 they write about Vitalik Buterin:

Now he was building a universally accessible, decentralized global supercomputer.

The next edition should drop the “supercomputer” verbiage because the Ethereum chain is only as powerful as the least powerful mining pool node… which in practice is typically a common computer located in a cloud provider such as AWS. This isn’t something like Summit over at Oak Ridge.

On p. 82 they write:

Now, with more than six hundred decentralized applications, or Dapps, running on Ethereum, he is looking vindicated. In just the first eleven months of 2017, the system’s internal currency, ether, rose from just over $8 to more than $400. By then the entire market cap for ether stood at $39 billion, a quarter that of Bitcoin’s. The success has made the wunderkind Buterin an instant multi-millionaire and turned him into a cultlike figure for the holders of ether and related tokens who’ve become rich.

The next version of the book should explicitly spell out what are the metrics for success. If it is solely price of a coin going up, what happens when the price of the coins goes down like it has in the past year?

For instance, ether (ETH), peaked in mid-January at around $1,400 and has been hovering near $100 the past several weeks. Does that mean Vitalik is no longer vindicated? Also, what is he vindicated from?

Lastly, it would be worth exploring in the next edition what Dapps are currently being used on a regular basis. As of this writing, the most popular Dapps are gambling apps (like proof-of-weak-hands / FOMO3D) and a few “decentralized exchanges” (DEX).

On p. 82 they write:

Ethereum co-founder Joseph Lubin only added to the complexity when he setup ConsenSys, a Brooklyn-based think tank-like business development unit tasked with developing new use cases and applications of the technology.

ConsenSys markets itself as a “venture studio” — a bit like YCombinator which incubates projects and provides some seed financing to get it off the ground. These projects are typically referred to as “spokes” (like a hub-and-spoke model).  As of this writing there are over 1,100 employees spread across several dozen spokes.  There is more to it than that and it would be interesting to see it explored in the next edition.

On p. 83 they write:

For example, the Parity Wallet, which was designed by Ethereum co-founder and lead architect Gavin Wood as a way to seamlessly engage, via a browser, with Ethereum smart contracts, lost $30 million in a hack.

Actually, Parity had a couple issues in 2017 and it is likely that the book may have been sent to publication around the same time the bigger problem occurred on November 13, 2017. The second one involved a Parity-developed multisig wallet… and $150 million in ether that is now locked away and cannot be accessed (barring a hardfork). Most developers — including those at Parity — characterize this instance as a “bug” that was accidentally exploited by a developer.

On p. 84 they write:

These kinds of dynamics, with large amounts of money at stake, can foster concerns that founders’ interests are misaligned with other users. Ethereum’s answer was the not-for-profit Ethereum Foundation, which was tasked with managing the pool of ether and other assets from the pre-mine and pre-sale- a model since used by many of the ICO token sales.

It would be interesting to explore how this foundation was created and how it evolved and who manages it today. For instance, at one point in 2014 there were conversations around creating a commercial, for-profit entity led in part by Charles Hoskinson who later left and founded Cardano.

On p. 85 they write about The DAO:

After a few modest coding changes failed, they settled on a drastic fix: Ethereum’s core developers “hard-forked” the Ethereum blockchain, implementing a backward-incompatible software update that invalidated all of the attacker’s transactions from a certain date forward. It was a radical move. To many in the cryptocurrency community, it threw into question Ethereum’s all-important claim to immutability. If a group of developers can force a change in the ledger to override the actions of a user, however unsavory those actions are, how can you trust that ledger won’t be tampered with or manipulated again in the interest of one group over another? Does that not destroy the whole value proposition?

This passage should probably be revised because of the usage of the word immutable.

Also, it could be argued that Bitcoin Core and other “core” groups act as gate keepers to the BIP process (or its equivalent) could lobby on behalf of special interest groups to push specific code changes and/or favor certain outcomes on behalf of specific stakeholders.

In either case, it is the miners that ultimately install and use the code. While some developers (like Bitcoin Core) are highly influential, without miners installing and running software, the rules on the network cannot be changed.

See Sufficiently Decentralized Howeycoins.

On p. 85 they write:

Well, in many respects, the Ethereum team operated as policymakers do during real-world crises. They made hard decisions that hurt some but were ultimately taken in the interests of the greater good — determined, hopefully, through as democratic a process as possible. The organizers went to great lengths to explain and gain support for the hard fork.

The next edition should strive to be more specific here: what exactly made the decision making around the hard fork democratic. Who participated, who didn’t participate. And so forth.

Continuing on p. 85:

And, much like the Segwit2x and other Bitcoin reform pro-miners didn’t accept it. For all intents and purposes, the fix was democratic – arguably, much more so than non-participatory democratic models through which crisis policymaking is enacted by national governments. And since Ethereum is more of a community of software engineers than of cryptocurrency investors, it was less contentious than Bitcoin’s struggle over hard-fork proposals.

This makes very little sense as it is written because the authors don’t define or specify what exactly made any of the decision making democratic. Who was enfranchised? Who got to vote and make decision? Also, how do the authors know that Ethereum is “more of a community of software engineers than of cryptocurrency investors.” Is there any hard numbers to back that assertion up?

And lastly how do we measure the level of contentiousness? Is there an objective measure out there?

On p. 85 they write about Ethereum Classic:

This created much confusion and some interesting arbitrage opportunities – as well as some lessons for bitcoin traders when their own currency split two years later – but it can also be viewed as the actions of a dissenting group non-violently exercising their right to secede. More than a year later, Ethereum Classic is still around, though it trades at a small fraction of Ethereum’s value, which means The DAO attacker’s funds – whose movements on the public Ethereum blockchain have been closely watched – are of lower value than if they’d been preserved in ETH.

I don’t think we can really say for sure how much the The DAO fund (and child DAO fundss) would be worth since that is an alternative timeline.

Also, there are some vocal maximalists that have created various Ethereum-branded tribes which are okay with The DAO attacker having access to those funds. Will be interesting to see if there are any sociological studies to reference in a new edition.

On p. 86 they write:

These hacks, and the scrambles to fix them, seem nuts, right? But let’s put them in perspective. First, is this monetary chaos anything less unsettling than the financial crisis of 2008? Or the audacity of the subsequent Wall Street trading scandals?

This is a whataboutism. Also, strangely the authors are saying the bar for judgement is as low as the financial engineering and socialized loses of the GFC. Isn’t the narrative that cryptocurrencies are supposed to be held to a higher standard because the coin creators seek to architect a world that doesn’t have arbitrary decision making?

On p. 87 and 88 they write:

When the FBI auctioned the 144,000 bitcoins (worth $1.4 billion as of late November 2017) that it seized from Ross Ulbricht, the convicted mastermind of the Silk Road illicit goods marketplace, those coins fetched a significantly higher price than others in the market. The notion was that hey had now been “whitewashed” by the U.S. government. In comparison, other bitcoins with a potentially shady past should be worth less because of the risk of future seizure. That’s hardly fair: imagine if the dollar notes in your wallet were hit with a 10 percent tax because the merchant knew that five years ago, unbeknownst to you, they had been handled by a drug dealer. To avoid these distortions and create a cryptocurrency that works more like fungible cash, Wilcox’s Zcash uses sophisticated “zero-knowledge proofs” to allow miners to prove that holders of the currency aren’t’ double-spending without being able to trace the addresses.

What the authors likely mean by “whitewashed” is probably “cleansed.” In the US there have been discussions on how this could take place via the existing Uniform Commercial Code (see Section 3.3). To date, there hasn’t been a specific update to the UCC regarding this issue (yet) but it has been discussed in multiple places such as Bitcoin’s lien problem.

As far as the “fairness” claim goes, it could be worth revising the passage to include a discussion around nemo dat quod non habet and bona fide purchasers. Legal tender is explicitly exempt because of the very scenario the authors describe. But cryptocurrencies aren’t legal tender, so that exemption doesn’t exist (yet).

Lastly, only “shielded” transactions in Zcash provide the functionality described in the passage above… not all transactions on Zcash utilize and opt-in to this mode.

On p. 89 they describe EOS. Worth updating this section because to-date, they have not achieved the 50,000 transactions per second on mainnet that is stated in the book. There has also been a bit of churn in the organizations as Ian Grigg (named in the book) is no longer at the organization, nor are employees 2 through 5.

On p. 90 they write about proof-of-stake:

One criticism of the model has been that without the electricity consumption costs of proof of work, attackers in a proof-of-stake system would simply mine multiple blocks to boost their chances of inserting a fraudulent one into the ledger.

This “nothing at stake” scenario is a valid criticism of some early attempts at building a proof-of-stake mechanism but isn’t valid for some other proposals (such as, theoretically, “Slasher“).

Chapter 4

On p. 91 they write:

It was clear that investors bought into Brave’s promise of a token that could fundamentally change the broken online advertising industry.

How do we know this was clear to investors? Anecdotally it appears that at least some investors participated as speculators, with the view that the token price would increase. A future edition should probably change the wording unless there is a reference that breaks down the motivation of the investors.

What about Civil?

On p. 96 they write about StorJ

Other models include that of the decentralized computer storage platform Storj, which allows hard-drive-starved users to access other’s excess space in exchange for storj tokens.

Could be worth pointing out that Storj had two public ICOs and it is still unclear if that will result in legal or regulatory issues. Putting that aside, currently Storj has just under 3,000 users. This stat is worth looking at again in future versions, especially in light of less-than-favorable reviews.

On p. 98 they talk about BAT:

The point is that it’s all on the community – the society of BATs users – not on external investors, to bear the risk of that happening

[…]

Once the 1 billion tokens had sold out in twenty-four seconds, it was revelead that only 130 accounts got them and that the biggest twenty holdings covered more than two-thirds of the total. Those distortions left many investors angry.

There is currently a debate around whether these types of ICOs in 2017 (and earlier) were investment contracts (e.g., securities). In the US, this has led to more than a hundred subpoenas with some quiet (and not so quiet) enforcement action.

The language used in this chapter (and elsewhere in the book) suggests that the participants involved in the ICO were investing with the expectation of profit in a common enterprise managed by the Brave team. Worth revisiting in a future edition.

On p. 102 they write about ERC20 tokens:

But because of the ERC-20 solution, they didn’t need to develop their own blockchain with all the independent computing power that would require. Instead, Ethereum’s existing computing network would do the validation for them.

This piggybacking may be initially helpful to token issuers but:

  1. it is a form of centralization which could have legal and regulatory consequences with respect to being viewed as not sufficiently decentralized
  2. in the long run this could create a top-heavy issue as miners are not being compensated in proportion to the amount of value they are trying to secure (see Section 2.1)

On p. 102 they write:

This low-cost solution to the double-spending challenge launched a factory of ICOs as issuers found an easy way to tap a global investing community. No painful negotiations with venture capitalists over dilution and control of the board. No wining and dining of Wall Street investment banks to get them to put their clients on the order book. No wait for SEC approval. Just straight to the general public: here are more tokens; they’re cool, buy them. It was a simple, low-cost formula and it lowered the barrier to entry for some brilliant innovators to bring potentially world-changing ideas to market. Unfortunately, it was also a magnet for scammers.

Could be worth updating this section to include more details on the scams and fraud that took place throughout 2017. Many of the tokens that raised capital from outside investors during this time not only have not delivered a working product, but in most cases, the token underperformed both ether and bitcoin.

Also bears mentioning that beginning in late 2017 through the time of this writing, there was a clear divergence between public sale ICOs and private sale of tokens… the latter of which basically involves a private placement to accredited investors, including the same type of funds that the passage above eschewed.

On p. 104 they write about Gnosis:

With the other 95 percent controlled by the founders, those prices meant that the implied valuation of the entire enterprise stood at $300 million – a figure that soon rose above $1 billion as the Gnosis token promptly quadrupled in price in the secondary market. By Silicon Valley standards, it meant we had the first ICO “unicorn.”

Actually, Ethereum did an ICO back in 2014 — and as the price of ether (measured in USD) increased, it is likely that ETH could be seen as the first ICO “unicorn.” But that’s not really an apples-to-apples comparison though because ETH (or Gnosis) holders do not have say, voting rights, which equity holders of a traditional company would.  Plus, “marketcap” is a poorly defined metric in the coin world (see Section 6).

On p. 104 and 105 they write:

One day, Paul received a call from a businessman who’d read one of his stories in The Wall Street Journal and wanted more information about how to get started and where to get legal advice. The man said he’d tried to reach the lawyer Marco Santori, a partner at the law firm Cooley who’d been quoted in the story, but couldn’t get through. Santori later told us that he was getting so many calls about ICOs, he simply couldn’t answer them all.

In January 2018, the SEC Chairman gave a public speech in which he singled out the “gatekeepers” (legal professionals) regarding the advice they gave clients. Could be worth revisiting who the main ICO-focused lawyers and lawfirms were during this time period and where they are now and if there were any enforcement actions undertaken.

On p. 105 they write:

“Most of these will fail,” said Olaf Carlson-Wee, the CEO of Polychain Capital, citing poorly conceived ideas and a lack of coding development. “Most of these are bad ideas from the beginning.” That said, Polychain is an investment firm that Carlson-Wee founded expressly to invest in these new projects. In fact, most of the people investing seemed to be taking a very VC-like approach to it. They understood that most of the projects would fail. They just hoped to have a few chips down on the one winner.

Carlson-Wee’s comments seem accurate insofar as the inability of many projects to execute and deliver based on the narratives each pitched investors. However, it could be worth digging into Polychain itself, which among other drama, may have “flipped” tokens due to a lack of lock-up periods.20 21

On p. 108 and 109 they compare Blue Apron and block.one (EOS). Even though it’s not an apples-to-apples comparison could be worth revisiting this in the future because of the churn and drama with both organizations.

Pages 110 and 111 aged quickly as most of the ICO rating websites and newsletters have fallen to the wayside due to payola scandals and inability to trust the motivations behind the ratings.

Similarly, the authors describe accredited investors and SAFTs. There is a typo here as the authors likely mean that an individual needs to have an income of $200,000 not $200 million. The SAFT model has fallen out of favor for several reasons that could be explored in a future version.22

On p. 112 they write about ASICs:

But developers of Vertcoin have shown that it’s also possible to create a permanent commitment to ASIC-resistance by introducing something from the real, non-digital world of social organizations: a pact. If the platform’s governing principles include a re-existing commitment from all users of the coin to accept a fork – a change to the code – that would add new, ASIC-resistant elements as soon as someone develops such a chip, the coin’s community can protect the distributed, democratic structure of a GPU-led mining network.

Putting aside the fanciful ASIC-resistance utopia that is peddled by some coin issuers, the passage above raises a couple flags.

Who gets to decide what the governing principles are? Do these principles get to change overtime? If the answer is yes to either, who are those decision makers and how are they chosen? So far, there has not really been any “democratic” way of participating in that decision making process for any cryptocurrency. How can that change in the future?

Why is a GPU-led mining network considered more democratic? In practice, most of these farms are located in basically the same type of structure and geography as ASIC-based equipment… in some cases they are swapped out over time. In light of the Sia coin fork… which clearly shows favoritism at play, a future edition of the book could include a chart or spectrum explaining how the mining of one coin more or less democratic versus another.

On p. 113 there is more discussion of ICOs and token sales as it relates to “open protocols” but in practice it has largely been reinventing the same intermediated system we have to do, but with fewer check and balances or even recourse for retail investors.

On p. 114 they speculate that:

This speaks to our broader notion that tokens, by incentivizing the preservation of public goods, might help humanity solve the Tragedy of the Commons, a centuries-in-the-making shift in economic reality.

That’s a big claim that requires evidence to back it. Let’s revisit next time.

On p. 115 they write:

Much like Wall Street bond traders, these will “make markets” to bring financial liquidity to every countervailing pair of tokens – buying some here and selling other there – so that if anyone wants to trade 100 BATs for a third of a Jackson Pollock, they can be assured of a reasonable market price.

But how does a blockchain actually do this? They mention Lykke as an startup that could help match tokens at a fair price… but to-date there is nothing listed on Lykke that really stands out as different than what you could fine at other cryptocurrency exchanges. Perhaps a future version of the book could walk the reader step-by-step through how a blockchain can enable this type of “fairness” whereas previous technology could not.

On p. 116 they discuss several projects they label as “interoperability” initiatives including Interledger, Cosmos, sidechains, and Lightning. It may be helpful for the reader to see a definition for what “interoperability” means because each of these projects — and its supporters — may be using the term in a different way. Perhaps a comparison chart showing the similarities and differences?

On p. 117 they write:

In an age where U.S. presidents peddle “alternative facts” and pundits talk openly about our “post-truth society,” using the truth machine to put a value on honesty sounds appealing.

On the face of it, that end goal seems like more than a stretch because it’s unclear how a blockchain (today) controls off-chain behavior. The example they go on to use is Augur. But Augur is a futures market and there are many of those already in existence. How would Augur or a futures market “with a blockchain” prevent politicians from lying? Walking through this process could be helpful to the reader.

On p. 118 they mention Erick Miller’s investment fund called CoinCircle… and a couple of “special value tokens” called Ocean Health Coin and Climate Coin.

Maybe worth following up in the next edition because neither has launched and each of the pitches sounds very handwavy, lacking in substance. Also, one of the ICOs CoinCircle advised – Unikrn – is part of a class action lawsuit.

Most of p. 119 and 120 come across as more political discourse, which is fine… but unclear how a blockchain in some form or fashion could directly impact the various issues raised. Perhaps the next edition could include a chart with a roadmap in how they see various projects achieving different milestones?

Chapter 5

If the reader is unfamiliar with IoT then the first 1/3 of chapter five is pretty helpful and informative.

Then there are some speedbumps.

On p. 130 they write about authenticating and verifying transactions involving self-driving cars:

The question, though, is: would this transaction be easily processed if it were based on a private blockchain? What are the chances, in a country of more than 230 million cars, that both vehicles would belong to the same closed network run by a group of permissioned validating computers? If they weren’t part of the same network, the payment couldn’t go through as the respective software would not be interoperable.

This is a red herring. Both “permissioned” and “permissionless” blockchains have similar (though not identical) scaling challenges. And interoperability is a separate issue which has been a known hurdle for years.

In fact, recently the Hyperledger Fabric team announced that it now supports the EVM. This comes a couple weeks after Hyperledger joined EEA as a member and vice-versa. Maybe none of these immediate efforts and experiments amount to many tangible outputs in the short-run but it does show that several ecosystems are attempting to be less tribal and more collaborative.

Also, the issue of payments is also separate from a blockchain-related infrastructure. Payments is a broad term and can include, for instance, a proposed central bank digital currency (e.g., “cash on ledger”)… or it can involve plugging into existing external payment systems (like Visa or ACH). It would be helpful if the next edition was more specific.

Continuing on p. 130 they write:

Other car manufacturers might not want to use a permissioned verification system for which, say GM, or Ford, is the gatekeeper. And if they instead formed a consortium of carmakers to run the system, would their collective control over this all-important data network create a barrier to entry for newer, startup carmakers? Would it effectively become a competition-killing oligopoly?

These are possible scenarios and good questions but this is kind of an unfair characterization of consortia. Let’s flip it around: why shouldn’t carmakers be allowed to build their own blockchains or collaborate with others who do? Do they need someones permission to do so? Depending on local regulations, maybe they do need permission or oversight in a specific jurisdiction. That could be worth exploring in another version.

On this topic they conclude that:

A truly decentralized, permissionless system could be a way around this “walled-garden” problem of siloed technology. A decentralized, permissionless system means any device can participate in the network yet still give everyone confidence in the integrity of the data, of the devices, and of the value being transacted. A permissionless system would create a much more fluid, expansive Internet of Things that’s not beholden to the say-so and fees of powerful gatekeepers.

That sounds well and good and a bit repetitive from earlier passages which said something similar. The passage aboves seems to be redefining what make something “permissioned” and “permissionless.” What does it mean for every device participate on a ‘decentralized, permissionless system’? Does that mean that each device is capable of building and/or creating a new block? If so, how do they choose which chain to build on?

And why is it so hard to imagine a world in which open-sourced platforms are also permissioned (e.g., validation is run by known, identifiable participants)… and these platforms are interoperable. Could be worth exploring because that scenario may be just as likely as the ones presented in this chapter.

Lastly, how does a “permissionless system” create a more fluid IoT world? These claims should be explored in more detail next time.

On p. 131 and 132 they write about IOTA, a specific project that markets itself as a purpose-built blockchain for IoT devices. But that project is beset by all kinds of drama that is beyond the scope of this review. Suffice to say that the February software build of IOTA cannot be run on most resource constrained IoT devices.

On p. 138 they mention in passing:

Exergy is a vital concept for measuring energy efficiency and containing wasteful practices; it doesn’t just measure the amount of energy generated but also the amount of useful work produced per each given amount of energy produced.

Fun fact: back in May 2014 I wrote an in-depth paper on Bitcoin mining that utilized the concept of “exergy.”

On pages 139-145 they talk about a number of vendors, use-cases, and platforms typically centered around the supply chain management world. Would be interesting to see which of these gained traction.

On p. 147 they write:

Blockchain-proven digital tokens point to what blockchain consultant and entrepreneurs Pindar Wong calls the “packetization of risk.” This radical idea introduces a negotiable structure to different phases of the chain. Intermediate goods that would otherwise be encumbered by a pre-established chain of unsettled commitments can instead be put out to bid to see if other buyers want to take on the rights and obligations associated with them.

It would be useful in this explanation to have a diagram or two to explain what Pindar proposes because it is a bit hard to follow.

On p. 147 they write:

This is why many people believe that the concept of a “circular economy” – where there is as much recycling as possible of the energy sources and materials in production – will hinge on the transparency and information flows that blockchain systems allow.

Does this mean that other “non-blockchain” systems do not allow transparency and information flows?

On p. 147 they write:

The principal challenge remains scaling. Open-to-all, permissionless blockcahins such as Bitcoin’s and Ethereum’s simply aren’t ready for the prime time of global trade. If all of the world’s supply chains were to pass their transactions through a permissionless blockchain, there would need to be a gargantuan increase in scalability, either off-chain or on-chain. Solutions may come from innovations such as the Lightning Network, discussed in chapter three, but they are far from ready at this stage.

Can we propose a moratorium on additional usages of “Lightning” in the next edition unless there is significant adoption and usage of it? Also, it is unclear why the worlds supply chains should for some reason be connected onto an anarchic chain: what is the benefit of putting this information onto a chain whose operators are unaccountable if a fork occurs?

On p. 148 they write:

Instead, companies are looking at permissioned blockchains, which we’ll discuss in more detail in chapter six. That makes sense because many big manufacturers think of their supply chains as static concepts, with defined members who have been certified to supply this or that component to a finished product. But in the rapidly changing world of the Fourth Industrial Revolution, this might not be the most competitive option. Emerging technologies such as additive manufacturing, where production can be called up anywhere and delivered by anyone with access to the right software files and a sufficiently configured 3D printer, are pointing to a much more fluid, dynamic supply-chain world, where suppliers come and go more easily. In that environment, a permissionless system would seem necessary. Once scaling challenges are resolved, and with robust encryption and reliable monitoring systems for proving the quality of suppliers work, permissionless blockchain-based supply chains could end up being a big leveler of the playing field for global manufacturing.

There are way too many assumptions in this paragraph to not have somewhere written that there are many assumptions.

Is a blockchain really needed in this environment? If so, a future edition should explain how a 3D printer would be more useful connected to a blockchain than some other network. Also, this seems to be a misuse of the term “permissionless” — why does the network need to be anarchic? How would the supply chain benefit from validators who are unknown?

On p. 148 they write:

It will be difficult to marry that old-world body of law, and the human-led institutions that manage it, with the digital, dematerailized, automated, and de-nationalized nature of blockchains and smart contracts.

How are blockchains “de-nationalized”? As of this writing there are probably a couple dozen publicly announced state-sponsored blockchain platforms of some kind (including various cryptocurrency-related initiatives). This phrase should probably be removed.

On p. 150 they write about the Belt and Road Blockchain Consortium:

Hence the opportunity for blockchain technologies to function as an international governance system. Hong Kong’s role will be important: the territory’s British legal traditions and reputation for respecting property rights have made it a respected safehouse for managing intellectual property and other contractual obligations within international trade. If the blockchain is to be inserted into global trade flows, the region’s bridging function may offer the fastest and most impactful route. For Hong Kong residents who want the territory to retain its British legal traditions, that role could be a vital protection against Beijing undermining them.

From publicly available information it is unclear if the Belt and Road Blockchain Consortium has seen much traction. In contrast, the Ping An-led HKMA trade finance group has turned on its “blockchain” platform.

Chapter 6

On p. 151 they wrote about a public event held on August 5, 2015:

As far as bankers were concerned, Bitcoin had no role to play in the existing financial system. Banking institutions thrive on a system of opacity in which our inability to trust each other leaves us dependent on their intermediation of our transactions. Bankers might give lip service to reforming the inner workings of their system, but the thought of turning it over to something as uncontrollable as Bitcoin was beyond heresy. It wasn’t even conceivable.

This is a bit of a red herring. I’ve been in dozens of meetings with banks and financial institutions over the past four years and in general there is consensus that Bitcoin – the network – is not fit for purpose as financial market infrastructure to handle regulated financial instruments. Why should banks process, say payments, on a network in which the validators are neither accountable if a problem occurs nor directly reachable in case users want to change or upgrade the software? Satoshi wasn’t trying to solve interbank-related issues between known participants so this description shouldn’t be seen as a slight against Bitcoin.

Now, bitcoin, the coin, may become more widespread in its usage and/or ownership at banks. In fact, as of this writing, nearly every large commercial bank owns at least a handful of cryptocurrencies in order to pay off ransomware issues. But the passage above seems to conflate the two.

See also: Systemically important cryptocurrency networks

On p. 151 they write:

At the same time, committed Bitcoin fans weren’t much interested in Wall Street, either. Bitcoin, after all, was designed as an alternative to the existing banking system. An improvement.

This is a bit revisionist. For instance, the original whitepaper uses the term “payment” twelve times. It doesn’t discuss banking or specific product lines at banks. Banks do a lot more than just handle payments too. Satoshi attempted to create an alternative payment system… the “be your own bank” narrative is something that other Bitcoin promoters later added.

On p. 152 they discuss the August 2015 event:

In essence, Symbiont was promising “blockchain without bitcoin” – it would maintain the fast, secure, and cheap distributed network model, and a truth machine at its center that validated transactions, but it was not leaderless, permissionless, and open to all. It was a blockchain that Wall Street could control.

This has some hyperbole in it (does “Wall Street” really control it?) but there is a kernel that the authors could expand on in the next version: vendor-dependence and implementation monopoly. In the example above, the authors could have pointed out that the same market structure still exists, so what benefit does a blockchain provide that couldn’t already be used? In addition to, what do the authors mean by “cheap distributed network model” when they have (rightly) mentioned that proof-of-work is resource intensive? As of this writing, Symbiont uses BFT-SMaRt and doesn’t use PoW.

Also, the authors seem to conflate “open to all” with blockchains that they prefer. Yet nearly all of the blockchains they seem to favor (like Bitcoin) involve relatively centralized gatekeeping (BIP process) and permissioned edges via exchanges.

Again, when I wrote the paper that created this distinction in 2015, the “permissionless’ness” is solely an attribute of mining not on sending or receiving coins.

On p. 153 they write:

But these permissioned systems are less open to experiments by computer engineers, and access rights to the data and software are subject to the whim of the official gatekeeper. That inherently constrains innovation. A private blockchain, some say, is an oxymoron. The whole point of this technology is to build a system that is open, accessible, and public. Many describe them with the generic phrase “distributed ledger technology” instead of “blockchain.”

This is why it would be important for the authors to explicitly mention what “blockchain” they are referring to. In many cases their point is valid: what is the point of using a blockchain if a single entity runs the network and/or monopolizes the implementation?

Yet their argument is diminished by insisting on using loaded phrases like “open” and “public.” What does it mean to be open or public here? For instance, in order to use Bitcoin today, you need to acquire it or mine it. There can be substantial entry and exit costs to mining so most individuals typically acquire bitcoins via a trusted, permissioned gateway (an exchange). How is that open?

Lastly, the euphemism of using the term “blockchain” instead of using the term “bitcoin” dates back to late 2015 with investors like Adam Draper explicitly stating that was his agenda. See: The great pivot?

On p. 156 they write:

Though Bitcoin fans frowned upon permissioned blockchains, Wall Street continued to build them. These tweaked versions of Bitcoin shared various elements of the cryptocurrency’s powerful cryptography and network rules. However, instead of its electricity-hungry “proof-of-work” consensus model, they drew upon older, pre-Bitcoin protocols that were more efficient but which couldn’t achieve the same level of security without putting a centralized entity in charge of identifying and authorizing participants.

There is a few issues with this:

  1. Which Bitcoin fans are the authors referring to, the maximalists?
  2. Proof-of-work is not an actual consensus model
  3. There are newer Byzantine fault tolerant protocols such as HoneybadgerBFT which are also being used by different platforms

Their last sentence uses a false dichotomy because there are different security assumptions based on the targeted operating environment that result in tradeoffs. To say that Bitcoin is more or less secure versus say, an instance of Fabric is a bit meaningless because the users have different expectations that the system is built around.

On p. 157 they write about R3:

The biggest winner in this hiring spree was the research and development company R3 CEV, which focused on the financial industry. It sought to build a distributed ledger that could, on the one hand, reap the benefits of real-time securities settlement and cross-industry harmonization but, on the other, would comply with a vast array of banking regulations and meet its members’ proprietary interest in keeping their books private.

This seems like a dated pitch from a couple use cases from mid-2015 because by the time I departed in September 2017, real-time securities settlement wasn’t the primary use (for Corda) being discussed externally.

Also, the “CEV” was formally removed from the name about two years ago. See: A brief history of R3 – the Distributed Ledger Group

By the spring of 2017, R3 CEV had grown its membership to more than one hundred. Each member firm paid annual dues of $250,000 in return for access to the insights being developed inside the R3 lab. Its founders also raised $107 million in venture funding in 2017, mostly from financial institutions.

I don’t think the full details are public but the description of the funding – and what was exchanged for it – is not quite correct. The original DLG members got equity stakes as part of their initial investment. Also, as far as the Series A that was announced in May 2017, all but one of the investors was a financial institution of some kind.

On p. 157 they write:

Some of that money went to hire people like Mike Hearn, a once prominent Bitcoin developer who dramatically turned his back on the cryptocurrency community with an “I quit” blog post complaining about the bitter in fighting. R3 also hired Ian Grigg – who later left to join EOS – another prominent onetime rebel from the cryptocurrency space.

To be clear on the timing: Mike Hearn began working at R3 in October 2015 (along with James Carlyle).23 Several months later he published a widely discussed post about Bitcoin itself. Based on his public talks since January 2016, he still seems to have some passing interest in cryptocurrencies; he did a reddit AMA on /r/btc this past spring.

Also, Ian Grigg has since left EOS and launched a new startup, Chamapesa.

On p. 157 they write about me:

Before their arrival, R3 had also signed on Tim Swanson as research director. Swanson was a distributed ledger/blockchain analyst who was briefly enthused by Bitcoin but who later became disillusioned with the cryptocurrency’s ideologues. He became a vocal, anti-Bitcoin gadfly who seemed to delight in mocking its travails.

This is also revisionist history.

Not to dive too much into the weeds here – and ignoring everything pre-2014 – a quick chronology that could be added if the authors are looking to be balanced is the following:

Over the course of under four months, after doing market research covering a few dozen projects, I published Great Chain of Numbers in March 2014… which was a brief report that quickly became outdated.

Some of the feedback I received – including from Bob, an expert at a data analytics startup – was that I was too charitable towards the claims of cryptocurrency promoters at payment processors and exchanges.24 That is to say, Bob thought that based on analytics, the actual usage of a payment processor was a lot lower than what the executives from that processor told me. In retrospect, Bob was absolutely correct.

A couple months later I ended up – by accident – doing an interview on Let’s Talk Bitcoin. The original guest did not show up and while we (the co-hosts) were waiting, I ended up getting into a small debate with another co-host about the adoption and usage of cryptocurrencies like Bitcoin. You can listen to it here and read the corresponding long-read that provides more citations and supporting links to back up the comments I made in the podcast.

From this moment forward (June 2014) – because I fact-checked the claims and did not blindly promote cryptocurrencies – I quickly became labeled as a pariah by several of the vocal cryptotwitter personalities. Or as the authors of this book unfairly label me: “anti-Bitcoin gadfly.” To call this order of events “disillusionment” is also unfair.

Lastly, a quick fix to the passage in the book: I technically became a formal advisor to R3 at the end of 2014 (after their second roundtable in Palo Alto)… and then later in August 2015 came on full-time as director of market research (although I subsequently wore several different hats).

On p. 158 they write:

Of a similar breed was Preston Byrne, the general counsel of Eris Ltd., later called Monax which designed private blockchains for banks and a variety of other companies. When Byrne’s Twitter feed wasn’t conveying his eclectic mix of political positions – pro-Trump, anti-Brexit, pro-Second Amendment, pro-encryption, anti-software utopianism – or constant references to marmots (the Eris brand’s mascot), it poured scorn on Bitcoin’s fanatic followers. For guys like Swanson and Byrne, Bitcoin’s dysfunctional governance was a godsend.

Again, chronologically I met Preston online in early 2014. He helped edit and contributed to Great Chain of Numbers. Note: he left Eris last year and recently joined a US law firm.

This is an unfair description: “For guys like Swanson and Byrne, Bitcoin’s dysfunctional governance was a godsend.”

This is unfair for several reasons:

  • We were hardly the first people to spend time writing about the governance problems and frictions involved in cryptocurrencies. For instance this includes: Ray Dillinger, Ben Laurie, and likely dozens of others. Nor were we the only ones discussing it in 2014 and 2015.
  • Preston and I have also – separately – written and discussed issues with other cryptocurrencies and blockchains during that time frame… not just Bitcoin.

Thus to single us out and simultaneously not mention others who had similar views, paints us as some type of cartoonish villains in this narrative. Plus, the authors could have reached out to us for comment. Either way, the next version should attempt to fix the word choices and chronology.

I reached out to Preston Byrne and he provided a response that he asked to have included in a footnote.25

On p. 159 they write more about R3:

On the one hand, regulators were comfortable with the familiar membership of R3’s consortium: they were more accustomed to working with bankers than with T-shirt-and-jeans-wearing crypto-investors. But on the other, the idea of a consortium of the world’s biggest banks having say-so over who and what gets included within the financial system’s single and only distributed ledger conjured up fears of excessive banking power and of the politically unpopular bailouts that happened after the crisis. Might Wall Street be building a “too-big-to-fail” blockchain?

This is some strange criticism because many of the developers of Corda (and other pieces of software) wore casual and business casual attire while working in the offices.

Corda is not the “single and only distributed ledger” being used by enterprises. Nearly all of the banks that invested in R3 also invested in other competing entities and organizations including Axoni and Digital Asset. Thus the statement in the middle should be updated to reflect that R3 does not have some kind of exclusivity over banking or enterprise relationships.

Michael Casey has said multiple times in public (even prior to the existence of Corda) that R3 was a “cartel coin” or “cartel chain” — including on at least one panel I was on with him in January 2016.  This is during a time in which R3 did not have or sell any type of product, it was strictly a services-focused company.  Maybe the organization evolves in the future – there may even be some valid criticism of a mono-implementation or a centrally run notary – but even as of this writing there is no Corda Enterprise network up and running.26

Lastly, all of these banks are members of many different types of consortia and multilateral bodies. Simply belonging to or participating in organizations such as IOSCO does not mean something nefarious is afoot.

On p. 160 they write:

The settlement time is also a factor in a financial crisis, and it contributed to the global panic of 2008.

This is a good point and it would be great to go into further details and examples in the next edition.

On p. 160 they write:

This systemic risk problem is what drew Blythe Masters, one of the key figures behind blockchain innovation on Wall Street, into digital ledger technology; she joined Digital Asset Holdings, a blockchain service provider for the financial system’s back-office processing tasks, as CEO in 2014.

Two small quibbles:

  1. Pretty sure the authors meant to say “distributed” not “digital”
  2. Blythe Masters joined as CEO in March 2015, not in 2014

On p. 162 they write:

It’s just that to address such breakdowns, this new wave of distributed ledger system designers have cherry-picked the features of Nakamoto’s invention that are least threatening to the players in the banking system, such as its cryptographic integrity, and left aside its more radical, and arguably more powerful, features, especially the decentralized, permissionless consensus system.

This is revisionist history. Satoshi bundled together existing ideas and libraries to create a blockchain. He or she did not invent cryptography from the ground up. For more details, readers are encouraged to read “Bitcoin is worse is better” from Gwern Branwen. IT systems at financial institutions were (and are) already using various bits of cryptography, encryption, permissioning, data lakes, and distributed storage methods.

Furthermore, because the participants in the financial system are known, there is no reason to use proof-of-work, which is used in Bitcoin because the participants (miners) are unknown.

Lastly, the authors touch on it and do have a valid point about market structure being changed (or unchanged) and should try to expand that in the next edition.

On p. 162 they write:

The DTCC, which settles and clears the vast majority of US stock and bond trades, handles 10,000 transactions per second; Bitcoin, at the time of this writing, could process just seven. And as strong as Bitcoin’s value – and incentive-based security model has proven to be, it’s not at all clear that a few hundred million dollars in bitcoin mining costs would deter rogue traders in New York or London when government bond markets offer billion dollar fraud opportunities.

Firstly, at the time of this writing, on-chain capacity for Bitcoin (even with Segwit activated) is still less than seven transaction per second.

Second, it is not clear how “rogue traders” in New York or London would be able to directly subvert the mining process of Bitcoin. Are the authors thinking about the potential security delta caused by watermarked tokens and colored coins?27

On p. 162 they write:

Either way, for the firms that R3 and Digital Asset serve – managers of the world’s retirement funds, corporate payrolls, government bond issuances, and so forth -these are not security risks they can afford. For now – at least until solutions as Lightning provide large-scale transaction abilities – Bitcoin isn’t anywhere near ready to service Wall Street’s back-office needs.

But Bitcoin is not fit for purpose for regulated financial institutions. Satoshi wasn’t trying to solve back-office problems that enterprises had, why are the authors intent on fitting a round peg in a square hole?

Also, Lightning isn’t being designed with institutions in mind either. Even if one or more of its implementations becomes widely adopted and used by Bitcoin users, it still doesn’t (currently) meet the functional and non-functional requirements that regulated institutions have. Why market it as if it does?

On p. 162 they write:

There are also legal concerns. R3’s Swanson has argued that the mere possibility of a 51 percent attack – that scenario in which a minder gains majority control of a cryptocurrency network’s computing power and fraudulently changes transactions – means that there can never be “settlement finality” in a cryptocurrency transaction. That of perpetual limbo is a scenario that Wall Street lawyers can’t live with, he said. We might retort that the bailouts and various other deals which banks reversed their losses during the crisis make a mockery of “finality,” and that Bitcoin’s track record of irreversibility is many magnitudes better than Wall Street’s. Nonetheless, Swanson’s catchy critique caught on among bankers. After all, he was preaching to the choir.

So there are a few issues with this statement.

I did not invent the concept of “settlement finality” nor did ‘Wall Street lawyers.’  The term dates back decades if not centuries and in its most recent incarnation is the product of international regulatory bodies such as BIS and IOSCO. Regulated financial institutions – starting with financial market infrastructures – are tasked with reducing risk by making sure the payment systems, for instance, are irreversible. Readers should peruse the PFMIs published in 2012.

The next issue is, they make it sound like I lobbied banks using some ‘gotcha’ loophole to scare banks from using Bitcoin. Nowhere in my presentations or speeches have I justified or handwaved away the (criminally?) negligent behavior of individuals at banks that may have benefited from bailouts. This is another unfair characterization that they have painted me as.

To that point, they need to be more specific about what banks got specific transactions reversed. Name and shame the organizations and explain how it would not be possible in a blockchain-based world. Comparing Bitcoin with ‘Wall Street’ doesn’t make much sense because Bitcoin just handles transfers of bitcoin, nothing else. ‘Wall Street’ encompasses many different product lines and processes many other types of transactions beyond payments.

All in all, painting me as a villain is weak criticism and they should remove it in their next edition.

On p. 163 they write about permissioned ledgers:

They’re not racing each other to win currency rewards, which also means they’re not constantly building a wasteful computing infrastructure a la Bitcoin.

They say that as if it is a good thing. Encourage readers to look through the energy costs of maintaining several different proof-of-work networks that handle almost no commerce.

On p. 163 they write:

That’s why we argue that individuals, businesses, and governments really need to support the various hard-core technical solutions that developers are pursuing to help permissionless ledgers like Bitcoin and Ethereum overcome their scaling, security, and political challenges.

This agenda has been pretty clear throughout the book, though it may be more transparent to the reader if it comes earlier in chapter 1 or 2.

From a historical perspective this argument doesn’t make much sense. If Karl Benz had said the same thing in the 19th century about getting engineers to build around his car and not others. Or the Wright Brothers had been ‘more successful’ at suing aerospace competitors. Why not let the market – and its participants – chose to work on platforms they find of interest?

On p. 165 they write about the MIT Digital Currency Inititative but do not disclose that they solicit financial support from organizations such as central banks, some of whom pay up to $1 million a year to collaborate on research projects. Ironically, the details of this program are not public.

On p. 167 they write:

A broad corporate consortium dedicated to a mostly open-source collaborative approach, Hyperledger is seeking to develop nothing less than a common blockchain / distributed ledger infrastructure for the global economy, one that’s targeted not only at finance and banking but also at the Internet of Things, supply chains, and manufacturing.

The next edition should update that passage. All of the projects incubated by the Hyperledger Project are open sourced, there is no “mostly.” And not all of these projects involve a blockchain, some involve identity-related efforts.28

On p. 169 and again on p. 172 the authors quote Joi Ito who compares TCP/IP with “walled gardens” such as AOL and Prodigy.

That is comparing apples-and-oranges. TCP/IP is a suite of protocols, not a business. AOL and Prodigy are businesses, not protocols. AOL used a proprietary protocol and you could use TCP/IP via a gateway. Today, there are thousands of ‘walled gardens’ called ISPs that allow packets to jump across boundaries via handshake agreements. There is no singular ‘Internet’ but instead there are thousands of intranets tied together using common standards.

Readers may be interested in: Intranets and the Internet

On p. 173 they write:

Permissionless systems like those of Bitcoin and Ethereum inherently facilitate more creativity and innovation, because it’s just understood that no authorizing company or group of companies can ever say this or that thing cannot be built.

How are they measuring this? Also, while each platform has its own terms of service, it cannot be said that you need explicit permission to build an application on top of a specific permissioned platform. The permissioning has to do with how validation is handled.

On p. 173 they write:

It’s the guarantee of open access that fosters enthusiasm and passion for “permissionlessness” networks That’s already evident in the caliber and rapid expansion in the number of developers working on public blockchain applications. Permissioned systems will have their place, if nothing else because they can be more easily programmed at this early stage of the technology’s life to handle heavier transaction loads. But the overarching objective for all of us should be to encourage the evolution of an open, interoperable permissionless network.

This is just word salad that lacks supporting evidence. For the next edition the authors should tabulate or provide a source for how many developers are working on public blockchain applications.

The passage above also continues to repeat a false dichotomy of “us versus them.” Why can’t both of these types of ‘platforms’ live in co-existence? Why does it have to be just one since neither platform can fulfill the requirements of the other?

It’s like saying only helicopters provide the freedom to navigate and that folks working on airplanes are only doing so because they are less restricted with distances. Specialization is a real.

On p. 173 they conclude with:

There’s a reason we want a world of open, public blockchains and distributed trust models that gives everybody a seat at the table. Let’s keep our eyes on that ball.

This whole chapter and this specific statement alone comes across as preachy and a bit paternalistic. If the message is ‘permissionlessness’ then we should be allowed to pursue our own goals and paths on this topic.

Also, there are real entry and exit costs to be a miner on these public chains so from an infrastructure point of view, it is not really accurate to say everybody gets a seat at the table.

Chapter 7

This is probably their strongest chapter. They do a good job story telling here. Though there were few areas that were not clear.

On p. 179 they write:

But as Bitcoin and the blockchain have shown, the peer-to-peer system of digital exchange, which avoids the cumbersome, expensive, and inherently exclusionary banking system, may offer a better way.

The authors have said 5-6 times already that proof-of-work networks like Bitcoin can be very costly and wasteful to maintain. It would be helpful to the reader for the authors to expand on what areas the banking system is expensive.

And if a bank or group of banks used a permissioned blockchain, would that reduce their expenses?

On p. 181 they write about time stamps:

The stamp, though, is incredibly powerful. And that, essentially, is the service that blockchains provide to people. This public, recognizable open ledger, which can be checked by any time by anybody, acts in much the same way as the notary stamp: it codified that certain action took place at a certain time, with certain particulars attached to it, and it does this in a way that the record of that transaction cannot be altered by private parties, whether they be individuals or governments.

In the next edition the authors should differentiate time stamps and all the functions a notary does. Time stamps may empower notaries but simply stamping something doesn’t necessarily make it notarized. We see this with electronic signatures from Hello Sign and Docusign.

Also, these blockchains have to be funded or subsidized in some manner otherwise they could join the graveyard of hundreds of dead coins.

On p. 181 they write about Factom and Stampery. It would be good to get an update on these types of companies because the founder of Stampery who they single out – Luis Ivan Cuende – has moved on to join and found Aragon.

On p. 183 they discuss data anchoring: taking a hash of data (hash of a document) and placing that into a blockchain so that it can be witnessed. This goes back to the proof-of-existence discussion earlier on. Its function has probably been overstated and is discussed in Anchor’s Aweigh.

On p. 184 they discuss Chromaway. This section should be updated because they have come out with their own private blockchain, Chromapolis funded via a SAFT.

On p. 185 they write:

The easier thing to do, then, for a reform-minded government, is to hire a startup that’s willing to go through the process of converting all of an existing registry, if one exists, into a digital format that can be recorded in a blockchain.

Why? Why does this information have to be put onto a blockchain? And why is a startup the right entity to do this?

On p. 186 they mention several companies such as Bitfury, BitLand, and Ubiquity. It would be good to update these in the next edition to see if any traction occurred.

On p. 187 they write:

They key reason for that is the “garbage-in/garbage-out” conundrum: when beginning records are unreliable, there’s a risk of creating an indisputable permanence to information that enshrines some abuse of a person’s property rights.

This GIGO conundrum doesn’t stop and isn’t limited to just the beginning of record keeping. It is an ongoing challenge, potentially in every country.

On p. 188-192 they describe several other use cases and projects but it is unclear why they can’t just use a database.

On p. 193 they write:

Part of the problem is that cryptocurrencies continue to sustain a reptutation among the general public for criminality. This was intensified by the massive “WannaCry” ransomware attacks of 2017 in which attackers broke into hospitals’ and other institutions’ databases, encrypted their vital files and then extorted payments in bitcoin to have the data decrypted. (In response to the calls to ban bitcoin that inevitably arose in the wake of this episode, we like to point that far more illegal activity and money laundering occurs in dollar notes, which are much harder to trace than bitcoin transactions. Still, when it comes to perception, that’s beside the point – none of these incidents help Bitcoin’s reputation.)

This is a whataboutism. Both actions can be unethical and criminal, there is no need to downplay one versus the other. And the reason why bitcoin and other cryptocurrencies are used by ransomware authors is because they are genuinely useful in their operating environment. Data kidnapping is a good use case for anarchic networks… and cryptocurrencies, by design, continue to enable this activity. The authors can attempt to downplay the criminal element, but it hasn’t gone away and in fact, has been aided by additional liquidity to coins that provide additional privacy and confidentiality (like Monero).

On p. 193 they write about volatility:

This is a massive barrier to Bitcoin achieving its great promise as a tool to achieve financial inclusion. A Jamaican immigrant in Miami might find the near-zero fees on a bitcoin transaction more appealing than the 9 percent it costs to use a Western Union agent to send money home to his mother.

This financial inclusion narrative is something that Bitcoin promoters created after Satoshi disappeared. The goal of Bitcoin — according to the whitepaper and announcement threads – wasn’t to be a new rail for remittance corridors. Maybe it becomes used that way, but the wording in the passage above as a “great promise” is misleading.

Also, the remittance costs above should be fact-checked at the very handy Save On Send site.

On p. 194 they write about BitPesa. Until we see real numbers in Companies House filings, it means their revenue is tiny. Yet the authors make it sound like they have “succeeded”:

The approach is paying dividends as evident in the recent success of BitPesa, which was established in 2013 and was profiled in The Age of Cryptocurrency. The company, which offers cross-border payments and foreign-exchange transactions in and out of Kenya, Nigeria, Tanzania, and Uganda, reported 25 percent month-on-month growth, taking its transaction volume midway through 2017, up from $1 million in 2016.

They also cited some remittance figures from South Korea to the Philippines which were never independently verified and are old.

On p. 194 they dive into Abra a company they described as a remittance company but earlier this year they pivoted into the investment app category as a Robinhood-wannabe, with a coin index.

On p. 196 they discuss the “Somalia dilemma” in which the entire country is effectively unable to access external financial systems and somehow a blockhain would solve their KYC woes. The authors then describe young companies such as Chainalysis and Elliptic which work with law enforcement to identify suspicious transactions. Yet they do not close the loop on the narrative as to how the companies would help the average person in Somalia.

On p. 198 they discuss a startup called WeTrust and mention that one of the authors – Michael – is an advisor. But don’t disclose if he received any compensation for being an advisor. WeTrust did an ICO last year. This is important because the SEC just announced it has fined and settled with Floyd Mayweather and DJ Khaled for violating anti-touting regulations.

Chapter 8

Chapter 8 dives into self-sovereign identity which is genuinely an interesting topic. It is probably the shortest chapter and perhaps in the next edition can be updated to reflect any adoption that took place.

On p. 209 they write about physical identification cards:

Already, in the age of powerful big data and network analytics – now enhanced with blockchain-based distributed trust systems to assure data integrity – our digital records are more reliable indicators of the behavior that defines who we are than are the error-prone attestations that go into easily forged passports and laminated cards.

How common and how easily forged are passports? Would be interesting to see that reference and specifically how a blockchain would actually stop that from happening.

On p. 212 they write about single-sign ons:

A group of banks including BBVA, CIBC, ING, Societe Generale, and UBS has already developed such a proof of concept in conjunction with blockchain research outfit R3 CEV.

Earlier they described R3 differently. Would be good to see more consistency and also an update on this project (did it go anywhere?).

On p. 213 they describe ConsenSys as a “think tank” but it is actually a ‘venture studio’ similar to an incubator (like 500 Startups). Later on p. 233 they describe ConsenSys as an “Ethereum-based lab”.

On p. 216 they write about Andreas Antonopoulos:

What we should be doing, instead of acting as judge and executioner and making assumptions “that past behavior will give me some insight into future behavior,” Antonpolous argues, is building systems that better manage default risk within lenders’ portfolios. Bitcoin, he sustains, has the tolls to do so. There’s a lot of power in this technology to protect against risk: smart contracts, multi-signature controls that ensure that neither of the two parties can run off with the funds without the other also signing a transaction, automated escrow arrangements, and more broadly, the superior transparency and granularity of information on the public ledger.

There are at least two issues with this:

Nowhere in this section do the authors – or Antonopolous – provide specific details for how someone could build a system that manages default risk on top of Bitcoin. It would be helpful if this was added in the next edition.
And recently, Antonopoulos claims to have been simply educating people about “blockchain technology” and not promoting financial products.

If you have followed his affinity marketing over the past 4-5 years he has clearly promoted Bitcoin usage as a type of ‘self-sovereign bank‘ — and you can’t use Bitcoin without bitcoins.29 He seems to be trying to have his cake and eat it too and as a result got called out by both Nouriel and Buttcoin.

On p. 219 they write:

If an attestation of identifying information is locked into an immutable blockchain environment, it can’t be revoked, not without both parties agreeing ot the reversal of the transaction. That’s how we get to self-sovereignty. It’s why, for example, the folks at Learning Machine are developing a product to prove people’s educational bona fides on Blockcerts, an MIT Media Lab-initiated open-source code for notarizing university transcripts that hashes those documents to the bitcoin blockchain. Note the deliberate choice of the most secure, permissionless blockchain, Bitcoin’s. A permissioned blockchain would fall short of the ideal because there, too, the central authority controlling the network could always override the private keys of the individual and could revoke their educational certificates. A permissionless blockchain is the only way to give real control/ownership of the document to the graduate, so that he/she can disclose this particularly important attribute at will to anyone who demands it.

This disdain for ‘permissioned blockchains’ is a red herring and another example of the “us versus them” language that is used throughout the book. If a blockchain has a central authority that can do what the authors describe, it would be rightly described as a single point of failure and trust. And this is why it is important to ask what ‘permissioned’ chain they had in mind, because they are not all the same.

They also need to explain how they measure ‘most secure’ because Bitcoin – as described throughout this review – has several areas of centralization include mining and those who control the BIP process.

On p. 219 they quote Chris Allen. Could be worth updating this because he left Blockstream last year.

Chapter 9

This chapter seemed light on details and a bit polemical.

For instance, on p. 223 they write:

Many of our politicians seem to have no ideas this is coming. In the United States, Donald Trump pushes a “Buy America First” campaign (complete with that slogan’s echoes of past fascism), backed by threats to raise tariffs, tear up trade deals, boot undocumented immigrants out of the country, and “do good deals for America.” None of this addresses the looming juggernaut of decentralized software systems. IoT systems and 3D printing, all connected via blockchains and smart-contract-triggered, on-demand service agreements, will render each presidential attempt to strong-arm a company into retaining a few hundred jobs in this or that factory town even more meaningless.

Putting the politics aside for a moment, this book does not provide a detailed blue print for how any of the technology listed will prevent a US president from strong-arming a company to do any specific task. How does a 3D printer connected to a blockchain prevent a president from executing on their agenda?

On p. 224 they write about universal basic income:

This idea, first floated by Thomas Paine in the eighteenth century, has enjoyed a resurgence on the left as people have contemplated how robotics, artificial intelligence, and other technologies would hit working-class jobs such as truck driving. But it may gain wider traction as decentralizing force based on blockchain models start destroying middle-class jobs.

This speculation seems like a non sequitur. Nowhere in the chapter do they detail how a “blockchain-based model” will destroy middle class jobs. What is an example?

On p. 227 they write:

In case you’re a little snobbish about such lowbrow art, we should also point out that a similar mind-set of collaborative creation now drives the world of science and innovation. Most prominently, this occurs within the world of open-source software development; Bitcoin and Ethereum are the most important examples of that.

If readers were unfamiliar with the long history of the free open source software movement, they might believe that. But this ignores the contributions of BSD, Linux, Apache, and many other projects that are regularly used each and every day by enterprises of all shapes and sizes.

Also, during the writing of this review, an open source library was compromised — potentially impacting the Copay wallet from Bitpay — and no one noticed (at first). Eric Diehl, a security expert at Sony, has a succinct post up on the topic:

In other words, this is an example of a software supply chain attack. One element in the supply chain (here a library) has been compromised. Such an attack is not a surprise. Nevertheless, it raises a question about the security of open source components.

Many years ago, the motto was “Open source is more secure than proprietary solutions.” The primary rationale was that many eyes reviewed the code and we all know that code review is key for secure software. In the early days of open source, this motto may have been mostly true, under some specific trust models ( see https://eric-diehl.com/is-open-source-more-secure/, Chapter 12 of Securing Digital Video…). Is it still true in our days?

How often do these types of compromises take place in open-source software?

On p. 232 they write:

Undaunted, an unofficial alliance of technologists, entrepreneurs, artists, musicians, lawyers, and disruption-wary music executives is now exploring a blockchain-led approach to the entire enterprise of human expression.

What does that even mean?

On p. 232 they write about taking a hash of their first book and inserting it into a block on the Bitcoin blockchain. They then quote Dan Ardle from the Digital Currency Council who says:

“This hash is unique to the book, and therefore could not have been generated before the book existed. By embedding this hash in a bitcoin transaction, the existence of the book on that transaction date is logged in the most secure and irrefutable recordkeeping system humanity has ever devised.”

These plattitudes are everywhere in the book and should be toned down in the next edition especially since Ardle – at least in the quote – doesn’t explain how he measures secure or irrefutable. Especially in light of hundreds of dead coins that were not sustainable.

On p. 233 they write:

The hope now is that blockchains could fulfill the same function that photographers carry out when they put a limited number of tags and signatures on reproduced photo prints: it turns an otherwise replicable piece of content into a unique asset, in this case a digital asset.

This seems to be solutionism because blockchains are not some new form of DRM.

Continuing on this topic, they write:

Copying a digital file of text, music, or vidoe has always been trivial. Now, with blockchain-based models, Koonce says, “we are seeing systems develop that can unequivocally ensure that a particular digital ‘edition’ of a creative work is the only one that can be legitimately transferred or sold.” Recall that the blockchain, as we explained in chapter three, made the concept of a digital asset possible for the first time.

This is empirically untrue. It is still trivially possible to download and clone a blockchain, nothing currently prevents that from happening. It’s why there are more than 2,000 cryptocurrencies at the time of this writing and why there are dozens of forks of Bitcoin: blockchains did not make the concept of a digital asset possible. Digital assets existed prior to the creation of Bitcoin and attempting to build a DRM system to prevent unauthorized copies does not necessarily require a blockchain to do.

On p. 238 they write:

Yet, given the amssive, multitudinous, and hetergeneous state of the world’s content, with hundreds of millions of would-be creators spread all over the world and no way to organize themselves as a common interest, there’s likely a need for a permissionless, decentralized system in which the data can’t be restricted and manipulated by a centralized institution such as a recording studio.

Maybe, but who maintains the decentralized system? They don’t run themselves and are often quite expensive (as even the authors have mentioned multiple times). How does a decentralized system fix this issue? And don’t some artists already coordinate via different interest groups like the RIAA and MPAA?

On p. 240 they discuss Mediachain’s acquisition by Spotify:

On the other hand, this could result in a private company taking a technology that could have been used publicly, broadly for the general good, and hiding it, along with its innovative ideas for tokens and other solutions, behind a for-profit wall. Let’s hope it’s not the latter.

This chapter would have been a bit more interesting if the authors weren’t as heavy handed and opinionated about how economic activities (like M&A) should or should not occur. To improve their argument, they could include links or citations for why this type of acquisition has historically harmed the general public.

Chapter 10

On p. 243 they write:

Bitcoin, with its new model of decentralized governance for the digital economy, did not spring out of nowhere, either. Some of the elements – cryptography, for instance – are thousands of years old. Others, like the idea of electronic money, are decades old. And, as should be evident in Bitcoin’s block-size debate, Bitcoin is still very much a work in progress.

This statement is strange because it is inconsistent with what they wrote on p. 162 regarding permissioned chains: “… cherry-picked the features of Nakamoto’s invention that are least threatening to the players in the banking system, such as its cryptographic integrity…”

In this section they are saying that the ideas are old, but in the passage above in chapter 6, they make it sound like it was all from Nakamoto. The authors should edit it to be one way or the other.

Also, Bitcoin’s governance now basically consists of off-chain shouting matches on social media. Massive influence and lobbying campaigns on reddit and Twitter is effectively how the UASF / no2x movement took control of the direction of the BIP process last year.

On p. 245 they write:

That can be found in the individual freedom principles that guide the best elements of Europe’s new General Data Protection Regulation, or GDPR.

All blockchains that involve cross-jurisdictional movement of data will likely face challenges regarding compliance with data privacy laws such as GDPR. Michele Finck published a relevant paper on this topic a year ago.

See also: Clouds and Chains

On p. 247 they write about if you need to use a blockchain:

Since a community must spend significant resources to prove transactions on a blockchain, that type of record-keeping system is most valuable when a high degree of mutual mistrust means that managing agreements comes at a prohibitively high price. (That price can be measured in various ways: in fees paid to middlemen, for instance, in the time it takes to reconcile and settle transactions, or in the fact that it’s impossible to conduct certain business processes, such as sharing information across a supply chain.) When a bank won’t issue a mortgage to a perfectly legitimate and creditworthy homeowner, except at some usurious rate, because it doesn’t trust the registry of deeds and liens, we can argue that the price of trust is too high and that a blockchain might be a good solution.

Not all blockchains utilize proof-of-work as an anti-Sybil attack mechanism, so it cannot be said that “a community must spend significant resources”.

In the next edition it would be interesting to see a cost / benefit analysis for when someone should use a blockchain as it relates the mortgage use case they describe above.

On p. 248 they talk about voting:

Every centralized system should be open for evaluation – even those of government and the political process. Already, startups such as Procivis are working on e-voting systems that would hand the business of vote-counting to a blockchain-based backend. And some adventurous governments are open to the idea. By piloting a shareholder voting program on top of Nasdaq’s Linq blockchain service, Estonia is leading the way. The idea is that the blockchain, by ensuring that no vote can be double-counted – just as no bitcoin can be double-spent – could for the first time enable reliable mobile voting via smartphones. Arguably it would both reduce discrimination against those who can’t make it to the ballot box on time and create a more transparent, accountable electoral system that can be independently audited and which engenders the public’s trust.

A month ago Alex Tapscott made a similar argument.

He managed to temporarily unite some of the warring blockchain tribes because he penned a NYT op-ed about how the future is online voting… powered by blockchains. Below is a short selection of some Twitter threads:

  • Arvind Narayanan, a CS professor at Princeton said this is a bad idea
  • Angela Walch, a law professor at St. Mary’s said this is a bad idea
  • Philip Daian, a grad student at Cornell said this is a bad idea.
  • Luis Saiz, a security researcher at BBVA said this is a bad idea
  • Joseph Hall, the Chief Technologist at the Center for Democracy & Technology said this a bad idea
  • Preston Byrne, a transatlantic attorney and father of marmotology said this is a bad idea
  • Matt Blaze, a CS professor at UPenn, said this is a bad idea

NBC News covered the reaction to Tapscott’s op-ed.  Suffice to say, the next edition should either remove this proposal or provide more citations and references detailing why this is a good idea.

Throughout this chapter projects like BitNation and the Economic Space Agency are used as examples of projects that are “doing something” — but none of these have gotten much traction likely because it’s doing-something-theater.

On p. 252 – 255 they uncritically mention various special interest groups that are attempting to influence decision makers via lobbying. It would be good to see some balance added to this section because many of the vocal promoters at lobbying organizations do not disclose their vested interests (e.g., coin positions).

On p. 255 they talk about “Crypto Valley” in Switzerland:

One reason they’ve done so is because Swiss law makes it easier to set up the foundations needed to launch coin offerings and issue digital tokens.

MME – the Swiss law firm that arguably popularized the approach described in this section – set up more than a dozen of these foundations (Stiftung) before stopping. And its creator, Luke Mueller, now says that:

“The Swiss foundation actually is a very old, inflexible, stupid model,” he said. “The foundation is not designed for operations.”

Could be worth updating this section to reflect what happened over the past year with lawsuits as well.

On p. 255 they write:

The next question is: what will it take for U.S. policymakers to worry that America’s financial and IT hubs are losing out to these foreign competitors in this vital new field.

This is FOMO. The authors should tabulate all of the companies that have left the US – or claim to leave – and look at how many jobs they actually set up overseas because of these laws. Based on many anecdotes it appears what happens in practice is that a company will register or hold an ICO overseas in say, Singapore or Panama, but then open up a development arm in San Francisco and New York. They effectively practice regulatory arbitrage whereby they bypass securities laws in one country (e.g., the US) and then turn around and remit the proceeds to the same country (the US).

On p. 263 they conclude the chapter with:

No state or corporation can put bricks around the Bitcoin blockchain or whitewash its record. They can’t shut down the truth machine, which is exactly why it’s a valuable place to record the voices of human experience, whether it’s our love poems or our cries for help. This, at its core, is why the blockchain matters.

Their description basically anthropromorphizes a data structure. It also comes across as polemical as well as favoritism towards one specific chain, Bitcoin. Furthermore, as discussed throughout this review, there are clear special interest groups – including VC-backed Bitcoin companies — that have successfully pushes Bitcoin and other cyrptocurrencies – into roadmaps that benefit their organizations.

Conclusion

Like their previous book (AoC), The Truth Machine touches on many topics but only superficially.  It makes a lot of broad sweeping claims but curious readers – even after looking at the references – are left wanting specifics: how to get from point A to point B.

There also seems to be an anti-private enterprise streak within the book wherein the authors condescendingly talk down efforts to build chains that are not anarchic. That becomes tiring because – as discussed on this blog many times – it is not a “us versus them” proposition.  Both types of blockchains can and do exist because they are built around different expectations, requirements, and operating environments.

In terms of one-sided narratives: they also did not reach out to several of the people they villify, such as both myself and Preston Byrne as well as coin proponents such as Roger Ver and Jihan Wu.  The next edition should rectify this by either dropping the passages cited above, or in which the authors reach out to get an on-the-record comment from.

Lastly, while some churn is expect, many of the phrases throughout the book did not age well because it relied on price bubbles and legal interpretations that went a different direction (e.g., SAFTs are no longer popular).  If you are still looking for other books to read on the topic, here are several other reviews.

Endnotes

  1. See A brief history of R3 — the Distributed Ledger Group []
  2. Developers of various coins will include “check points” which do make it virtually impossible to roll back to a specific state. Both Bitcoin and Bitcoin Cash have done this. []
  3. See Why the payment card system works the way it does – and why Bitcoin isn’t going to replace it any time soon by Richard Brown []
  4. See Learning from the past to build an improved future of fintech and Distributed Oversight: Custodians and Intermediaries []
  5. Unsurprisingly users want to be able to hold someone accountable for their lack of care and/or difficulty in safely and securely backing up their keys. []
  6. Ibid []
  7. Technically every orphaned block alters the blockchain, because you thought one thing and now you are asked to think another. []
  8. Readers may be interested in The Path of the Blockchain Lexicon by Angela Walch []
  9. Recall that generating hashes is a means to an end: to make Sybil attacks costly on a network with no “real” identities. []
  10. For instance, Selfish Mining []
  11. Albumatic -> Koala -> Chain.com the Bitcoin API company -> Chain.com the enterprise company, etc. []
  12. This is slightly reminiscent of Dr. Strangelove in which General Turgidson says, “I admit the human element seems to have failed us here.” []
  13. See The Revolving Door Comes to Cryptocurrency by Lee Reiners and Is Bitcoin Secretly Messing with the Midterms? from Politico []
  14. See also his role in attacks on CoiledCoin and BBQcoin []
  15. David Andolfatto, from the St. Louis Fed, also pointed this out back in May 2015, skip to the 28 min mark []
  16. See the “no” side of the debate: Can Bitcoin Become a Dominant Currency? []
  17. Ironically in his most recent op-ed published today, he asks people to “quit this ugly obsession with price.”  There are at least 3-4 instances of the co-authors using price as a metric for “strength” in this book. []
  18. See also this related thread from Don Bailey []
  19. Some exchanges, such as Gemini, want proof of mining activity. See also: What is Permissioned-on-Permissionless []
  20. See also the Polly Pocket Investor Day []
  21. Ryan Zurrer, second-in-command at Polychain, was recently fired from Polychain amid weak performance this year. []
  22. The whole public sale thing is problematic from a MSB perspective. The colorability of the position taken by Cooley in that section was questionable at the time and possibly indefensible now. []
  23. Mike wrote the first line of code for Corda over three years ago. []
  24. The initial conversation with Bob took place in San Francisco during Coin Summit. Bob later became a key person at Chainalysis. []
  25. According to Preston:

    Eris, now Monax, was the first company to look at the combination of cryptographic primitives that make up Bitcoin and attempt to use them to make business processes more efficient. In shorthand, the company invented “blockchains without coins” or “permissioned blockchains.”

    Bitcoin’s dysfunctional governance wasn’t a “godsend” for our business, as we weren’t competing with Bitcoin. Rather we were trying to dramatically expand the usecases for database software that had peer to peer networking and elliptic curve cryptography at its core, in recognition of the fact that business counterparties reconcile shared data extremely inefficiently and their information security could benefit from a little more cryptography.

    In exchange for our efforts, Bitcoiners of all shapes and sizes heaped scorn on the idea that any successor technology could utilize their technology’s components more efficiently. We responded with pictures of marmots to defuse some of the really quite vitriolic attacks on our company and because I like marmots; these little critters became the company’s mascot through that process.

    Subsequent developments vindicated my approach. Cryptographically-secure digital cash being trialled by Circle, Gemini, and Paxos utilizes permissioning, a concept that Circle’s Jeremy Allaire said was impossible in 2015 – “they’re not possible separately” – and I predict that as those USD coins seek to add throughput capacity and functionality they will migrate off of the Ethereum chain and onto their own public, permissioned chains which are direct conceptual descendants of Eris’ work.

    They will compete with Bitcoin in some respects, much as a AAA-rated bond or USD compete with Bitcoin now, but they will not compete with Bitcoin in others, as they will cater to different users who don’t use Bitcoin today and are unlikely to use it in the future.

    Ultimately, whether Eris’ original vision was right is a question of how many permissioned chains there are, operating as secure open financial services APIs as Circle and Gemini are using them now. I predict there will be rather a lot of those in production sooner rather than later. []

  26. Oddly the authors of the book do not name “Corda” in this book… they use the phrase: “R3’s distributed ledger” instead. []
  27. Readers may also be interested in reading the 2016 whitepaper from the DTCC []
  28. At the time of this writing there are: 5 incubated “Frameworks” and 6 incubated “Tools.” []
  29. Antonopolous recently gave a talk in Seattle where he promoted the usage of cryptocurrencies to exit the banking system.  Again, a user cannot use a cryptocurrency without absorbing the exposure and risks attached to the underlying coins of those anarchic networks. []

Events and activities through November

The past 6 months have seen an evolution of insanity to sanity.  Just kidding!

One observation I have seen is that a few of the most vocal coin promoters have finally sat down and spoken with policy makers.  Or rather, they finally started attending events in which policy makers, regulators, and decision makers at institutions speak at.

For those of us who have been attending and participating in regulatory-focused events for several years, the general messaging hasn’t changed that much: laws and regulations around financial market infrastructure and financial instruments exist for legitimately good reasons (e.g., systemic risks can be existential to society).

What has changed is that there are a few new faces from the coin world — most of which have previously pretended or perhaps did not even know that there is parallel world that can be engaged with.

It is still too early to see whether or not this governance education will be helpful in moderating their coin-focused excitement on social media but it seems to be the case that regulators and policy makers are still further ahead in their understanding of the coin world than vice versa.  Maybe next year coin issuers and promoters will finally dive into the PFMIs which have been around since 2012.

Below are some of the activities I was involved and participated in.

Panels and presentations

Interviews and quotes

Op-ed

Cited

Systemically important cryptocurrency networks

[Note: this article was first published at FintechPolicy on November 2, 2018]

For self-serving reasons there has been an enormous amount of revisionism that Satoshi built Bitcoin in direct response to the Great Financial Crisis.  But Satoshi explained that the coding for it began in mid-2007, which was months before any of the now notorious investment banks faced the brunt of the crisis or grappled with existential issues.

Either way, Bitcoin itself does not directly solve any problem that Lehman or Bear Sterns had, or for that matter, anything that mortgage loan originators had as well.  The two behemoths did not collapse because of a payments (transactional) problem.  Or a double-spending problem between pseudonymous participants.  There wasn’t even a problem with digital signatures being reversed or some other strange technological edge case.  

Instead it was a combination of many “off-chain” issues: lax lending standards, over leverage, unrealistic valuations, rubber stamp ratings, improperly assessed risk models, lack of proper documentation, special interests lobbying, imprudent oversight, and a laundry list of other culprits.  None of those were things that Bitcoin itself could have fixed.

Perhaps hypothetically an industry-wide blockchain or some kind of commonly used distributed ledger could have maybe sorta helped with reducing reconciliations which could have maybe sorta lead to quicker identification of rehypothecation, but it is not accurate to say that a cryptocurrency like Bitcoin would have prevented the GFC.  Let’s put that faux narrative to rest.

Garbage in, garbage out: blockchains cannot magically fix the underlying information — behind the representations — being inserted into blocks, that’s not what they are designed to ameliorate.

Pittsburgh

A year after Lehman collapsed, leaders from the G20 and several other international organizations met in Pittsburgh to reflect on and iron out additional methods of shoring up the decentralized yet highly concentrated and intermediated financial system.  One of the decisions – potentially fatal in the long run – was to require that all standardized derivative contracts be cleared through what are known as central counterparties (CCPs), frequently referred to as clearing houses.  Unlike exchanges, most CCPs are not common household names, but they are an order of magnitude systemically more important than even the largest of traditional exchanges.

Some of the older CCPs absorbed the additional derivative clearing routes and simultaneously new clearing houses were created around the world.  Most legacy market infrastructure providers were welcoming to this new mandate as it meant additional business lines and fees.  Regulators were also – at first – welcoming to this set of clearing requirements too because it meant that they could more easily observe and measure aggregate values and risks in just one or two physical places.

But being the bright reader you are, you are a step ahead and realize that the unseen consequence is that CCPs have actually created additional concentration of risk in a market with scarcely a few single points of trust.  Some of these CCPs are to date, arguably undercapitalized relative to the risks they bear.  If even one of them collapsed, you probably would not have time to sell your magic internet coins on the KYC-less exchanges you love to use before the shockwaves reached it first.

But this article isn’t so much about traditional systemically important financial institutions and infrastructures so much as it is about the topic everyone reads fintech zines for: coin scuttlebutt.

Matryoshka Stablecoins

“Stablecoins” have become a catch-all term for a type of coin or token that is marketed as having parity with some kind of exogenous unit-of-account, typically the USD.  In some cases the issuers are unlicensed e-money transmitters, although most market participants (traders) do not seem to care.

What problem are they solving and for whom?   Is it for banks?  

Probably not.

When speaking with banks about back-end payment issues, they do not lack general solutions either in-house or via 3rd party.  From a compliance standpoint, some of their challenges are how to build solutions that satisfy AML regulations.  One of the biggest unknowns about online-only money transmission businesses (e.g., PayPal, Transferwise) is whether they have not been in AML news because:

  1. they are much better at building those solutions 
  2. because they are still small enough to stay under the radar 
  3. have been getting breaks by regulators and law enforcement

But regardless of fintech, the creation of a stablecoin doesn’t automatically improve AML surveillance by and for government agencies.  

In fact, stablecoins as an aggregate may actually be expanding obfuscation of identity across borders because many exchanges, especially outside of the US, do not require stringent KYC, AML, and CTF checks.

The funny thing about the current mania around stablecoins is that a small group of us talked about and gestated their warts and all back in 2014 and 2015.  For example, during that time Vitalik Buterin penned a comprehensive post on the topic and Robert Sams authored a short paper entitled “Seigniorage Shares” which a couple current stablecoin projects have unceremoniously cribbed on.

But the 50-odd proposals that are currently floating around in one form or fashion aren’t actual solutions to existential questions around intermediation and finality.  At best, they are quick fixes to the desirability of reducing volatility whilst day trading in coin bucketshops.  At worst, they create a new systemic risk to both cryptocurrency markets and traditional financial markets.  And we know this because of who the credit risk is: commercial banks.

You see, contrary to the cartoonish explanations on cryptotwitter, today there is probably just one form of money: reserves sitting inside a central bank.  Everything beyond coins and notes and money equivalents is arguably a credit risk.

Even a deposit made by companies into a commercial bank account ultimately bears the credit risk of that specific bank: it could collapse, force a haircut onto depositors, freeze assets at the request of the court, decide to shut down accounts, and at least a handful of other issues.  We all witnessed the consequences of these risks first hand with the sorrowful collapse of retail and commercial banks during 2008 – 2009.

In contrast, the only potential stable form of currency within an economy is the one that a central bank issues and/or fully backs.  But in order to access this today, you have to be an approved bank.  On the wholesale side – with the advent of central bank digital currency (CBDC) and central bank digital account (CBDA) – who has access to these reserves could begin to include non-bank organizations and enterprises.  It is unclear if or when a retail equivalent will exist, although several Narrow Bank proposals effectively provide roughly the same utility.  

It is probably a little unfair to say that all cryptocurrency-focused venture funds would invest in a rope-making startup that could hang the entire economy so as long as they could get a quick exit.  But it is clear that every VC firm that has invested in “stablecoins” is wanting to extract and privatize specific rents called seigniorage.  

These VCs would like a healthy cut of the cash flow that a central bank would normally collect and remit to the national treasury which then pays for social services.  In the case of VCs, it would flow through the management structure and then to the LPs who then would reinvest into increasingly cleverer sounding stablecoins.  Just like Matryoshka dolls.  

https://pbs.twimg.com/media/DpfjpGvU8AAT3eY.jpg:large

Source: Larry Cermak

The line graph (above) represents a one year chart showing weekly exchange traded volume (measured in USD) of three stablecoins:  Tether, Dai, and TrueUSD.  Note: there are allegations that Tether’s volume are manipulated (e.g., trans-mining), but that is a conversation for a different article.

Too big to fail anarchic chains

If you are a developer or investor and you really wanted users to have access to stability without reintermediating the payment system, you should explore alternative platforms that have access to CBDCs, CBDAs, and Narrow Banks.

But that is annoyingly time consuming, right?  Who wants to spend time sitting around with some fuddy duddy suits when you could be spinning up tokens with coinbros and “thought leaders” at coin festivals?  

Last year I penned an accurate prediction of what would happen this year: the cryptocurrency world would become increasingly reliant on the unit-of-account of actual money, in this case, the USD.

We see this desirability for a stable U-o-A with the dozens of aforementioned stablecoins that have been concocted, some with the approval of state regulators.  And all attempt to maintain parity of some kind relative to a traditional currency.

Consequently, we see the confluence of the problem highlighted in the section above, namely credit risk, with Tether (USDT).  For those unfamiliar with Tether Ltd, it is a company that issues USDT which are – depending who you talk to at the company – supposedly pegged 1:1 to USD held in reserve somewhere.  Ignoring the likelihood that they are not in full compliance with the BSA regime, Tether Ltd and its owner Bitfinex, keep losing access to commercial banks.  Their accounts are shut down and as a result, the peg breaks because it is not a real peg.

While Tether currently trades at a credit discount arguably it still serves its original purposes (e.g., quasi-cash leg, tax free harbor for intra-day gains).  But an ongoing issue is that the quality remains transparent to insiders and opaque to outsiders.  Another issue is that aside from the lack of end-to-end KYC and AML surveillance, it really serves no purpose that couldn’t be better offered by collateral management solutions.

While everyone likes to claim that newer fully collateralized stablecoins that have been approved by state agencies are going to be better because they comply with BSA and BSA-equivalent surveillance requirements, this is untrue for at least two reasons:

  1. The credit risk still involves commercial banks, not central banks (there is a difference).
  2. The chains they reside on do not provide definitive legal settlement finality.

If you have read my material in the past you probably think I sound like broken record.  But consider that about half of the 50+ stablecoin proposals exist as ERC20 tokens on Ethereum.  The remaining half piggy-back on top of Bitcoin or other anarchic cryptocurrency.

None of these chains are unforkable, by design.  That is to say, they only provide probabilistic finality.  And that presents an existential risk to not just the everyday user transmitting coins, but also any derivative – like stablecoins – that sits on top, reliant on a functioning unforked network below.  This is not a new observation, I even wrote a lengthy paper about top-heavy issues three years ago.  To put it another way: by design, block producers on these anarchic networks are rewarded an endogenous value (seigniorage) to secure the network.  Adding ad hoc exogenous value atop of the network weakens and dilutes the overall security of a network which could lead to a compromise or fork. 

At this point, if Bitcoin and other cryptocurrencies somehow disappeared, there will likely be no systemic impact because they do not yet have a large functioning ecosystem of derivative instruments and leverage behind it.  So it is a bit of a moot point for now.  But if the demand for stablecoins – which parasitically sit atop of anarchic chains – grew and expanded significantly to include credit, the chances of related 2008-like crisis within the cryptocurrency world would seem much higher.  It is still a matter of debate as to how a cascading failure of these parasitic assets from a forked network would impact the traditional financial system.  

Recall that for obvious reasons there is enormous amount of oversight for financial market infrastructures (FMI) like payment and clearing systems.  If they ever achieve the critical size that VCs publicly claim they will, could cryptocurrencies such as Bitcoin that process and secure transactions for stablecoins eventually be considered systemically important and thus fall within that regulatory mandate? 

According to the latest FSB report, Bitcoin and other “crypto-assets” do not pose risk to financial stability at this time.  In the future, crypto-assets may pose risk to financial stability (see Appendix 1 of the report), but that would not, by itself, bring within scope of regulatory mandate.  Obviously one critical issue with Bitcoin is – what jurisdiction does this fall within? ASIC in Australia is already developing an approach that touches on this.

In the event that occurs, this could turn these anarchic networks into expensive chimeras, permissioned-on-permissionless chains.  But that is a topic for a different article.

Conclusions

Cryptocurrency promoters often speak nostalgically of how the Great Satoshi solved a sundry of computer science and economic problems on Halloween 2008.  But on closer examination, Satoshi proposed one way of transmitting e-cash and bypass existing payment providers without having to comply with the BSA-regime. 

When she disappeared in late 2010, the cryptocurrency world up to that point was still relatively disintermediated and decentralized.  There were a couple of semi-pro mining pools and deposit-taking exchanges as well as a few custodial wallets, nearly all of which got hacked and pilfered.

Those first victims had no legal recourse and probably didn’t care enough at the time to sue anyone because just about everyone playing around with Bitcoin and its clones understood that there were no terms of service or end user licensing agreements, it was (and is) caveat emptor.

Fast forward 10 years and what is commonly referred to as the “cryptocurrency space” is heavily intermediated.  The vast majority (80%) of all transactions last year flowed through some kind of third party.  Nearly everyone hedges their trading positions in just a couple of underregulated exchanges.  And it is rumored that the main reason the largest off-shore exchanges have not been shut down is because of the access they provide to certain law enforcement agencies regarding suspicious accounts involved in illicit activities.

In other words, while Satoshi had attempted to create an alternative payment system, her followers have not only recreated the same concentration of risk and intermediation as the financial world she apparently wasn’t a fan of, but this new one lacks nearly all of the safeguards, accountability, recourse, and broad oversight that civilization has collectively placed on SIFIs.  

The Black Mirror episode we live in today is even more strange and perverse once you account for:

  1. the environmental toll, the negative externality that proof-of-work mining creates… where seigniorage gains are privatized and the degradation is socialized 
  2. the same nouveau riche coinbros and broettes who enriched themselves off unsophisticated retail investors by publicly shilling and flipping ICOs last year are now funding more than a handful of coin lobbying organizations to convince regulators to keep their statist hands out of this highly centralized yet opaque market

Creating systemically important cryptocurrency networks is likely the most ironic phenomenon to have arisen from an anarchic experiment started on a mailing list ten years ago.  Yet here we are.

If you are interested in participating in something that doesn’t merely enrich existing coin holders at the expense of society and the environment, highly recommend reading Ray Dillinger’s recent interview and also looking into dFMI.  And then circle back to the CBDC report from the BIS this past March. 

Interview with Ray Dillinger

[Note: the 10th anniversary of the Bitcoin whitepaper is this month.  Below is a detailed interview with one of the first individuals to have interacted with Satoshi both in public and private: Ray Dillinger.

All of the written responses are directly from Ray with no contributions from others.]

Logo from 2010: Source

Q1: Tell us about yourself, what is your background?

A1: I am originally from Kansas.  At about the same time I entered high school I became interested in computers as a hobbyist, although hobby computers were still mostly useless at that time.  I got involved in early BBS systems when DOS hadn’t been released yet, modems were acoustically coupled and ran at 300 bits per second or slower, and software was stored mostly either on notebook paper or cassette tapes.

The early interest in computers is part of my lifelong tendency to become deeply involved in technology and ideas that are sufficiently interesting. This has led me to develop interests, obsessions, and expertise in a huge variety of things most of which the public does not discover reasons to care about until much later.

I graduated from KU with a degree in Computer Science in December of 1995 after spending far too long alternating between semesters of attending classes and semesters of working to pay for classes.

After graduation I moved to the San Francisco Bay area.  I worked for several AI startups in the next seven years and hold a couple of patents in natural-language applications from that work.  After that, I worked the night shift for FedEx for some years while doing occasional security consulting gigs during daytime hours.  I am currently doing AI algorithm research and implementation (and some cryptographic protocol/document design) at a FinTech startup.  I work on General AI projects on my own time.

I am somewhat pessimistic by nature and tend to assume until given reason to believe otherwise that anyone trying to sell me something or convince me of something is a scammer.  I know that’s irrational, but knowing doesn’t make the belief stop.  I have an abiding hatred of scammers and find them viscerally disgusting.

I consider making noise to be rude, avoid crowds and public appearances, and distrust anyone speaking faster than they can think.  Although I write a great deal, I rarely speak and strongly dislike talking on the phone.

In spite of my peculiar interests and asocial tendencies, I somehow managed to get married to a wonderful woman who tolerates an unbelievable degree of geekdom in an unbelievable variety of subjects, ranging from mild interest to full-on mad scientist levels in scope. I am tremendously thankful to have her in my life, and to whatever degree
I might be considered social, she deserves most of the credit.

I became marginally involved with Bitcoin in its early development because cryptocurrency, and the application of block chains to cryptocurrency in particular, are interesting.  I ceased to be involved in Bitcoin when the next steps would necessarily involve salesmanship, frequent talking, and social interaction, because those things are not interesting.

Q2: Perry Metzger created the now infamous Cryptography mailing list years ago.  When did you join and what made you interested in cryptography?

A2: I joined so many years ago it’s hard to remember.  It was pretty much as soon as I became aware of the list, but I’m sure it was more than fifteen years ago. It may have been late 2001 or early 2002.

I think I may even have been one of the first twenty or thirty posters on that list – it was still very young.

I remember being vaguely annoyed that it hadn’t been available when I was actually still in college and doing a crypto project in a grad-level networking course – I’d been a member of the even-earlier ‘cypherpunks’ list back when I was in school, but its strident political ideologues (including a guy named Hal Finney, whom you’ve probably heard of)
annoyed me, even back then.

‘cypherpunks’ was where I became aware of and started corresponding with Hal.  Although, way back then, I think we were both mostly annoying to each other.  And possibly to others as well.  Hal had been stridently political all the way from those days (and probably before) to the day he died, and in retrospect, I think I really needed some ‘remedial human-being lessons’ and some wider education at the time.  I’ve learned a lot since then – and perspective outside the narrow specialties we studied in school really does matter.

Q3: There were a lot of other non-cryptocurrency related discussions taking place simultaneously in November 2008 and many of the frequent posters didn’t comment on Bitcoin when it was first announced.  What interested you in it?  How involved would you say you were with providing coding suggestions prior to the genesis block that following January?

A3: I was interested in it for several reasons.  First, Bitcoin was a digital cash protocol, and digital cash protocols have some significant challenges to overcome, and I’d been interested in them for a long time already.  I’d even designed a couple by then.  The first I designed was unsound. The second, which is the only one worth talking about, which I’ll talk more about below.

Second, Bitcoin used a central proof chain (which we now call a block chain) as means of securing the history of each note, and I had known for a long time that any successful digital cash protocol had to use proof chains in some form or it couldn’t circulate (couldn’t be spent onward by someone who’d been paid in it).  And I was very, very much interested in proof chains, especially for a digital cash protocol.  I had already used proof chains (very differently) for a digital cash protocol when I extended Chaum’s e-cash protocol in 1995.

(see Digression #1 below to understand the differences between my protocol and Satoshi’s, and their effect on protocol design.)

Third, Satoshi eventually convinced me that he wasn’t a scammer.  I’m sort of a natural pessimist at heart, and digital cash protocols have a long history of scammers, so at first I had assumed the worst.  I think a lot of others also assumed the worst, which would be why few of them responded.  I made my first couple of replies without even having read it yet, to see how he responded before I wasted mental effort on something that would probably turn out to be a scam.

When I finally bothered to actually read the white paper, and spent the mental effort to understand it, I realized that (A) it wasn’t the usual incompetent bullshit we’d seen in far too many earlier digital-cash proposals, and (B) Its structure really and truly contained no Trusted Roles – meaning the opportunity to scam people was NOT built into the structure of it the way it had been with e-gold, e-cash, etc.

Fourth, and absolutely the clincher for me; it was very very INTERESTING!  It was an entirely new paradigm for a digital cash protocol, and had no Trusted Roles!  Nobody had EVER come up with a digital cash protocol having no Trusted Roles before!

Of course it wasn’t a “serious” proposal, I thought. It wouldn’t work for any kind of widespread adoption (I thought at the time) because of course people would conclude that spent hashes which absolutely couldn’t be redeemed for the electricity or computer power that had been used to create them were valueless.  And it would never scale beyond small communities or specialized applications of course because of its completely stupid bandwidth requirements.

But it was INTERESTING!

I could never have come up with Bitcoin because of the tremendous bandwidth.  Without Satoshi’s proposal, the idea of transmitting every transaction to every user would just have bounced off my mind as inconceivable.  Hell, I didn’t even understand it the first couple of times through the white paper because I was looking for ANY WAY AT ALL to parse those sentences and ‘transmitting every transaction to every user wasn’t even a POSSIBLE parse for me until Satoshi explicitly told me yes, that really was what he meant.

When I finally understood, I started doing math to prove to him that it was impossible, tried to relate bandwidth to rate of adoption and got a largest possible answer that’s only about one-eighth of today’s number of nodes.   I was assuming transaction volume proportional to userbase, which would be at least three times the transactions that today’s blocksize-limited block chain handles, and looking at a version of the protocol which doubled it by transmitting every transaction twice.  So,GIGO, I was wrong – but for good reasons and in the correct order of magnitude anyway.

But that was a couple orders of magnitude larger than the highest answer I had expected to get!  And that meant Satoshi’s idea actually seemed…. surprisingly plausible, if people really didn’t care about bandwidth.

The fact that bandwidth seemed to be available enough for the proposal to be technically plausible was sort of mind-boggling.  So was the idea that so many people did not care, at all, about bandwidth costs.

(See digression #2 to understand why it was hard for me to accept that
people now consider bandwidth to be valueless.)

Anyway, problems aside, it was INTERESTING! If the proof-of-concept actually sort-of worked at least on scales like for a campus or community merchandise token or something it would extend our understanding of protocol design!

What I had done back in 1995 had been INTERESTING for a different reason. At that time nobody had ever come up with a digital cash protocol that allowed people who’d been paid digital coins to respend them if they wanted instead of taking them right back to the issuer.  Of course it wouldn’t work for general adoption because of its own problems, but it had extended our understanding of protocol design back then, so back then that had been INTERESTING!

And before that, Chaum had demonstrated a digital cash protocol that worked at all, and at the time that was INTERESTING!

And in between a whole bunch of people had demonstrated ways to cooperate with bankers etc to have different kinds of access to your checking account or whatever.  Some of those had had privacy features v. the other users, which were also INTERESTING!

And so on.  I was very much looking at things that improved our understanding of digital cash protocols, and had no idea that Bitcoin was intended for widespread release.

Anyway, Satoshi and I talked offlist about the problems, and possible solutions, and use of proof chains for digital cash, and my old protocol, and several previous types of digital cash, and finally he sent me the proof chain code for review.

And the proof chain code was solid, but I freaked out when I saw that it used a Floating Point type rather than an Integer type for any kind of accounting. Accounting requirements vs. floating point types have a long and horrible history.

So that prompted some more discussion. He was designing specifically so that it would be possible to implement compatible clients in languages (*cough* Javascript *cough*) in which no other numeric type is available, so he wanted to squish rounding-error bugs in advance to ensure compatibility.  If anybody gets different answers from doing the same calculation the chain forks, so it’s sort of important for everybody to get the same answer.  Because Javascript clients were going to use double float, and he wanted them to get the same answer, he was going to make sure he got correct answers using double floats.

He was trying to avoid rounding errors as a way of future-proofing: making it completely consistent so clients with higher-precision representations wouldn’t reject the blocks of the old chain – but on the ground he wanted to be damn sure that the answers from Javascript clients, which *would* by necessity use double float, could be compatible with checking the block chain.

The worst that could happen from a rounding error, as long as everybody gets the *SAME* rounding error, is that the miner (whose output is unspecified in the block and defined as “the rest of the TxIn values input”) gets a few satoshis more or less than if the rounding error hadn’t happened, and no satoshis would be created or destroyed.

But if people on different clients get *DIFFERENT* rounding errors, because of different representation or differently implemented operations, the chain forks. And That Would Be Bad.

I would have said *screw* Javascript, I want rounding errors to be impossible, and used integers.  If the Javascripters want to write a float client, they’d better accept accurate answers, even if they have to allow for answers different than their code generates.  And if they make transactions containing rounding errors, let everybody in the universe reject them and not allow them into blocks.  But that’s me.

It was when we started talking about floating-point types in accounting code that I learned Hal was involved in the effort. Hal was reviewing the transaction scripting language, and both the code he had, and the code I had, interacted with the accounting code. So Satoshi brought him in for the discussion on floating point, and both of us reviewed the accounting code. Hal had a lot of experience doing exact math in floating point formats – some of his crypto code in PGP even used float types for binary operations. So he wasn’t as freaked-out about long doubles for money as I was. We talked a lot about how much divisibility Bitcoins ought to have; whether to make ‘Satoshis’ an order of magnitude bigger just to have three more bits of cushion against rounding errors, or keep them near the limit of precision at 10e-8 bitcoins in order to assure that rounding errors would always fail. Failing, immediately, detectably, and hard, at the slightest error, is key to writing reliable software.

So I went over the accounting code with a fine-toothed comb looking for possible rounding errors.  And I didn’t find any.

Which is more than a little bit astonishing.  Numeric-methods errors are so ubiquitous nobody even notices them.  Inevitably someone multiplies and divides in the wrong order, or combines floats at different magnitudes causing rounding, or divides by something too small, or makes equality comparisons on real numbers that are only equal 65535 times out of 65536, or does too many operations between sequence points so that they can be optimized differently in different builds, or uses a compiler setting that allows it to do operations in a different sequence, or checks for an overflow/rounding in a way that the compiler ignores because it can prove algebraically that it’s “dead code” because it will never be activated except in case of undefined behavior (like eg, the roundoff or overflow that someone is checking for)!  Or SOMETHING.  I mean, in most environments you absolutely have to FIGHT both your language semantics and your compiler to make code without rounding errors.

Clearly I hadn’t been the first pessimistic screaming hair-triggered paranoid aware of those issues to go over that accounting code; I could not find a single methods error.  The ‘satoshi’ unit which is the smallest unit of accounting, is selected right above the bit precision that can be handled with NO rounding in the double float format, and every last operation as far as I could find was implemented in ways that admit no rounding of any bits that would affect a unit as large as a satoshi.

To cause rounding of satoshis in the Bitcoin code, someone would have to be adding or subtracting more than 21 million Bitcoins (I think it’s actually 26 million, in fact…).  So, the Bitcoin chain is, I believe, rounding-free and will continue to check regardless of whether clients use any higher floating point precision.

For comparison Doge, which has so many coins in circulation that amounts larger than 26 million Doge are actually transacted, has rounding errors recorded in its block chain.  If a new client ever uses a higher-precision float format, their old chain won’t check on that client.  Which would be seen as a bug in the new client, and “corrected” there (by deliberately crippling its accuracy when checking old blocks). In fact it’s a bug in the Doge coin design which will never be fixed because they’ve already committed too much to it.

Integers.  Even with code that is meticulously maintained and tested for consistency, even where methods errors have been boiled out by somebody’s maniacal obsessive dedication, Integers would have been so much cleaner and easier to check.

Digression #1:
Why I was VERY interested in proof chains and digital cash protocols.

When I extended Chaum’s protocol in 1995, I had used proof chains attached to each ‘coin’, which grew longer by one ‘link’ (nowadays we say ‘block’) every time the coin changed hands. That allowed coins to circulate offline because all the information you needed to make another transaction was in the chains attached to the individual coins.  In order to make it possible to catch double spenders, the ‘links’ contained secret splits which, if two or more contradictory links were combined, would reveal the identity of the spender.

So, it could circulate offline and make transfers between users who weren’t even connected to the Internet. It didn’t have the ferocious bandwidth expense and even more ferocious proof-of-work expense of Bitcoin. Double spenders couldn’t be caught until the differently-spent copies of a coin were compared, potentially after going through several more hands which meant you had to have some kind of resolution process. And a resolution process meant you absolutely had to have a Trusted Certificate Authority with a database that could link UserIDs to RealWorld IDs in order to figure out who the RealWorld crook was.

Buyer and seller had to have valid UserIDs issued by the Trusted CA, which were known to each other even if to no one else.  And although not even The Trusted CA could link UserIDs and transactions except in case of a double spend, the parties to each transaction definitely could. Either party could later show and cryptographically prove the details of the transaction including the counterparty’s UserID, so your transactions were “Private”, not “Secret”. Finally, the ‘coins’ were non-divisible meaning you had to have exact change.

It was, at best, clunky compared to Bitcoin, and not being able to identify double spends until unspecified-time-later would probably be a deal-killer for acceptance. But it also had some advantages: It didn’t create a central permanent ledger that everybody can datamine later the way Bitcoin does, so Trusted CA or not it might actually have been better privacy in practice.  It was completely scalable because no transaction needed bandwidth between anybody except buyer and seller. And it had no proof-of-work expense.  But it needed a God-Damned Trusted Certificate Authority built directly into the design, so that CA’s database was open to various kinds of abuse.

Digression #2:

I had no comprehension of modern attitudes toward bandwidth costs.

I mean, I knew it had gotten cheap, but it was still taking me hours, for example, to download a complete Linux distribution. I figured other people noticed big delays like that too, and wide adoption of Bitcoin would mean slowing down EVERYTHING else they (full nodes anyway) did.  I just hadn’t understood that – and still have trouble with – the idea that by 2008, nobody even cared about bandwidth any more.

I got my first computer, because at that time privately owned computers were INTERESTING!  So I had to, even though they were also mostly useless.  (See a pattern here?)

But at that time, computers were not communications devices.  At All. If you hadn’t invested in something called a “LAN”, which anyway could only work inside one building, probably cost more than the building itself, and was useless unless you’d also invested in multiple computers, you moved data back and forth between your machines and your friends’ machines using cassette tapes.  Or, if and your friend were both rich enough to buy drives, or had been lucky enough dumpster diving to get drives you could repair, and had access to the very expensive media through some kind of industrial or business supply place, you might have done it using floppy disks.  Which held eighty kilobytes.

I got my first modem a few years later, and modems at the time were flaky hardware only BARELY supported by single-tasking systems that had never been designed to handle any signal arriving anywhere at a time they did not choose.  If your computer didn’t respond fast enough to interrupts, a modem could crash it.  If you were running anything that didn’t suspend and resume its business correctly (and most things didn’t because they’d never had to before) or anything that was coded to use the same interrupt, the modem would crash it.  If the software on your end ever started taking too long to execute per input character, the modem would fill up the short hardware buffer faster than your software could empty it, and crash it.  If you transmitted characters faster than the software running on the remote system could handle them, you’d crash the remote system.  There were no error correcting protocols because none of us had the compute power to run them fast enough to avoid a crash at the speeds the modems ran.

And that modem couldn’t transmit or receive characters even as fast as I could type. Sometimes you could crash the remote system just by accidentally typing too fast for a minute or two.

Computer security wasn’t a thing. Pretty much anybody you allowed to connect could at least crash your system and probably steal anything on your computer or delete everything on your computer if they really wanted to.   The host programs weren’t *intended* to allow that, but something as simple as transmitting an unexpected EOT signal could often crash them – sometimes crashing the whole machine, sometimes leaving the caller at the all-powerful command-line prompt. Stuff like that happened all the time, just by accident!  So people were understandably reluctant to let strangers connect to their systems.

There was one place in my whole state that I could call with it where I found people who’d leave a modem running on their machine despite the risk of crashes, and would allow a stranger on their system.  That sysop, in an act of sheer grace that he didn’t have to extend and which nobody was paying him for, allowed me to connect to it.  There were no such things as commercial providers; they could not exist until at least some system security actually worked.

There was barely even any commercial software: Every machine came with its own BIOS and Operating System, and the ONLY way to distribute a program that would run on more than a tiny fraction of systems was to distribute it as source code which people could tweak and fix and adapt in order to get it running, and commercial vendors didn’t want to distribute any source code.

So our software was all shared.  It came from fellow hobbyists, and unless we were physically in the same room to exchange media (and had the ability to read and write media compatible with the other’s systems), we could not share it without using bandwidth.

Long distance calls were over a dollar a minute, modems ran at 160 or 300 bits per second, and I could have burned through my entire monthly paper route income in under three hours.

Finally, every second I was connected to that remote system, that phone line was busy and everybody else couldn’t use it. And the other users needed it for reasons FAR more important than I did. They were military veterans, some of them profoundly not okay after Viet Nam, using it as sort of a hobby-mediated support group, and I was a fifteen-year-old kid hobbyist with a paper route.  Hobby in common or not, I had no illusions about the relative value of our access.   So I tried to be a good guest; I took my turns as fast as possible, at times least likely to conflict as possible, using as many pre-recorded scripts (played off a cassette tape deck!) as possible to waste absolutely no time, and got off.  I didn’t want to keep anybody out of something which was that important to them.

That’s the way things were when I started learning about the value of bandwidth.

No matter how much bandwidth I’ve got now, no matter how cheap it becomes, I’m still aware of it and it’s still important to me to not waste it.  I’ve sweated every byte every time I’ve designed a protocol.

And that’s why – to me anyway – universal distribution of a globally writable block chain is still amazing.  Just the fact that it’s now POSSIBLE seems incredible.

Q4: When Satoshi released the white paper, you had many public exchanges with her on that mailing list.  For instance, you asked her about inflation and Satoshi seemed to think that there could be some price stability if the number of people using it increased at the same level as the supply of bitcoins increased.  But, relative to the USD, there has never really been much price stability in its history to date.  Is there a way to re-engineer Bitcoin and/or future cryptocurrencies to do so without having to rely on  external price feeds or trusted third parties?

A4: Whoof…  that’s a hard question.  “Is not Gross Matter Interchangeable with Light?”  was considered impossible until Einstein figured it out. And the people who’d been asking that question didn’t even recognize or care about Einstein’s answer because his answer wasn’t about bodies and souls and the afterlife.  If the answer is ‘yes’ but the re-engineering involved changes the fundamental qualities that make you (or anybody) value cryptocurrencies, then is the answer really yes?

Satoshi tried to do it by anticipating the adoption curve.  We know how that turned out.

I think it’s fundamentally impossible to plot an adoption curve before launch.  I mean, I was the pessimist who assumed that there’d be a small group, formed early, that wasn’t going to be growing at all as these additional millions of coins pumped into that campus or that community economy.  So I figured, some initial value and rapid inflation thereafter.

Satoshi was far less pessimistic in figuring a widespread and fairly gradual adoption, and had picked the logarithmic plot to put coins into the economy at about the rate envisioned for adoption, assuming Bitcoin would follow a logarithmic adoption curve. It wasn’t a bad guess, as it’s a decent approximation to the Bass Diffusion Model, but the
parameters of the curve were completely unknown, and the Bass curve often appears after something’s been around a long time – not just when it’s launched.

Most importantly, nobody anticipated Bitcoin’s primary use as being a vehicle of financial speculation. The Bass Diffusion Model isn’t applicable to speculative commodities, because price changes in speculative commodities are responsive to PREVIOUS price changes in the speculative commodity.  That makes them nonlinear and chaotic.

And that, I think, is what it comes down to.  If people will be using something as a vehicle of speculation, then its price point is chaotic and defies all attempts to stabilize it by predicting and compensating for it.  So I think we need to abandon that notion.

You’ve already ruled out the idea of external price feeds and trusted third parties, because those would change the fundamental qualities that make you value cryptocurrencies.

That leaves internal price feeds:  If a cryptocurrency is used as a medium of exchange in other fungible assets, and those exchanges are recorded in its own block chain, then exchanges of crypto for dollars and exchanges of crypto for, eg, gold bars are visible in the block chain and could at least in theory be used to detect economic conditions and adjust the rate of issue of cryptocoins.

But the fly in that ointment is, again, the fact that the crypto is being used as a speculative asset.  People can read the block chain before the changes are made, anticipate what changes the code is about to make, and will front-run them.  Or, operating as “Sybil and her Sisters”, make a thousand completely bogus transactions in order to fool the software into doing something crazy.  Either way reintroducing positive feedback via market manipulation.

Most schemes aimed at stabilizing the value of a coin via any automatic means assume that the price can be changed by changing the rate of issue.  But the more coins are in circulation, the less possible it becomes for changes in the rate of issue to shift the price, meaning it devolves back to the first case of nonlinear and chaotic feedback.  IOW, the new coins being added represent a much smaller fraction of the available supply, and withholding them will affect almost no one except miners.

Honestly I’m very surprised Tethercoin isn’t dead yet.  What they propose, economically speaking, simply will not work.  They got themselves somehow declared to be the only way to get money OUT of a major wallet, which props up their transaction volume, but if the people haven’t already walked away with most of the money they’re supposedly holding but won’t say where, then I’m very surprised.

Q5: About a year ago you wrote a highly-commented upon, passionate retrospection published on LinkedIn.  You called out a lot of the nonsense going on then, is there anything that has been on your mind since then that you wanted to expand upon?

A5: Um.  Artificial Intelligence, Financial Markets, Human Brains and how they are organized, the nature, origins and mechanisms of consciousness and emotion, a generalization of neuroevolution algorithms intended to scale to recurrent networks of much greater complexity than now possible, scope of political corruption and the politics of divisiveness, gene migration and expression, the way cells control and regulate mutation in different kinds of tissues, directed apoptosis via a multiplicity of P53 genes as a preventive for cancer (happens naturally in elephants; easy to do with CRISPR; engineered humans would probably be radiation-resistant enough for lifetimes in space, or just plain longer-lived, or both), history of the Balkans, history of the Roman Empire, ancient religions, writing a science fiction novel ….

You know, things that are INTERESTING!  I actually _can’t_ turn my brain off.  It’s a problem sometimes.

I have had a few thoughts about cryptocurrencies, however, which is probably what you intended to ask about.

The first:

I have figured out how to redesign the cryptographically secured history database built by cryptocurrencies so that you don’t need any full nodes.  There are other ways to organize the blocks that give the proof property you need; They don’t have to form something that’s only a chain, and you don’t have to have specialized nodes for the purpose of holding them because everybody can hold just the blocks they need to show the validity of their own txOuts.

In order to verify the validity of any txOut, you need three things:  to see the block where it was created, to be sure that block is part of the same database as that proposed for the transaction, and to be sure that no block exists between those two in which that txOut was spent in another transaction.

Call it a “Block Hyperchain”, by reference to the N-dimensional hypercube it’s based on and the block chain it replaces.

I should be clear and say there are things it does and things it doesn’t do.  If your goal is to check all transactions, you’ll download a scattering of blocks for each transaction that soon add up to most of the block database, so someone who wants to check every transaction will rapidly accumulate the whole database.

But most users should be happy with just the few blocks they need to demonstrate the validity of the txOuts they hold, and it’s damn nice to be able to download a client, open it up, and just use it with minimal delay because someone offered to pay you bitcoins one minute ago and you want to be able to make sure the transaction he’s offering is valid RIGHT NOW, instead of waiting to accumulate the whole chain to check anything.

Suppose we pick a base, for convenience, of 10.  This helps make things easy to explain because we work with base-10 numbers, but we could have picked 16 and used hexadecimal for our explanations.

In a base-10 Block Hyperchain, every block that’s published has its own set of transactions, and the hashes of the blocks  10^N blocks ago for every integer value of N from N=0 to N <= log10 of block height.

Every block would record its own transactions, and also one list of destroyed txOuts per integer value N over the same range.

Each destroyed-txOut list would be all txOuts created in blocks whose block numbers match (modulo 10^N) the current block number, that have been destroyed in the last 10^N blocks.

Example:
If someone shows me a transaction seeking to spend a txOut, I want to check and see if it’s valid.  Ie, I want to see the block where it was created, and see evidence that it hasn’t been spent since.

So I can look at that txOut’s ID and know it was created in block 124. If the current block is 7365,  I get block 7365 and 7364 to make sure it hasn’t been spent in those, the same way we can do with a block chain.

Then I have a block whose last digit matches the last digit of the block where the txOut was created.  So I start checking the 10-block txOut-destroyed lists.  I check the list in block 7364 to make sure it wasn’t spent in blocks 7354 to 7363.

Then, jumping back by 10-block increments (relying on the second recorded hash in the header), I can check to make sure it hasn’t been spent in the previous ten blocks to each of blocks 7354, 7344, and 7334.  Then I get block 7324.

Now I’m at a block whose last 2 digits match the block where the txOut was created, so I can start checking the previous hundred blocks using the second txOut-destroyed list, and jumping back by hundred-block increments using the third recorded hash.  So I get blocks 7224 and 7124.

Finally, I’m at a block whose last 3 digits match the block where the txOut was created, so I can start jumping back by thousand-block increments, checking the thousand-block txOut-destroyed lists.  So I get blocks 6124, 5124, 4124, 3124, 2124, 1124, and finally 124.

So finally, I have a txOut created over 7200 blocks previous to the current block, and I have downloaded a total of 15 blocks to make sure that it was created in the same Hyperchain and hasn’t been spent since.

The number of blocks downloaded is proportional to the log base 10 of the number of blocks in the chain.

The blocks I’ve downloaded are larger because of the spent-txOut lists, but the spent-txOut lists have an average length that is the same regardless of the span of blocks they cover.  Lists that report transactions from a set 10x as long, only need to report individual transactions from that set 1/10 as often.

With more efficient access to the history database, it is possible to substantially raise transaction bandwidth.  People who make transactions during the next 7 blocks or so would need to see that block;  Later on, people who accept txOuts created during that block will need to see that block. And there’ll be about 49 blocks worth of txOuts,  scattered through the earlier history, that someone eventually has to traverse this block to verify.

All this means you have drastically smaller bandwidth requirements (remember I obsess on bandwidth costs?) for the same transaction volume but larger data-at-rest requirements (for any weirdo who for whatever reason feels like they need to collect the WHOLE database in one place, and why would anybody do that?) by a factor of seven.

And I keep thinking I’m going to do it, because it’s INTERESTING! And I ought to do it, because it’s VALUABLE!  But then I think about the current state of the cryptocurrency world and the quality of the people it would bring me into contact with and the ways people would try to scam with it and the number of people who’d find reasons to lie to me or about me, and then I get a sour stomach and go on to do something ELSE!

And feel vaguely guilty for not doing it, because it actually would be valuable.

It’s really hard for me to be motivated or enthusiastic about a cryptocurrency project, until the whole field is more full of people I’d be happy to interact and exchange ideas with and less full of ….  um.

The words that come to mind really shouldn’t be printed.  [This is fine meme]  I don’t mind if people know I’m sort of upset with the conditions and business ethics out there, or even that being so upset is literally preventing me from doing something useful.  But I’d rather not have it expressed in terms that are an incitement to violence.

Anyway, moving on;  In order to mine, someone would have to be able to see seven of the previous blocks; a different set of seven every time. But if I thought bandwidth was going to waste, that doesn’t even START to address the costs of hashing!  Deploying something that saves bandwidth without also figuring out a way to save hashing would fail to address a critical point.

So, I’ve had a bunch of thoughts about mining.  Most of which aren’t as interesting or valuable as the thought about how to organize the history database.  In favor of mining, it’s good that someone is able to join the network permissionlessly, help secure it, get paid, and initially get coin into circulation going from “none” to “some”.

My thoughts for securing a chain without proof-of-work are something I suppose I ought to call “Proof-of-Total-Stake.”

Congratulations!  This conversation with you got me to name it!  I had been calling it “proof-of-activity” but I see that name has acquired a much more specific meaning than it had when I started calling this by it, and no longer fits.

I still need to figure out what to call my revised structure for the block history database though.

Proof-of-Total-Stake  means measuring the priority of a fork by the total value of TxOuts that existed BEFORE the fork that have been spent AFTER the fork.  In other words, the total stake: how much of EVERYBODY’s money the blocks formed after the fork represent.  That is a well-founded mechanism for security that doesn’t involve trusted parties nor burning hashes.  It’s the only one I’ve come up with.  In the long run, unless somebody comes up with another fundamentally new idea, or accepts the idea at least of trusted block signers, that’s what I think a proper cryptocurrency would have to wind up with.

But there’s a problem with it.

Proof-of-Total-Stake, by itself, doesn’t provide an obvious way to determine who gets to form the next block – which can be a CRUCIALLY important security concern.

And Proof-of-Stake, including Proof-of-Total-stake, doesn’t handle the initial, permissionless, distribution of coins.  They can’t go from “none” to “some.”  They can only go from “some” to “some more.”

So I think it could only be deployed along with some kind of mining.

Q6: We first started interacting some four years ago when I was doing some research on dead cryptocurrencies, most of which were just direct clones or copies of Bitcoin.  At the time you were doing the heavy lifting categorizing how they died in a BitcoinTalk thread.  Today sites like Deadcoins.com have tried to do something similar.  Even though loud advocates at events like to claim blockchains ” live immutably forever” empirically there are probably just as many dead blockchains than living blockchains.  What do you think the top reason for why so many blockchains lose support to the point of death and do you think those reasons will change much in the future?

A6: By far the vast majority of those people were not doing anything INTERESTING!  A lot of the honest ones discovered that it was a lot of work and had other commitments in life.  A lot of the dishonest ones made their money and walked away leaving the  suckers behind.  A lot of people discovered that maintaining a codebase needed more programming chops than they actually possessed, and quietly withdrew from the field. A fair number ran into scammers and crooks whose utterly disgusting behavior left them convinced they wanted to do something else rather than meeting any more of those guys.

But the most important point? Hardly any of those coins was ever used in any transaction for an actual thing – not even an initial experiment like Laszlo’s Pizza.

Most of them were only ever mined by people who intended absolutely nothing beyond immediately converting them into Bitcoin, and only ever held by people who daily watched their value trying to guess the right time to sell them for Bitcoin.

It’s not so much that most of them *failed* – it’s more the case that the vast majority never even remotely began to *succeed*. There was no economic activity, meaning sales of merchandise or payment for work, that they facilitated.  Put bluntly, they just didn’t do anything beyond providing a temporary and completely discardable medium for speculation and scamming.  And, as surely as atomic decay, they got used, for that purpose only, and discarded.

Q7: Based on the original white paper, the intent of Bitcoin was to be an e-cash  payment system which could be utilized without needing to disclose a real identity to an administrator.  It seems that over time several different tribes have popped up, including those who market Bitcoin as a form of “e-gold.”  What do you think of the visible fracture that has occurred between the various Bitcoin tribes?  Does proof-of-work really act as a type of DRM for coin supply or do all the forks we have seen turn the advertised “digital scarcity” and “digital gold” into an oxymoron?

A7: That endless fight, starting with the block size fight, with everybody yelling and nobody listening, pretty much convinced me that the “community” which had grown around Bitcoin was in deep trouble.

The differences between the various proposed technical changes to the block chain, are far less important to the futures of those forks, than the integrity of the people who support and do business using them.

But the technical merits were never discussed by most. Instead, repetitive sound bites and slogans about them containing absolutely no new information were shouted.  Integrity was seldom displayed either. Instead, the fight was carried forward almost exclusively by partisans who had already decided what was the only possible solution that they would accept, and in many cases using tactics that inspire an absolute refusal to support their interests, or even participate in the communities where they are found.

If someone hires a troll army to attack a community by astroturfing fake support for something, can you respect that person?  If someone drives people who disagree away with personal abuse, is that a reasonable method for coming to an agreement about a protocol?  Is it a valid form of technical reasoning to launch a sabotage against a block chain based consensus mechanism?  What can you say about someone who buys existing accounts of users whom others trust in order to fake trusted support for their agenda? How about when it happens after those users whom others trust have been driven away or left in disgust?  Is it a respectful negotiator interested in the insights of others in solving a problem, whose negotiating skills include locking the damn doors and refusing to let someone leave the room until they get his signature on an “agreement” that they wrote without his knowledge before he even got there?

Is someone who would participate in a fight, on those terms, someone whose agenda or business interests you really want to support?  Hint: You already know that people who fake support for their agenda, or tell lies about other in order to discredit them, or who deliberately deceive others about the merits of their own proposal or others’ proposals, are doing business by means of fraud.  Do you want to carry on until the fraud is financial and the victim is you?

These factions had no interest whatsoever in reaching a consensus.  And nothing prevented each from implementing their idea and launching, with no hard feelings from anybody and no fight.  The only thing they were really fighting over was the name “Bitcoin,”  which was absolutely unrelated to the technical merit of any proposal.  And, to a first approximation, the other merits of having the name is a thing that none of them even mentioned during the fight.

Technically speaking, there is not much wrong with any of these forks. They address certain problems in different ways slightly favoring the interests of different groups, but not seriously to anyone’s disadvantage.  None of them was entirely without technical merit.

On the other hand none of them make more than a tiny amount of difference.  None helped with the bandwidth or transaction volume by anything more than a small constant factor, so the problem they were supposedly about solving was not in fact solved, nor even very much affected.

So while none of the proposed changes were objectionable in themselves, there was really no *very* compelling reason for any of them to be implemented.  Each of those ideas is merely a stopgap that pushes the rock down the road another foot or two without moving it out of the way. If you want to move that rock out of the road, you will need a much more powerful idea.

Q8: You’ve mentioned that limited supplies simply incentivizes hoarding which leads to low economic activity.  You have proposed a type of “proof-of-activity” replacement.  Can you expand more on either of these views?

A8: Suppose you have an economy that’s growing (more value is being created) but has a constant supply of coins.

In that case your coins represent, let’s say, one-millionth or so of the money that’s in circulation.

And, as the economy continues to grow, your coins will continue to represent one-millionth or so of the money that’s in circulation.  But that will be one-millionth or so of a lot more actual wealth.  In fact, your money, just sitting there in your wallet, is GUARANTEED to rise in value by the same fraction that the economy is growing by.  In our terms, this would be exactly the market average, as though you were holding stocks invested in ALL the businesses in your economy in proportion according to their  capitalization.  This is what index funds and IRAs make, mostly, but it’s making it with no risk.

Now, if you offer any investor a risk-free investment that’s guaranteed to make the same return as the market average, that investor would be mad to pass it up.  No investor is confident that she’ll beat the market average in any given year.  That’s why they call it “AVERAGE!”  And volatility – variance in return – is an unqualified bad thing because it will always take an 11% gain to make up for a 10% loss.  That money sitting right there in her wallet is the best investment she could possibly make.  There might be things that would make as much or more money, but all of them involve risk out of proportion to their marginal return.  Let other investors do that; they’re suckers and she’ll make the same money they do.

The problem with that is that the other investors are looking at the same question.  And reaching the same conclusion.  Why invest in companies doing anything productive, and expose yourself to risk, when you can make the same money just by holding your investment in your wallet?

And then who invests in the businesses that, if they were working, would actually create the value these people all intend to have some share in?

… (sound of crickets chirping) …  Suckers.

Suckers who lose more often than they win, because it takes an 11% gain to recover a 10% loss.  And the money the lose? Eventually trickles into the hands of the people who are hoarding it.

With no reason for investors to invest in business, the businesses eventually starve and the economy shrinks.  And all those coins that represent one-millionth of the economy’s wealth start representing one-millionth of less and less actual value.

This is what happened to ancient Rome.  They used metals (gold and silver and bronze) as currency, and their economy collapsed WHILE people had plenty enough money to keep it going!  Everybody stashed all their coins expecting to benefit later from prospering businesses, and the businesses, for want of capital, did not prosper.

Then the death spiral started: everybody stashed their coins waiting for the economy to come back so the coins would be worth their “real” value, and the economy never came back.  The coins were never worth their “real” value, until the people who remembered where the coins were buried had also been buried.

It’s a millennium-and-a-half later and we are STILL finding stashes of Roman coins!  The people who could have gotten their economy moving again, if they had EVER supported a business, instead buried their money in sacks.

The government tried to get it moving again, or pretend for a while that it hadn’t collapsed, making coins with increasingly ridiculous adulterated alloys.  But that didn’t change the underlying dynamic.

The Gold bugs of course have all told each other a different version of this story, where the adulterated coins were the cause of the collapse rather than the increasingly desperate attempt to recover from it.  And it’s pointless to try to convince them otherwise; they believe they already know the only possible truth. But for those actually motivated to investigate, the chronology of the events is reasonably clear.

===============================================================

The next thing is about “Proof-of-Total-Stake”, which I guess is what I’m going to call this idea for securing the chain.

The fundamental idea behind Proof-of-Total-Stake is that the priority of any branch of a fork is the total amount of EVERYBODY’s money which that fork represents.  That means, coins generated in that fork and pre-existing coins brought into the fork by transactions.

Coins generated in a fork are the coinbase transactions; Coins moved into the fork from earlier parts of the chain are TxOuts from earlier in the block chain that have been spent during the fork.

But we have to know which BRANCH of the fork they were spent into. ie, someone trying to create a fork should not be able to stick transactions from the valid branch of the chain into it, or they can match the txOut spending from earlier in the chain.  This is the basic problem with most implementations of proof-of-stake, which some writers have called “nothing at stake.”   Whatever resource you are using to secure the chain is meaningless when it can be used to secure *BOTH* forks of the chain.

In order to prevent the replay attack, each transaction would have to “stake” a recent block, making a commitment to supporting only forks which include that block.  This adds a field to each transaction.

The new field would give the (hash) ID of a block, indicating that this particular transaction is not valid in any branch of the chain which does not include the staked block.

So, let’s say that two transactions “coffee” and “eggs” are made at the same time,  after the chain forks at block 50.  “Coffee” stakes block 48 and “eggs” stakes block 51A.

When “coffee” appears in block 51B, the total stake of fork B is increased by that amount; its weight counts toward that resolution of the fork.

Then “eggs” is added to block 52A, and can’t be placed in chain B because it staked a block doesn’t exist in chain B.  Now “eggs” counts as stake in favor of the A branch and “coffee” counts as stake in favor of the B branch.

But then “coffee” appears in branch 53A, where it is also valid because the same block 48 is behind both branches.  This cancels out its support for branch B, just by being equal – revealing that stake which can be used in favor of both chains counts for nothing.

Security happens because some finite resource (coins created before the branch point and spent in transactions that are staked after the branch point) is committed detectably and irrevocably to the support of one branch (by staking after the branch point), and cannot be used to support any other.

This is exactly what Bitcoin does with hashes:  Hashes per second and number of seconds spent hashing are finite.  Hashes are irrevocably used in support of one branch (because the hash preimage can never be made to match a different block).  And the fact that they are used to support a particular branch is detectable.

Well, strictly speaking there’s only one “detectable” hash in each block. All we know about the others is, on average, how rare that one “detectable” one was and therefore, on average, how many they must have been.

But it’s still the same basic criteria.  Some finite resource, committed detectably and irrevocably to the support of one branch, which cannot be used to support conflicting branches.  And proof-of-total stake says that resource is the amount of EVERYBODY’s coins that branch represents.

With transactions supporting the basic security of the chain, and the idea behind coinbases being that they are payment for providing chain security, we want our “coinbases” to reward the people who make transactions that stake recent blocks.

PoTS is strong in the long run, or when the chain is seeing a high volume of legitimate transactions, but has its own problems.

Transactions in most cryptocurrencies are a very bursty use of something with long latent periods.  Absent heavy transaction volume, you can’t really expect PoTS to definitively reject a branch in such a way that a crook couldn’t resurrect it with a very large spend.  If the crook has more coins than the difference in total-stake between the two forks, the crook could resurrect the “dead” fork.

This is why the “interest” payments (actually per-transaction coinbases of a particular sort) when a transaction staking a recent block are made. To encourage a fairly constant stream of transactions that support one particular version of the chain up to a very recent block.

But the peril with that is that you want to structure it in such a way that you don’t incentivize people to overwhelm your bandwidth by transferring every coin they own from their left pocket to their right every block either.  So the actual design would come down to some compromise between transaction fees, and interest payments on transactions staked in very recent blocks, where the breakevens represent the transaction volume you want.

And there are a couple of final things to address together.  First, PoTS, while it has a workable rule for figuring out which branch of forks is preferred, is pretty silent about who gets to form blocks and how.  Second, Interest on coins spent has the “nothing to something” problem where if you don’t have anything in the system to start with, you won’t have anything ever.  These are both classic problem with PoTS coins.  The final design has to include some additional kind of coin creation that doesn’t depend on previous holdings (even if it gets de-emphasized after a while) and some way to determine who forms the next block.

Q9: ICOs have been around in some form or fashion for about five years now.  What’s your view on these fundraising schemes?

A9: The SEC is bouncing on them pretty hard, and as far as I can see it’s pretty much deserved.  Everybody wants something they can freely trade on secondary markets, and sell on the basis of its future value, but they also want to lie about it by saying it isn’t a security.

It is a security.  If a security is sold by a company to raise money, but does not represent a bond (a promise to buy it back) nor a stock (a share in future earnings) then an investor is getting nothing for her money – except maybe a receipt for having made a donation.

Another investor (a “real” investor who knows and understands a broad market, not a speculator who made a lot of money by a couple of strokes of sheer luck) will not buy it from them, at any price.  Such a thing has only speculative value.

If something’s continued value depends on a company, but the company’s continued existence doesn’t depend on that thing having value, it would be an excellent thing to not buy.

And all of that, we can say without ever touching on ethics and business practices of the people who run them.  But when we do touch on the people who run them, the story gets worse.  Much worse.  Much, much worse.  In this most are following the path trod by Altcoins.  And racking up a very similar ratio of efforts that fail, or which never even start to succeed.

Q10: You have alluded to tokenized securities in the LinkedIn article as well as our correspondence, what is your take on this topic?  What are the advantages versus say, simply doing what Carta (formerly eShares) does?

A10: I would have to answer that admitting to some degree of ignorance about Carta.  As I remember eShares, it was very much a top-down stock and option management tool, in that a private company with (non-traded) shares typically uses it to keep track of who owns what – actually issuing assets or recording changes in their status, making info about them available for the holders but mostly just to view online.

What it does not do, as I understand it, is directly enable the shareholders to trade those shares or options with each other.  Nor does it handle securities involved with or created by more than one company at a time.  It is a management interface, not a market.

I envision a block chain – sigh, now I have to come up with a name again.  Phooey.  I never care about naming anything, and then someone wants me to talk about one of my ideas and I have to come up with a name for it on the spot.  Let’s go for the pun and call it the Stock Trading and Options CryptoAsset Keeper.  I could come up with  something even dumber, but for the sake of exposition, call it STOCK.

The idea is that STOCK would act both as a Transfer Agent (which Carta does) AND a market (which AFAIK Carta does not).   A company could issue securities such as stocks and bonds directly on the STOCK block chain (“cryptoassets”) and the block chain could record trades in those issues against its native cryptocurrency.  The benefit here is the clear record and history to keep track of all trades and the current disposition of all the different cryptoassets – the stocks, the bonds, and the “cash” used to trade in them, would all be on the chain.

As long as no off-chain assets like bushels of wheat or truckloads of sneakers need to be delivered, and dividends/prices/etc accruing to these instruments are paid out (or in) in the cryptocurrency, the block chain could then function directly as market, transfer agent, means of delivery, and payment channel.  The task of converting the cryptocurrency to and from actual fiat, and the heavily regulated business of delivering the fiat currency, could be left to already-established cryptocurrency markets.

Trading in stocks/bonds/etc is highly regulated, and debts (NEGATIVE amounts) can crop up unexpectedly when companies go south or options traders go bust. Stuff gets into the RealWorld quickly when someone has to be found for debt payments, served process, and/or prosecuted for fraud, etc.  So STOCK couldn’t be an  “anonymous/permissionless” chain, at least not for regulated trades.  Each person or entity authorized to actually make securities trades would have to have a vetted, verified ID as specified by KYC laws, and would have to sign each such transaction with a public/private key pair proving Identity.

From the point of view of investors, STOCK would be a very sluggish market – submit your trade, have a completely random execution window averaging ten minutes (or whatever) during which the price might change, then a whole block of transactions all fly past at once and everybody’s waiting for the next completely randomly-timed block.  On the other hand, you don’t need an agent, or a broker, or a company transfer agent, or a registrar, or a clearance period, or ANY of those people who normally collect fees on every trade.  You could actually have a market where the buyer and seller get the exact same price with no ‘float’ whatsoever.  And you don’t have to worry about what time it is.  NASDAQ closes at 5PM new york time, and then a whole bunch of “off-market,” “private,” and “over the counter”  trades that nobody but the insiders can participate in or see happen. But STOCK would go on making blocks twenty-four hours a day seven days a week.  Why should it ever stop?

The SEC would be all over it of course; they’d be sticking a microscope up the butts of everybody involved to make sure that there was absolutely no scamming the investors.  Which is, after all, their job. And they’d require KYC compliance, and a whole lot of other regulatory compliance.  But, y’know, that’s kind of how starting any _legitimate_ business in financial services works.  No need to feel special or particularly victimized about that.

And the regulators would need some privileged keys that could be used to “seize” assets when a court orders them to, as part of a settlement for fraud or theft or something.  And everything else.  There’s a great irony that they’re interested in nobody having the opportunity to scam the investors, but they structurally require, just to be able to do their fundamental mission, builtins to the protocol that if misused would allow somebody to scam the investors.

But once satisfied and functioning within the law, I think they’d welcome STOCK as something that puts down a visible, provable, inalterable, unfakeable history of all trades.

Q11: Is there any cryptocurrency you think could become widely used outside of geeks, cypherpunks, and ideologues?  If not, what would need to change and how?  Has any popular coin ossified to such an extent that it can’t meaningfully evolve?

A11: Homer Husband and Harriet Housewife want convenience and familiarity. Which is mostly about form factor and compatibility.  They do not want to deal with key management in any form.

To do that, you have to make a hardware wallet small enough to fit into a wallet or a purse.  It doesn’t have to be literally credit card sized, but couldn’t be much bigger.  It should be the size of a stack of five credit cards, at most.  Or maybe it gets stuck back-to-back onto their cell phone.  It has to have an end that acts like a chip card, or an edge that acts like a mag stripe, or both, so that it can interact with the grocery stores, auto shops, restaurants, etc that Homer and Harriet already do business with.

That’s very very important, because Homer and Harriet aren’t evangelists.  The mechanic they’ve been going to for fifteen years has never heard of cryptocurrency and is never going to deal with the inconvenience of getting set up to accept it.  He wants people to pay cash or pay with a card, and Homer and Harriet would NEVER consider arguing with him about it, don’t want to go to the effort of explaining it to him, and probably couldn’t explain it very well anyway.  If they have to do any of those things, that’s a deal-breaker.

After that you have to get your cryptocurrency onto the Plus or Cirrus network, using the same interface as a foreign fiat currency.  That would allow Homer and Harriet to automate the sale and exchange to whatever local people think is money, or the purchase and exchange to crypto, when they want to spend or accept stuff from that “card.”  This will mean that they get hit with some extra fees when they use it, but
those fees are both unavoidable if you want to be on those networks, and relatively familiar to them.

Finally, there’s that key management thing.  You could handle most of it by making the wallet do it.  But sooner or later, that hardware wallet is going to fall and bounce of the curb, and go crunch under the tires of a bus.  Or, you know, get dropped into the ocean accidentally, or just get lost.

Homer and Harriet are NOT willing to accept that this is not something they can recover.  The only thing that they accept not being able to recover, when they lose their wallet, is familiar, folding fiat currency.  And that’s why they don’t keep very much of folding fiat actually in their regular wallets.

If you do convince them that losing the wallet makes the funds unrecoverable, they will never want to have more than fifteen dollars on it, which will mean it isn’t useful.  So, your hardware wallet has to interact with SOMETHING that keeps enough information about what’s on it, to enable a new wallet to recover everything that got lost.

Q12: Mining farms, mining pools, and ASICs. Many accounts are that Satoshi did not anticipate the full industrial scale these would reach.  Do you agree with this?  What are your views on mining pools and ASICs as we know them know today (specifically as described by Eric Budish’s paper)?

A12: My first problem with ASICs is that they can be used for exactly two things:  Mining cryptocurrencies, and carrying out attacks on cryptocurrencies.

Every day of every year, people who own those enormous ASIC farms are deciding which is the most profitable use of them, on that day.

And the rewards for mining cryptocurrencies ratchet downward every couple of years.

That seems problematic.  I keep watching to see what emerges each time the reward ratchets down, but I haven’t seen evidence yet that any of the big ASIC farms have turned around on any large scale.

My second problem with ASICs is that they are sucking up ridiculous amounts of energy that can never be recovered or used for anything else. I don’t so much mind this when converting the energy into heat is actually useful – replacing electric heaters in the basement of a building with a bank of Antminers that use the same amount of power is
energy-neutral and helps secure the chain.

But that’s not what happens in huge ASIC farms.  All that heat is just waste. Nobody’s home is made more comfortable, no furnace’s power bill is alleviated, no greenhouses are enabled to grow food in the winter, nobody’s oven gets to bake bread with that heat, and all that energy is just plain gone.

The Bitcoin chain issues the same number of coins per day regardless of how much energy is spent; I’d like to think that spending a whole lot less of it, at least in ways where the heat produced isn’t useful, would be better.

But then we get back to the first problem;  If honest miners start spending a whole lot less on the energy costs of hashing, then there’s a whole lot of ASICs not being used, and the owners of those are going to be looking around making their daily decision about what’s more profitable….

So the logic finally does work out the same. Security requires the vast majority of those ASIC boxes to be in use mining.  It just seems such a colossal expenditure of power, and it might be that a different design could have achieved chain security without that global cost.

My third problem with ASICs is that they have become a way for their owners to steal money from the taxpayers in many nations.  Countries that mean to do a good thing for everybody, create “development zones” with subsidized electricity, paid for by the taxpayers of that country. And then people move in with ASIC farms to suck up that electricity which the public paid for, and convert it into bitcoins in their private possession.  These are business that employ very few people, drive the development of no other resources, and otherwise do pretty much nothing for the development of the local economy.  IOW, the taxpayers who paid for that electricity are definitely not getting their money’s worth in economic development.

My fourth problem with ASICs is that there really is no way to monitor centralization of hashing power.  People keep pretending that they’re tracking whether a 51% attack is underway, but I think most of them probably suspect, as I do, that what they’re really tracking is probably nothing more than whether or not the cabal of ASIC farm owners
remembered to configure that new warehouse full of machinery to use a different identifier.

In all fairness, this last thing results directly from anonymous, permissionless mining, which is something that was a very specific and very much desired part of Satoshi’s vision; he wanted anybody to be able to connect and participate, without any interference of a gatekeeper. But there can never be security from a Sybil attack when you don’t have any way of tracking RealWorld identities, and a “majority” can never be
relied on to be more than the front for some cabal or business interest, as long as a Sybil attack is possible.

And that was what Proof-of-work was supposed to prevent.  In those early days everyone was thinking of hashing power as a side effect of computing infrastructure that was likely to be there, or be useful, for other purposes when it wasn’t hashing.  And EVERYBODY has a use for warehouses full of computers, so it was easy to think that hashing power would remain at least somewhat distributed.  The idea that someone would amass enormous numbers of special-purpose machines which made every other kind of computer in the world utterly useless for mining and which are themselves utterly useless for any other job (except attacking the network), was not, I think, really considered.

Satoshi definitely understood, and planned, that there would probably be server farms devoted to mining and that economies of scale and infrastructure would eventually drive individuals with ordinary desktop machines out of the mining business by being more efficient and making it unprofitable for the less efficient machines.

But I’m pretty sure he didn’t think of miners in places with artificially low subsidized rates for electricity outcompeting all other miners because of that advantage, driving the concentration of the vast majority of hashing power into just one country where it’s subject to the orders and whims of just one government and a few businessmen who
pal around with each other.

So he probably figured, yes, there’d be a few dozen large-ish server farms and a couple hundred small-ish server farms, but I’m pretty sure he envisioned them being scattered around the planet, wherever people find it worthwhile to install server farms for other reasons.

I’m fairly sure Satoshi’s notion of the eventual centralization of hashing power didn’t really encompass todays nearly-complete centralization in a single country, owned by a set of people who are subject to the whims and commands of a single government, who very clearly know each other and work together whenever it’s convenient.

And I find it worrisome.

Those enormous mining farms, and the way economics drove them together, are a structural problem with converting electricity into security.

I am not comfortable with the implication that, for any Proof-of-Work block chain including Bitcoin, economics will eventually devolve to the point where, when Beijing says ‘jump’ the mining and security of that block chain says ‘how high?’

And that is one of the greatest reasons why I look around for a different means of securing block chains.

El Fin

Evolving language: Decentralized Financial Market Infrastructure

[Note: this was originally published at Diar.co]

Beginning in late 2014 through early 2015 a small group of startups in the US and UK independently began to lay the ground work for what is often marketed as “permissioned” distributed ledgers.  Or DLT as it became known.

I am acutely aware of their journey because I wrote the key, widely cited paper that unfortunately popularized that exact term (a term first invented by Robert Sams from Clearmatics). 

I say unfortunately because that DLT acronym – while well-intentioned – quickly became a gimmicky “marketing term” by many of the large consultancies around the world trying to capitalize – and frankly scare – clients into buying high-priced toys, none of which gained any meaningful traction.  Conjoined with images of a Candyland nirvana, there were (and are) a slew of “me too” vendors that flooded the market in late 2015 and early 2016 all searching for big pay days and funding from deep pocketed enterprises that had no clue as to what DLT as an acronym actually meant; subsequently some of these flash-in-the-pan ambulance chasing vendors have repivoted to doing things like an ICO or just fading away entirely.

How to visualize this?  If shrink-wrapped box packaging was still en vogue, we could imagine “Now with DLT!” brightly stamped in neon colors on the side of the latest version of some wares. 

For example, some finger-pointing can be done at various software companies, though not all of them.  Lured by a number of their clients who wanted to remove reconciliation but maintain the same intermediated business model, more than a few vendors deconstructed the concept of a byzantine fault-tolerant, globally shared state capable of enabling P2P transfer of value into something arguably less meaningful: bilateral states using the same old financial intermediation to solve the double-spend problem.  In some cases it was boiled down to digitally signed message passing integrated into legacy market structure.  Useful yes, but not revolutionary.  Calling it a “distributed ledger” makes boring software products sound sexy but it ultimately confuses anyone who makes the effort to figure out what it all means.

And because there’s plenty of blame to go around: various coin maximalists religiously latched onto and dutifully created umpteen strawmen arguments using contorted disingenuous views of what DLT meant to them.  The two specific cartoonish examples that stick out the most are the horse-buggy meme and the naive “sewer rat” analogy that is occasionally regurgitated on reddit.  Why are these shortsighted?  Because at the time of their genesis, they both assumed that the only type of blockchain (or distributed ledger) that can or should exist, is the Bitcoin blockchain or derivative thereof.  It is entirely self-serving, dogmatic, and void of empirical reflection.

In all instances – big consultancies, starry-eyed startups, large software companies, and ideological zealots – they eventually butchered the acronym into an indistinguishable pile of mush.  By late 2015 as this was happening, I explained that it was basically the same thing that happened during the “no gluten” marketing mania of the early-2010s.  No one could really tell you what gluten is, but every food vendor was quick to add that their products do not have it.  A bit like cloudwashing endured too.

Due to their collective inability to manage expectations, by mid-2017 nearly the entire “DLT” ecosystem found itself in the abyss of the trough of disillusionment.  A handful never fully fell in and a couple have clawed their way out, without the aid of retail coin flippers or religious troll armies.  Others attempted quick fixes or rebrand such that they were no longer classified as a DLT company hoping that definitionally they couldn’t be in the trough of disillusionment.

A good couple books could be written on the trials and tribulations of the vendors that made the headlines during these first few years.  Eventually the DLT term has fallen out of disfavor for something only slightly less abused: “enterprise chains.”  It’s only marginally better than DLT in that it is shorter when written out and hasn’t been gentrified by VCs or demonized by coin peddlers.  But it’s not really accurate because the tools that are being built, aren’t just for use by enterprises. 

|| Onwards and upwards

This brings us to: DLT is an acronym that has served its initial use and should evolve with the times. 

What then, can we use to describe the utilization of technology to re-architect organizational processes and business models?  Automating networks is generic and while accurate, is not nuanced enough.

While it would take a bit more length than this article form allows for, there are some salvageable ideas worth transplanting in the years ahead. 

For starters, there is something rather mundane but simple: automating the principles for financial market infrastructures (PFMI).  As I – and others – have described elsewhere, PFMI are decades old standards by which operators (and overseers) of financial market infrastructure ought to follow; in most jurisdictions operators are legally required to follow them.  Basically a list of do’s and don’ts for running systemically important things like payment and settlement systems.   Like, how to identify risks and hold those who touch risk accountable when something goes wrong.  This is a bundle of seemingly boring but existentially important frameworks.

Which principals can be automated or should be automated?  Unfortunately, that’s beyond the scope of this short article.

What is being briefly proposed – and built – is what can be labeled “dFMI”: decentralized financial market infrastructure.

Funnily enough, FMI today is typically distributed and not fully centralized.  In the case of the EU there is a supranational payment system, but this is an exception to the rule that each developed, and most developing, country has one or more payment, clearing, and settlement system for both cash and securities.  The majority of these systems were set up and created heavy intermediation (single point of trust) due in part to technological limitations of the 1970s.  The CSDs such as DTCC and even exchange operators exist the way they do today – as systemically important institutions – partly because of an era in which mainframes and ‘minicomputers’ were the only available options.

What if we could safely and securely disintermediate market structure, reduce single points of trust, and remove monopoly rents, all while following PFMI?

It is a bold vision, but one that does not involve standing on tables saying it is the greatest thing since the invention of the internet or preying on unsophisticated retail investors in order to flog the coin-of-the day to some other retail punter.

It’s easy to be cynical towards an ecosystem that has proportionally attracted as many snake oil salesmen as the various coin groups have the past few years.  And it is hard to fulfill the promises that are hyped at events.  For example, the Sibos “New Kids on the Blockchain” video from 2015 is illustrative of those difficulties: just a couple of the panelists still work for the same company they did at the time and all of the groups represented in the video have had uphill battles to stay afloat today.

In conclusion, instead of playing identity politics with lightning bolts in a social media handle, motivated developers genuinely looking to help transform market structure can crack open a copy of the PFMI handbook and immerse themselves with a world that keeps civilization from falling apart. 

Coupled with tools and libraries first conjured up within the ill-defined drama-filled blockchain world, real market structure changes can be made and society will be better off for it.  Best of all, it doesn’t need to involve burning mountains of coal to secure either.

It’s not sin to still use DLT as a term-of-art but dFMI is arguably a more expressive acronym, providing more context for both practioners and users alike.

How much electricity is consumed by Bitcoin, Bitcoin Cash, Ethereum, Litecoin, and Monero?

I recently created a thread that on Twitter regarding the lower-bound estimates for how much electricity the Bitcoin blockchain consumed using publicly available numbers.

The first part of this post is a slightly modified version of that thread.

The second part of this post, below part 1, includes additional information on Bitcoin Cash, Ethereum, Litecoin, and Monero using the same type of methodology.

Background

The original nested thread started by explaining why a proof-of-work (PoW) maximalist view tries to have it both ways.

You cannot simultaneously say that Bitcoin is – as measured by hashrate – the “most secure public chain” and in the same breath say the miners do not consume enormous quantities of energy to achieve that.  The fundamental problem with PoW maximalism is that it wants to have a free energy lunch.

All proof-of-work chains rely on resource consumption to defend their network from malicious attackers.  Consequently, a less resource intensive network automatically becomes a less secure network.1  I discussed this in detail a few years ago.

Part 1: Bitcoin

Someone recently asked for me to explain the math behind some of Bitcoin’s electricity consumption, below is simple model using publicly known numbers:

  • the current Bitcoin network hashrate is around 50 exahashes/sec
  • the most common mining hardware is still the S9 Antminer which churns out ~13 terahashes/sec

Thus the hashrate pointed at the Bitcoin network today is about 50,000,000 terashashes.

Dividing one from the other, this is the equivalent of 3,846,000 S9s… yes over 3 million S9s.

While there is other hardware including some newer, slightly more energy efficient gear online, the S9 is a good approximate.

Because the vast majority of these machines are left on 24/7, the math to estimate how much energy consumption is as follows:

  • in practice, the S9 draws about 1,500 watts
  • so 1,500 x 24 = 36kWh per machine per day

Note: here’s a good thread explaining this by actual miners.

In a single month, one S9 will use ~1,080 kWh.

Thus if you multiply that by 3,846,000 machines, you reach a number that is the equivalent of an entire country.

  • for a single day the math is: ~138.4 million kWh / day
  • annually that is: ~50.5 billion kWh / year

For perspective, ~50.5 billion kWh / year would place the Bitcoin network at around the 47th largest on the list of countries by electricity consumption, right between Algeria and Greece.

But, this estimate is probably a lower-bound because it doesn’t include the electricity consumed within the data centers to cool the systems, nor does it include the relatively older ASIC equipment that is still turned on because of local subsidies a farm might receive.

So what?

According to a recent Wired article:

In Iceland, the finance minister has warned that cryptocurrency mining – which uses more power than the nation’s entire residential demand – could severely damage its economy.

Recent analysis from a researcher at PwC places the Bitcoin network electricity consumption higher, at more than the level of Austria which is number 39th on that list above.  Similarly, a computer science professor from Princeton estimates that Bitcoin mining accounts for almost 1% of the world’s energy consumption.2

Or to look at it in a different perspective: the Bitcoin network is consuming the same level of electricity of a developed country – Austria – a country that generates ~$415 billion per year in economic activity.

Based on a recent analysis from Chainalysis, it found that Bitcoin – which is just one of many proof-of-work coins – handled about $70 million in payments processed for the month of June.  Yet its cost-per-transaction (~$50) is higher than at any point prior to November 2017.

You don’t have to be a hippy tree hugger (I’m not) to clearly see that a proof-of-work blockchains (such as Bitcoin and its derivatives) are currently consuming significantly more resources than they create. However this math is hand-waved away on a regular basis by coin lobbyists.

The figure also didn’t include the e-waste generated from millions of single-use ASIC mining machines that are useful for about ~12 months; or the labor costs, or building rents, or transportation, etc.  These ASIC-based machines are typically discarded and not recycled.

In addition to e-waste, many mining farms also end up with piles of discarded cardboard boxes and styrofoam (source)

Part 2: Bitcoin Cash

With Bitcoin Cash the math and examples are almost identical to the Bitcoin example above.  Why?  Because they both use the same SHA256 proof-of-work hash function and as a result, right now the same exact hardware can be used to mine both (although not simultaneously).3

So what do the numbers look like?

The BCH network hashrate has been hovering around 4 – 4.5 exahashes the past month. So let’s use 4.25 exahashes.

Note: this is about one order of magnitude less hashrate than Bitcoin so you can already guesstimate its electricity usage.  But let’s do it by hand anyways.

An S9 generates ~13 TH/s and 4.25 exahashes is 4.25 million terahashes.

After dividing: the equivalent of about 327,000 S9s are used.

Again, these machines are also left on 24/7 and consume about 36 kWh per machine per day.  So a single S9 will use ~1,080 kWh per month.

  • 327,000 S9s churning for one day: ~11.77 million kWh / day
  • Annually this is: ~4.30 billion kWh / year

To reuse the comparison above, what country’s total electricity consumption is Bitcoin Cash most similar to?

Around 124th, between Moldova and Cambodia.

How much economic activity does Moldova and Cambodia generate with that electricity consumption?  According to several sources, Cambodia has an annual GDP of ~ $22 billion and Moldova has an annual GDP of ~$8 billion.

For comparison, according to Chainalysis, this past May, Bitcoin Cash handled a mere $3.7 million in merchant payments, down from a high of $10.5 million in March a couple months before.

Also, the Bitcoin Cash energy consumption number is likely a lower-bound as well for the reasons discussed above; doesn’t account for the e-waste or the resources consumed to create the mining equipment in the first place.

This illustrates once again that despite the hype and interest in cryptocurrencies such as Bitcoin and Bitcoin Cash, there is still little real commercial “activity” beyond hoarding, speculation, and illicit darknet markets.  And in practice, hoarding is indistinguishable from losing a private key so that could be removed too.  Will mainstream adoption actually take place like its vocal advocates claim it will?

Discarded power supplies from Bitcoin mining equipment (source)

Part 3: Ethereum

So what about Ethereum?

Its network hashrate has been hovering very closely to 300 TH/s the past month

At the time of this writing, the Ethereum network is still largely dominated by large GPU farms. It is likely that ASICs were privately being used by a handful of small teams with the necessary engineering and manufacturing talent (and capital), but direct-to-consumer ASIC hardware for Ethereum didn’t really show up until this summer.

There are an estimated 10 million GPUs churning up hashes for the Ethereum network, to replace those with ASICs will likely take more than a year… assuming price stability occurs (and coin prices are volatile and anything but stable).

For illustrative purposes, what if the entire network were to magically switch over the most efficient hardware -the Innosilicon A10 – released next month?

Innosilicon currently advertises its top machine can generate 485 megahashes/sec and consumes ~ 850 W.

So what is that math?

The Ethereum network is ~300 TH/s which is around 300,000,000 megahashes /sec.

Quick division: that’s the equivalent of 618,557 A10 machines.

Again, each machine is advertised to consume ~850 W.

  • in a single day one A10 consumes: 20.4 kWh
  • in a month: ~612 kWh

So what would 618,557 A10 machines consume in a single day?
– about 12.6 million kWh / day

And annually:
– about 4.6 billion kWh / year

That works out to be between Afghanistan or Macau.  However…

Before you say “this is nearly identical to Bitcoin Cash” keep in mind that the Ethereum estimate above is the lowest of lower-bounds because it uses the most efficient mining gear that hasn’t even been released to the consumer.

In reality the total energy consumption for Ethereum is probably twice as high.

Why is Etherum electricity usage likely twice as high as the example above?

Because each of the ~10 million GPUs on the Ethereum network is significantly less efficient per hash than the A10 is. 4  Note: an example of a large Ethereum mine that uses GPUs is the Enigma facility.

For instance, an air-cooled Vega 64 can churn ~41 MH/s at around 135 W which as you see above, is much less efficient per hash than an A10.

If the Ethereum network was comprised by some of the most efficient GPUs (the Vega 64) then the numbers are much different.

Starting with: 300,000,000 MH/s divided by 41 MH/s.  There is the equivalent to 7.32 million Vega GPUs generating hashes for the network which is more in line with the ~10 million GPU estimate.

  • one Vega 64 running a day consumes ~3.24 kWh
  • one Vega 64 running a month: ~77.7 kWh

If 7.32 million Vega equivalent GPUs were used:

  • in a day: ~ 23.71 million kWh
  • in a year: ~8.65 billion kWh

That would place the Ethereum network at around 100th on the electricity consumption list, between Guatemala and Estonia.

In terms of economic activity: Guatemala’s GDP is around $75 billion and Estonia’s GDP is around $26 billion.

What is Ethereum’s economic activity?

Unlike Bitcoin and Bitcoin Cash, the stated goal of Ethereum was basically to be a ‘censorship-resistant’ world computer.  Although it can transmit funds (ETH), its design goals were different than building an e-cash payments platform which is what Bitcoin was originally built for.

So while merchants can and do accept ETH (and its derivatives) for payment, perhaps a more accurate measure of its activity is how many Dapp users there are.

There are a couple sites that estimate Daily Active Users:

  • State of the Dapps currently estimates that there are 8.93k users and 8.25K ETH moving through Dapps
  • DappRadar estimates a similar number, around 8.37k users and 8.57K ETH moving through Dapps

Based on the fact that the most popular Dapps are decentralized exchanges (DEXs) and MLM schemes, it is unlikely that the Ethereum network is generating economic activity equivalent to either Guatemala or Estonia.5

For more on the revenue Ethereum miners have earned and an estimate for how much CO2 has been produced, Dominic Williams has crunched some numbers.  See also this footnote.6

According to Malachi Salacido (above), their mining systems (in the background) are at a 2 MW facility, they are building a 10 MW facility now and have broken ground on a 20 MW facility. Also have 8 MW of facilities in 2 separate locations and developing projects for another 80 MW. (source)

Part 4: Litecoin

If you have been reading my blog over the past few years, you’ll probably have seen some of my Litecoin mining guides from 2013 and 2014.

If you haven’t, the math to model Litecoin’s electricity usage is very similar to both Bitcoin and Bitcoin Cash.  From a mining perspective, the biggest difference between Litecoin and the other two is that Litecoin uses a hash function called scrypt, which was intended to make Litecoin more “ASIC-resistant”.

Spoiler alert: that “resistance” didn’t last long.

Rather than diving into the history of that philosophical battle, as of today, the Litecoin network is composed primarily of ASIC mining gear from several different vendors.

One of the most popular pieces of equipment is the L3+ from Bitmain.  It’s basically the same thing as the L3 but with twice the hashrate and twice the power consumption.

So let’s do some numbers.

Over the past month, the Litecoin network hashrate has hovered around 300 TH/s, or 300 million MH/s.

Based on reviews, the L3+ consumes ~800 W and generates ~500 MH/s.

So some quick division, there are about 600,000 L3+ machines generating hashes for the Litecoin network today.

As an aggregate:

  • A single L3+ will consume 19.2 kWh per day
  • So 600,000 will consume 11.5 million kWh per day
  • An annually: 4.2 billion kWh per year

Coincidentally this is roughly the same amount as Bitcoin Cash does as well.

So it would be placed around 124th, between Moldova and Cambodia.

Again, this is likely a lower-bound as well because it assumes the L3+ is the most widely used ASIC for Litecoin but we know there are other, less efficient ones being used as well.

What about activity?

While there are a few vocal merchants and a small army of “true believers” on social media, anecdotally I don’t think I’ve spoken to someone in the past year who has used Litecoin for any good or service (besides converting from one coin to another).

We can see that — apart from the bubble at the end of last year — the daily transaction volume has remained roughly constant each day for the past 18 months.  Before you flame me with a troll account, consider that LitePay collapsed before it could launch, partly because Litecoin still lacks a strong merchant-adopting ecosystem.

In other words, despite some support by merchant payment processors, its current usage is likely as marginal as Bitcoin and Bitcoin Cash.

Genesis Mining facility with Zeus scrypt mining equipment (source)

Part 5: Monero

The math around Monero is most similar to Ethereum in that it is largely dominated by GPUs.

In fact, earlier this year, a large number of Monero developers convinced its boisterous userbase to fork the network to prevent ASICs from being used.  This resulted in four Monero forks and basically all of them are dominated by high-end GPUs.

For the purposes of this article, we are looking at the fork that has the highest hashrate, XMR.  Over the past month its hashrate has hovered around 475 MH/s.

Only 475 MH/s?  That may sound like a very diminutive hashrate, but it is all relative to what most CPU and GPU hashrate performance is measured in Monero and not other coins.

For example, MoneroBenchmarks lists hundreds of different system configurations with the corresponding hashrate.  Similarly there are other independent testing systems that provide public information on hashrates.

Let’s take that same Vega 64 used above from Ethereum.  For Monero, based on tweaking it generates around 2000 hashes/sec and consumes around 160 W.

So the math is as follows:

  • 475,000,000 hashes/sec is the current average hashrate
  • A single Vega 64 will generate about 2000 hashes/sec
  • The equivalent of 237,500 Vega 64s are being used
  • Each Vega 64 consumes about 3.84 kWh per day
  • So 237,500 Vega 64s consume 912,000 kWh per day
  • And in a year: 332 million kWh

The 332 million kWh / year figure is a lower-bound because like the Ethereum Vega 64 example above: it doesn’t include the whole mining system, all of these systems still need a CPU with its own RAM, hard drive, and so forth.

As a result, the real electricity consumption figure is much closer to Haiti than Seychelles, perhaps even higher.  Note: Haiti has a ~$8.4 billion economy and the GDP of Seychelles is ~$1.5 billion.

So what about Monero’s economic activity?  Many Monero advocates like to market it as a privacy-focused coin.  Some of its “core” developers publicly claimed it would be the best coin to use for interacting with darknet markets.  Whatever the case may be, compared to the four above, currently it is probably the least used for commercial activity as revealed by its relative flat transactional volume this past year.

A now-deleted image of a Monero mining farm in Toronto (source)

Conclusion

Above were examples of how much electricity is consumed by just five proof-of-work coins.  And there are hundreds of other PoW coins actively online using disproportionate amounts of electricity relative to what they process in payments or commerce.

This article did not dive into the additional resources (e.g., air conditioning) used to cool mining equipment.  Or the subsidies that are provided to various mining farms over the years.  It also doesn’t take into account the electricity used by thousands of validating nodes that each of the networks use to propagate blocks each day.

It also did not include the huge amount of semiconductors (e.g. DRAM, CPUs, GPUs, ASICs, network chips, motherboards, etc.) that millions of mining machines use and quickly depreciate within two years, almost all of which becomes e-waste.7 For ASIC-based systems, the only thing that is typically reused is the PSU, but these ultimately fail as well due to constant full-throttle usage.

In summation, as of this writing in late August 2018:

  • Bitcoin’s blockchain likely uses the same electricity footprint as Austria, but probably higher
  • Bitcoin Cash’s blockchain is at least somewhere between Moldova and Cambodia, but probably higher
  • Ethereum’s blockchain is at least somewhere between Guatemala and Estonia, but probably higher
  • Litecoin’s blockchain is at least somewhere between Moldova and Cambodia, but probably higher
  • One of Monero’s blockchains is at least somewhere between Haiti and Seychelles, but probably higher

Altogether, these five networks alone likely consume electricity and other resources at an equivalent scale as The Netherlands especially once you begin to account for the huge e-waste generated by the discarded single-use ASICs, the components of which each required electricity and other resources to manufacture.  Perhaps even higher when costs of land, labor, on-going maintenance, transportation and other inputs are accounted for.

The Netherlands has the 18th largest economy in the world, generating $825 billion per annum.

I know many coin supporters say that is not a fair comparison but it is.  The history of development and industrialization since the 18th century is a story about how humanity is increasingly more productive and efficient per unit of energy.

Proof-of-work coins are currently doing just the opposite.  Instead of being more productive (e.g., creating more outputs with the same level of inputs), as coin prices increase, this incentivizes miners to use more not less resources.  This is known as the Red Queen Effect.89

For years, proof-of-work advocates and lobbying organizations like Coin Center have been claiming that the energy consumption will go down and/or be replaced by renewable energy sources.

But this simply cannot happen by design: as the value of a PoW coin increases, miners will invest more capital in order to win those coins.  This continues to happen empirically and it is why over time, the aggregate electricity consumption for each PoW coin has increased over time, not decreased.  As a side-effect, cryptocurrency mining manufacturers are now doing IPOs.10

Reporters, if you plan to write future stories on this topic, always begin by looking at the network hashrate of the specific PoW coin you are looking at and dividing it by the most common piece of mining hardware.  These numbers are public and cannot be easily dismissed.  Also worth looking at the mining restrictions and bans in Quebec, Plattsburgh, Washington State, China, and elsewhere.

To front-run an example that coin promoter frequently use as a whataboutism: there are enormous wastes in the current traditional financial industry, removing those inefficiencies is a decades-long ordeal.  However, as of this writing, no major bank is building dozens of data centers and filling them with single-use ASIC machines which continuously generate random numbers like proof-of-work coins do.  That would be rightly labeled as a waste.

In point of fact, according to the Federal Reserve:

In the aggregate, U.S. PCS systems process approximately 600 million transactions per day, valued at over $12.6 trillion.

It shouldn’t take the energy footprint of a single country, big or small, to confirm and settle electronic payments of that same country.  The fact of the matter is that with all of its headline inefficiencies (and injustices), that the US financial system has — the aggregate service providers still manage to process more than three orders of magnitude more in transactional volume per day than all of the major PoW coins currently do.11 And that is just one country.

Frequent rejoinders will be something like “but Lightning!” however at the time of this writing, no Lightning implementation has seen any measurable traction besides spraying virtual graffiti on partisan-run websites.

Can the gap between the dearth of transactional volume and the exorbitantly high cost-per-transaction ratio be narrowed?  Does it all come down to uses?  Right now, the world is collectively subsidizing dozens of minuscule speculation-driven economies that in aggregate consumes electricity on par with the 18th largest real economy, but produces almost nothing tangible in exchange for it.

What if all mining magically, immediately shifted over to renewable energy?

Izabella Kaminska succinctly described how this still doesn’t solve the environmental impact issues:

Renewable is displacement. Renewable used by bitcoin network is still renewable not used by more necessary everyday infrastructure. Since traditional global energy consumption is still going up, that ensures demand for fossil continues to increase.

To Kaminska’s point, in April a once-shuttered coal power plant in Australia was announced to be reopened to provide electricity to a cryptocurrency miner.  And just today, a senator from Montana warned that the closure of a coal power plant “could harm the booming bitcoin mining business in the state.”

It is still possible to be interested in cryptocurrencies and simultaneously acknowledge the opportunity costs that a large subset of them, proof-of-work coins, are environmental black holes.12

If you’re interested in discussing this topic more, feel free to reach out.  If you’re looking to read detailed papers on the topic, also highly recommend the first two links listed below.

Recommended reading:

End notes

  1. If the market value of a coin decreases, then because hashrate follows price, in practice hashrate also declines.  See also a ‘Maginot Line’ attack []
  2. Another estimate is that Bitcoin’s energy usage creates as much CO2 as 1 million transatlantic flights. []
  3. There have been proposals from various developers over the years to change this hash function but at the time of this writing, both Bitcoin and Bitcoin Cash use the same one. []
  4. And because many of these mining systems likely use more-powerful-than-needed CPUs. []
  5. Note: Vitalik Buterin highlighted this discrepancy earlier this year with the NYT: The creator of Ethereum, Vitalik Buterin, is leading an experiment with a more energy-efficient way to create tokens, in part because of his concern about the impact that the network’s electricity use could have on global warming. “I would personally feel very unhappy if my main contribution to the world was adding Cyprus’s worth of electricity consumption to global warming,” Mr. Buterin said in an interview. []
  6. At 8.65 billion kWh * $0.07 / kWh comes to around $600 million spent on electricity per year.  Mining rewards as of this writing: 3 ETH * $267 / ETH * 6000 blocks / day equals to $4.8 million USD / day.  Or ~$1.7 billion per year.  This includes electricity and hardware.  Thanks to Vitalik for double-checking this for me. []
  7. Just looking at the hash-generating machines, according to Chen Min (a chip designer at Avalon Mining), as of early November 2017, 5% of all transistors in the entire semiconductor industry is now used for cryptocurrency mining and that Ethereum mining alone is driving up DRAM prices. []
  8. See Chapter 3 []
  9. As described in a Politico article this past spring: “To maintain their output, miners had to buy more servers, or upgrade to the more powerful servers, but the new calculating power simply boosted the solution difficulty even more quickly. In effect, your mine was becoming outdated as soon as you launched it, and the only hope of moving forward profitably was to adopt a kind of perpetual scale-up: Your existing mine had to be large enough to pay for your next, larger mine.” []
  10. Following the dramatic drop in coin prices since January, Nvidia missed its revenue forecast from cryptocurrency-related mining: Revenues from miners were $289 million in Q1, which was about 10% of Nvidia’s revenue. The forecast for Q2 was $100 million and the actual revenues ended up being $18 million. []
  11. On average, the Bitcoin network confirms about 300,000 transactions per day.  A lot of that is not commercial activity.  Let’s take the highest numbers from Chainalysis and assume that each major cryptocurrency is processing at least $10 million in merchant transactions a day.  They aren’t, but let’s assume that they are.  That is still several orders of magnitude less than what US PCS systems do each day. []
  12. The ideological wing within the cryptocurrency world has thus far managed to convince society that negative externalities are ‘worth the cost.’  This narrative should be challenged by both policy makers and citizens alike as everyone must unnecessarily bear the environmental and economic costs of proof-of-work blockchains.  See also the Bitcoin Energy Consumption Index from Digiconomist and also Bitcoin is not a good fit for renewable energy. Here’s why. []

The GRU

[Note: the content below was originally sent to clients and contacts on a private weekly note from Post Oak Labs on July 15, 2018.]

Earlier this week, the Mueller investigation indicted a dozen GRU officers as part of its investigation into the 2016 elections.

In the indictment, the DoJ alleges that these officers used bitcoin to finance some of its operations.  This was not limited to simply exchanging bitcoins for services, but also mining them. It is unclear how many bitcoins were mined or which specific mining pool was involved.

If you have read my articles and papers in the past, this is an issue I and others have raised with respect to FMI: the possibility of illicit actors not only running infrastructure but profiting and having the ability to launder proceeds of crime.  See “know your miner” in Chapter 3.

For example, in early 2015, after publishing Consensus as a service, several coin journalists chain’splained to me that it is not a problem if North Korea or other actors were running mining pools that regulated institutions used to process financial instruments.  This was back in the heyday of maximalism — the view that everything would run on top of Bitcoin, laws be damned.

Turns out, they were probably wrong because financial institutions likely would be violating AML / OFAC / sanctions check requirements if they were sending payments to pools/miners that were sanctioned and/or located in sanctioned countries.  Vendors such as Symbiont eventually shifted to non-public chain infrastructure because of this legal constraint too (though they originally started by using Bitcoin).

An ironic thing that most of the ideological bitcoin proponents miss is: that savvy state actors could be using the infrastructure nominally built by anarchists… in order to carry out the state-sponsored activities (such as what the GRU allegedly did, but also less sophisticated operations).

Why did the GRU use bitcoins?  According to the indictment, to avoid direct relationships with traditional financial institutions.  We can only speculate at this time for other reasons but consider that if you mine a coin, a 3rd party cannot immediately track the purchase of newly minted coins… because they haven’t been purchased.  This is one reason why “virgin” coins carry a premium over others. For instance, Blocktrail provided the service (although it has since removed its announcement).

In the future, perhaps mining equipment manufacturers could be subpoenaed to learn their customer list, but keep in mind that there is a secondary market for miners as well, and some of those have ended up in both North Korea and Russia.

Anyone have a guess for how much state-sponsored activity comprises cryptocurrency networks today?

Cryptocurrency and blockchain-related book reviews

Over the past few years I’ve had the chance to read through and dissect several cryptocurrency and blockchain-related books.

Below are the reviews I have publicly published (in chronological order):

Be sure to also check out Turning it to 11, a quick reflection on these reviews.

I’ve provided feedback on a handful of others.  If you’re currently writing a book on the topic – and schedule permitting – feel free to send over a draft for my candid feedback.

Book Review: Cryptoassets

[Disclaimer: The views expressed below are solely my own and do not necessarily represent the views of my clients.  I currently own no cryptocurrencies.]

As a follow-on to my previous book reviews, an old colleague lent me a copy of Cryptoassets by Chris Burniske and Jack Tatar.

Overall they have several “meta” points that could have legs if they substantially modify the language and structure of multiple sections in the book.  As a whole it’s about on par with the equally inaccurate “Blockchain Revolution” by the Tapscotts.

As I have one in my previous book reviews, I’ll go through and provide specific quotes to backup the view that the authors should have waited for more data and relevant citations as some of their arguments lack definitive supporting evidence.

In short: hold off from buying this edition.

If you’re interested in understanding the basics of cryptocurrencies but without the same level of inaccuracies, check out the new The Basics of Bitcoins and Blockchains by Antony Lewis.  And if you’re interested in the colorful background of some of the first cryptocurrency investors and entrepreneurs, check out Digital Gold by Nathaniel Popper.

Another point worth mentioning at the beginning is that there are no upfront financial disclosures by the authors.  They do casually mention that they have bitcoin once or twice, but that’s about it.

I think this is problematic because it is not being transparent about potential conflicts of interest (e.g., promoting financial products you may own and hope to see financial gain from).

For instance, we learned that Chris Burniske carried around a lot of USD worth of cryptocurrencies on his phone from a NYT article last year:

But a particularly concentrated wave of attacks has hit those with the most obviously valuable online accounts: virtual currency fanatics like Mr. Burniske.

Within minutes of getting control of Mr. Burniske’s phone, his attackers had changed the password on his virtual currency wallet and drained the contents — some $150,000 at today’s values.

Some quick math for those at home.  The NYT article above was published on August 21, 2017 when 1 BTC was worth about $4,050 and 1 ETH was worth about $314.  So Burniske may have had around 37 BTC or 477 ETH or a combination of these two (and other coins).

That is not a trivial amount of money and arguably should have been disclosed in this book and other venues (such as op-eds and analyst reports).1 In the next edition, they should consider adding a disclosure statement.

A final comment is that several reviewers suggested I modify the review below to be (re)structured like a typical book review — comparing broad themes instead of a detailed dissection — after all who is going to read 38,000+ words?

That is a fair point.  Yet because many of the points they attempt to highlight are commonly repeated by promoters of cryptocurrencies, I felt that this review could be a useful resource for readers looking for different perspective to the same topics frequently discussed in media and at events.

Note: all transcription errors are my own.


Authors’ Note

On p. xi, the authors wrote:

When embarking on our literary journey, we recognized the difficulty in documenting arguably the world’s fastest moving markets. These markets can change as much in a day – up or down – as the stock market changes in a year.

It is only mentioned in passing once or twice, but we know that market manipulation is a real on-going phenomenon.  The next edition could include a subsection of cryptocurrencies and ICOs that the CFTC and SEC – among other regulators – have identified and prosecuted for manipulation.  More on that later below.

Foreword

On p. xiv, Brian Kelly wrote in the Foreword

The beauty of this book is that it takes the reader on a journey from bitcoin’s inception in the ashes of the Great Financial Crisis to its role as a diversifier in a traditional investment portfolio.

A small quibble: Satoshi actually began writing the code for Bitcoin sometime in mid-2007, before the GFC took place.  It may be a chronological coincidence that it came out when it did, especially since it was supposed to be a payment system, which is just one small function of a commercial bank.23

On p. xv Kelly writes:

As with any new model, there are questions about legality and sustainability, but the Silicon Valley ethos of “break things first, then ask for forgiveness” has found its way to Wall Street.

There are also two problems with this:

  1. Both the SEC and CFTC – among other federal agencies – were set up in the past because of the behavior that Kelly thinks is good: “break things first, then ask for forgiveness” is arguably a bad ethos to have for any fiduciary and prudential organizations.4
  2. Any organization can do that, that’s not hard.  Some have gotten away with it more than others.  For instance, Coinbase was relatively loose with its KYC / AML requirements in 2012-2014 and has managed to get away with it because it grew fast enough to become an entity that could lobby the government.

On p.xv Kelly writes

“Self-funded, decentralized organizations are a new species in the global economy that are changing everything we know about business.”

In point of fact, virtually all cryptocurrencies are not self-funded.  Even Satoshi had some kind of budget to build Bitcoin with.  And basically all ICOs are capital raises from external parties.  Blockchains don’t run and manage themselves, people do.

On p. xv Kelly writes:

“These so-called fat protocols are self-funding development platforms that create and gain value as applications are built on top.”

The fat protocol thesis has not really born out in reality, more on that in a later chapter below.  While lots of crytpocurrency “thought leaders” love to cite the original USV article, none of the platforms are actually self-funded yet.  They all require external capital to stay afloat because insiders cash out for real money.5 And because there is a coin typically shoehorned at the protocol layer, there is very little incentive for capable developers to actually create apps on top — hence the continual deluge of new protocols each month — few actors want to build apps when they can become rich building protocols that require coins. More on this later.6

Introduction

On p. xxii the authors write:

“… and Marc Andreessen developing the first widely used web browser, which ultimately became Netscape.”

A pedantic point: Marc Andreessen was leader of a team that built Mosaic, not to take away from that accomplishment, but he didn’t single handedly invent the web browser.  Maybe worth rewording in next edition.

On p. xxiii they write:

Interestingly, however, the Internet has become increasingly centralized over time, potentially endangering its original conception as a “highly survivable system.”

This is a valid point however it glosses over the fact that all blockchains use “the internet” and also — in practice — most public blockchains are actually highly centralized as well.  Perhaps that changes in time, but worth looking at “arewedecentralizedyet.”

On p. xxiii they write:

Blockchain technology can now be thought of as a general purpose technology, on par with that of the steam engine, electricity, and machine learning.

This is still debatable.  After all, there is no consensus on what “blockchains” are and furthermore, as we have seen in benchmark comparisons, blockchains (however defined) come in different configurations.  While there are a number of platforms that like to market themselves as “general purpose,” the fact of the matter is that there are trade-offs based on the user requirements: always ask who the end-users and the use-cases a blockchain was built around are.

On p. xxiv they cite Don and Alex Tapscott.  Arguably they aren’t credible people on this specific topic.  For example, their book was riddled with errors and they even inappropriately made-up advisors on their failed bid to launch and fund their NextBlock Global fund.

On p. xxiv the authors write:

Financial incumbents are aware blockchain technology puts on the horizon a world without cash – no need for loose bills, brick-and-mortar banks, or, potentially, centralized monetary policies.  Instead, value is handled virtually through a system that has no central authority figure and is governened in a centralized and democratic manner. Mathematics force order in the operations. Our life savings, and that of our heirs, could be entirely intangible, floating in a soup of secure 1s and 0s, the entire system accessed through computers and smartphones.

This conflates multiple things: digitization with automation.7  Retail banking has and will continue its march towards full digital banking.  You don’t necessarily need a blockchain to accomplish that — we see that with Zelle’s adoption already.8

Also, central banks are well aware that they could have some program adjust interest rates, but discretion is still perceived as superior due to unforeseen incidents and crisis. 9

On p. xxv they write:

The native assets historically have been called cryptocurrencies or altcoins but we prefer the term cryptoassets, which is the term we will use throughout the book.

The term seems to have become a commonly accepted term but to be pedantic: most owners and users do not actually utilize the “cryptography” part — because they house the coins in exchanges and other intermediaries they must trust (e.g., the user doesn’t actually control the coin with a private key).10

And as we continue to see, these coins are easily forkable.  You can’t fork physical assets but you can fork and clone digital / virtual ones.  That’s a separate topic though maybe worth mentioning in the next edition.

On p. xxv they write:

It’s early enough in the life of blockchain technology that no books yet have focused solely on public blockchains and their native cryptoassetss from the investing perspective. We are changing that because investors need to be aware of the opportunity and armed both to take advantage and protect themselves in the fray.

Might be worth rewording because in Amazon there are about 760 books that pop up when “investing in cryptocurrencies” is queried.  And many of those predate the publication of Cryptoassets.  For instance, Brian Kelly, who wrote the Forward, published a fluffy coin promotion book a few years ago.

On p. xv they write:

Inevitably, innovation of such magnitude, fueled by the mania of making money, can lead to overly optimistic investors. Investors who early on saw potential in Internet stock encountered the devastating dot-com bubble. Stock in Books-A-Million saw its price soar by over 1,000 percent in one week simply by announcing it had an updated website. Subsequently, the price crashed and the company has since delisted and gone private. Other Internet-based high flyers that ended up crashing include Pets.com, Worldcom, and WebVan. Today, none of those stocks exist.

So far, so good, right?

Whether specific cryptoassets will survive or go the way of Books-A-Million remains to be seen.  What’s clear, however, is that some will be big winners. Altogether, between the assets native to blockchains and the companies that stand to capitalize on this creative destruction, there needs to be a game plan that investors use to analyze and ultimately profit from this new investment theme of cryptoassets. The goal of this book is not to predict the future – it’s changing too fast for all but the lucky to be right- but rather to prepare investors for a variety of futures.

Even for 2017 when the book was publish, this statement is lagging a bit because there were already several “coin graveyard” sites around.  Late last month Bloomberg ran a story: more than 1,000 coins are dead according to Coinopsy.

It is also unclear, “that some will be big winners.”  Maybe modify this part in the next version.11

On p. xxvi they write:

“One of the keys to Graham’s book was always reminding the investor to focus on the inherent value of an investment without getting caught in the irrational behavior of the markets.”

There is a healthy debate as to whether cryptocurrencies and “cryptoassets” have any inherent value either.12  Arguably most coins traded on a secondary market depend on some level of ‘irrational’ behavior: many coin holders have short time horizons and want someone else to help push up the price so they can eventually cash out.13

Chapter 1

On p. 3 they write:

In 2008, Bitcoin rose like a phoenix from the ashes of near Wall Street collapse.

This a little bit of revisionist history.14

The Bitcoin whitepaper came out on October 31, 2008 and Satoshi later said that he/she had spent the previous 18 months coding it first before writing it up in a paper.  The authors even discuss this later on page 7.  Worth removing in next edition.

On p. 3 they write:

Meanwhile, Bitcoin provided a system of decentralized trust for value transfer, relying not on the ethics of humankind but on the cold calculation of computers and laying the foundation potentially to obviate the need for much of Wall Street.

This is not quite true.  At most, Bitcoin as it was conceived and as it is today — is a relatively expensive payment network that doesn’t provide definitive settlement finality.15 Banks as a whole, do more than just handle payments — they manage many other services and products.  So the comparison isn’t really apples-to-apples.

Note: banks again as a whole spend more on IT-related systems than nearly any other vertical — so there is already lots of “cold calculation” taking place within each of these financial institutions.16

Now, maybe blockchain-related ideas replace or enhance some of these institutions, but it is unlikely that Bitcoin itself as it exists today, will do any of that.

On p. 5 they write:

What people didn’t realize, including Wall Street executives, was how deep and interrelated the risks CMOs posed were. Part of the problem was that CMOs were complex financial instruments supported by outdated financial architecture that blended and analog systems.

That may have been part of a bigger problem.17

There were a dozen plus factors for how and why the GFC arose and evolved, but “outdated financial infrastructure” isn’t typically at the top of the list of culprits.  Would blockchain-like systems have prevented the entire crisis?  There are lots of op-eds that have made the claim, but the authors do not really provide much evidence to support the specific “blended” argument here.  Perhaps worth articulating in its own section next time.

Speaking of which, also on p. 5 they write:

Whether as an individual or an entity, what’s now clear is that Satoshi was designing a technology that if existent would have likely ameliorated the toxic opacity of CMOs. Due of the distributed transparency and immutable audit log of a blockchain, each loan issued and packaged into different CMOs could have been documented on a single blockchain.

This seems to conflate two separate things: Bitcoin as Satoshi originally designed it in 2008 (for payments) and later what many early adopters have since promoted it as: blockchain as FMI.18

Bitcoin was (purposefully) not designed to do anything with regulated financial instruments, it doesn’t meet the PFMI requirements.  He was trying to build e-cash that didn’t require KYC and was difficult to censor… not ways to audit CMOs.  If that was the goal, architecturally Bitcoin would likely look a lot different than it did (for instance, no PoW).

And lastly on p. 5 they write:

This would have allowed any purchaser to view a coherent record of CMO ownership and the status of each mortgage within.  Unfortunately, in 2008 multiple disparate systems – which were expensive and therefore poorly reconciled – held the system together by digital strings.

Interestingly, this is the general pitch for “enterprise” blockchains: that with all of the disparate siloed systems within regulated financial institutions, couldn’t reconciliation be removed if these same systems could share the same record and facts on that ledger?  Hence the creation of more than a dozen enterprise-focused “DLT” platforms now being trialed and piloted by a slew of businesses.

This is briefly discussed later but the next edition could expand on it as the platforms do not need a cryptocurrency involved.19

On p. 7 they write:

By the time he released the paper, he had already coded the entire system.  In his own words, “I had to write all the code before I could convince myself that I could solve every problem, then I wrote the paper.” Based on historical estimates, Satoshi likely started formalizing the Bitcoin concept sometime in late 2006 and started coding around May 2007.

Worth pointing out that Hal Finney and Ray Dillinger — and likely several others – helped audit the code and paper before any of it was publicly released.

On p. 8 they write:

Many years later people would realize that one of the most powerful use cases of blockchain technology was to inscribe immutable and transparent information that could never be wiped from the face of digital history and that was free for all to see.

There appears to be a little hyperbole here.

Immutability has become a nebulous word that basically means many different things to everyone.  In practice, the only thing that is “immutable” on any blockchain is the digital signature — it is a one-way hash.   All something like proof-of-work or proof-of-stake does are decide who gets to vote to append the chain.

Also, as mentioned above, there are well over 1,000 dead coins so it is actually relatively common for ‘digital history’ to effectively be wiped out.

On p. 8 they write:

A dollar invested then would be worth over $1 million by the start of 2017, underscoring the viral growth that the innovation was poised to enjoy.

Hindsight is always 20-20 and the wording above seems to be a little unclear with dates.  As often as the authors say “this is not a book endorsing investments,” other passages seem do just the opposite: by saying how smart you would’ve been if you had bought at a relative low, during certain (cherry picked) dates.

Also, what viral growth?  What are the daily active and monthly active user numbers they think are occurring on these chains?  In later chapters, they do cite some on-chain activity but this version lacks specific DAU / MAU that would strengthen their arguments.20 Worth revisiting in the next edition.

On p. 8 they write:

Diving deeper into Satoshi’s writings around the time, it becomes more apparent that he was fixated on providing an alternative financial system, if not a replacement entirely.

This isn’t quite right.  The very first thing Satoshi tried to build was a marketplace to play poker which was supposed to be integrated with the original wallet itself.

A lot of the talk about “alternative financial system” is arguably revisionist propaganda from folks like Andreas Antonopoulos who have tried to rewrite the history of Bitcoin to conform with their political ideology.

Readers should also check out MojoNation and what that team tried to accomplish.

On p. 9 they write;

While Wall Street as we knew it was experiencing an expensive death, Bitcoin’s birth cost the world nothing.

There are at least two issues that can be modified for the future:

  1.  Wall Street hasn’t died, maybe parts of the financial system are replaced or removed or enhanced, but for better and worse almost 10 years since the collapse of Lehman, the collective financial industry is still around.
  2.  Bitcoin cost somebody something, there were opportunity costs in its creation.  And as we now know: the ongoing environmental impact is enormous.  Yet promoters typically handwave it away as a “cost of doing anarchy.”  Thus worth rewording or removing in the next edition.

On p. 9 they also wrote:

It was born as an open-source technology and quickly abandoned like a motherless babe in the world. Perhaps, if the global financial system had been healthier, there would have been less of a community to support Bitcoin, which ultimately allowed it to grow into the robust and cantankerous toddler that it currently is.

This prose sounds like something from Occupy Wall Street and not something found in literature to describe a computer program.

For example, there are lots of nominally open source blockchains, hundreds or maybe even thousands.21 That’s not very unique (it is kind of expected since there is a financial incentive to clone them).

And again, Satoshi worked on it for at least a couple years.  It’s not like he/she dropped it off at an orphanage after immediate gestation.  This flowery wording acts like a distraction and should be removed in the next edition.

Chapter 2

On p. 12 they write:

Three reputable institutions would not waste their time, nor jeopardize their reputations, on a nefarious currency with no growth potential.

There is a bit of an unnecessary attitude with this statement.  The message also seems to go against the criticism earlier in the book towards banks.  For instance, the first chapter was critical of the risks that banks took leading up to the GFC.  You can’t have it both ways.  In the next edition, should either remove this or explain what level or risk is appropriate.

Also, what is the “growth potential” here?  Do the authors mean the value of a coin as measured in real money?  Or actual usage of the network?

Lastly, the statement above equates the asset value growth (USD value increases) with a bank’s interest. Bank’s do not typically speculate on the price, they usually only care about volumes which make revenues. A cryptocurrency could go to $0.01 for all they care; and if people want to use it then they could consider servicing it provided the bank sees an ability to make money.  For example, UK banks did not abandon the GBP even though it lost 20% of its value in 2016 following the Brexit referendum.

On p. 12 they write:

Certainly, some of the earliest adopters of Bitcoin were criminals. But the same goes for most revolutionary technologies, as new technologies are often useful tools for those looking to outwit the law.

This is a “whataboutism” and is actually wrong.  Satoshi specifically says he/she has designed Bitcoin to route around intermediaries (like governments) and their ability to censor.  It doesn’t take too much of a stretch to get who would be initially interested in that specific set of payment “rails” especially if there is no legal recourse.22

On p. 12 they also write:

We’ll get into the specific risks associated with cryptoassets, including BItcoin, in a later chapter, but it’s clear that the story of bitcoin as a currency has evolved beyond being solely a means of payment for illegal goods and services. Over 100 media articles have jumped at the opportunity to declare bitcoin dead, and each time they have been proven wrong.

The last sentence has nothing to do with the preceding sentence, this is a non sequitur.

Later in the book they do talk about other use cases but the one that they don’t talk about much is how — according to analytics — the majority of network traffic in 2017 was users moving cryptocurrencies from one exchange to another exchange.

For example, about a month ago, Jonathan Levin from Chainalysis did an interview and mentioned that:

So we can identify, it is quite hard to know how many people. I would say that 80% of transactions that occur on these cryptocurrency ledgers have a counterparty that is a 3rd party service. More than 80%.

Maybe mention in the second edition: the unintended ironic evolution of Bitcoin has had… where it was originally designed to route around intermediaries and instead has evolved into an expensive permissioned-on-permissionless network.23

On p. 13 they write:

It operates in a peer-to-peer manner, the same movement that has driven Uber, Airbnb, and LendingClub to be multibillion-dollar companies in their own realms. Bitcoin lets anyone be their own bank, putting control in the hands of a grassroots movement and empowering the globally unbanked.

Not quite.  For starters: Uber, Airbnb, and LendingClub all act as intermediaries to every transaction, that’s how they became multibillion-dollar companies.

Next, Bitcoin doesn’t really let anyone be their own bank because banks offer a lot more products and services beyond just payments.  At most, Bitcoin provides a way of moving bitcoins you control to someone else’s bitcoin address (wallet).  That’s it.24

And there is not much evidence that Bitcoin or any cryptocurrency for that matter, has empowered many beyond relatively wealthy people in developed or developing countries.  There have been a few feel-good stories about marginalized folks in developing countries, but those are typically (unfortunately) one-off theatrics displaying people living in squalor in order to promote a financial product (coins).  It would be good to see more evidence in the next edition.

For more on this topic, recommend listening to LTB episode 133 with Richard Boase.

On p. 13 they write:

Decentralizing a currency, without a top-down authority, requires coordinated global acceptance of a shared means of payment and store of value.

Readers should check out “arewedecentralizedyet” which illustrates that nearly all cryptourrencies in practice have some type of centralized, top-down hierarchy as of July 2018.

On p. 13 they write:

Bitcoin’s blockchain is a distributed, cryptographic, and immutal database that uses proof-of-work to keep the ecosystem in sync.

Worth modifying because the network is not inherently immutable — only digital signatures have “immutability.”25 Also, proof-of-work doesn’t keep any “ecosystem” in sync.  All proof-of-work does is determine who can append the chain.  The “ecosystem” thing is completely unrelated.

On p. 15 they write:

There is no subjectivity as to whether a transaction is confirmed in Bitcoin’s blockchain: it’s just math.

This isn’t quite true.26 Empirically, mining pools have censored transactions for various reasons.  For example, Luke-Jr (who used to run Eligius pool) thinks that SatoshiDice misuses the network; he is also not a fan of what OP_RETURN was being used for by Counterparty.

Also, humans control pools and also manage the code repositories… blockchains don’t fix and run themselves.  So it’s not as simple as: “it’s just math.”

On p. 15 they write an entire paragraph on “immutability”:

The combination of globally distributed computers that can cryptographically verify transactions and the building of Bitcoin’s blockchain leads to an immutable database, meaning the computers building Bitcoin’s blockchain can only do so in an append only fashion. Append only means that information can only be added to Bitcoin’s blockchain over time and cannot be deleted – an audit trail etched in digital granite. Once information is confirmed in Bitcoin’s blockchain, it’s permanent and cannot be erased. Immutability is a rare feature in a digital world where things can easily be erased, and it will likely become an increasingly valuable attribute for Bitcoin over time.

This seems to have a few issues:

  1. As mentioned several times before in this review, “immutability” is only a characteristic of digital signatures, which are just one piece of a blockchain.  Recommend Gwern’s article entitled “Bitcoin-is-worse-is-better” for more details.
  2. Empirically lots of blockchains have had unexpected and expected block reorgs and hard forks, there is nothing fundamental to prevent this from happening to Bitcoin.  See this recent article discussing a spate of attacks on various PoW coins: Blockchain’s Once-Feared 51% Attack Is Now Becoming Regular
  3. The paragraph above ignores the reality that well over 1,000 blockchains are basically dead and Bitcoin itself had a centralized intervention on more than one occasion, such as the accidental hardfork in 2013 and the Bitcoin block size debate from 2015-2018.

On p. 15 they introduce us to the concept of proof-of-work but don’t really explain its own origin as a means of combating spam email in the 1990s.

For instance, while several Bitcoin evangelists frequently (mistakenly) point to Hashcash as the original PoW progenitor, that claim actually legitimately goes to a 1993 paper entitled Pricing via Processing or Combatting Junk Mail by Cynthia Dwork and Moni Naor.  There are others as well, perhaps worth adding in the next edition.27

On p. 16 they write:

Competition for a financial rewad is also what keeps Bitcoin’s blockchain secure.  If any ill-motivated actors wanted to change Bitcoin’s blockchain, they would need to compete with all the other miners distributed globally who have in total invested hundreds of millions of dollars into the machinery necessary to perform PoW.

This is only true for a Maginot Line attack (e.g., attack via hashrate).28 There are  cheaper and more effective out of band attacks, like hacking BGP or DNS.  Or hacking into intermediaries such as exchanges and hosted wallets.  Sure the attacker doesn’t directly change the blocks, but they do set in motion a series of actions that inevitably result in thefts that end up in blocks further down the chain, when the transactions otherwise wouldn’t have taken place.

On p. 17 they write:

The hardware runs an operating system (OS); in the case of Bitcoin, the operating system is the open-source software that facilitates everything described earlier.  This software is developed by a volunteer group of developers, just as Linux, the operating system that underlies much of the cloud, is maintained by a volunteer group of developers.

This isn’t quite right in at least two areas:

  1. Linux is not financial market infrastructure software; Bitcoin originally attempted to be at the very least, a payments network.  There are reasons why building and maintaining FMI is regulated whereas building an operating system typically isn’t.  It has to do with risk and accountability when accidents happen.  That’s why PFMI exists.
  2. At least in the case of Bitcoin (and typically in most other cryptocurrencies), only one group of developers calls the shots via gating the BIP / EIP process.  If you don’t submit your proposals and get it approved through this process, it won’t become part of Bitcoin Core.  For more on this, see: Bitcoin Is Now Just A Ticker Symbol and Stopped Being Permissionless Years Ago

On p. 17 they discuss “private versus public blockchains”:

The difference between public and private blockchains is similar to that between the Internet and intranets.  The internet is a public resource.  Anyone can tap into it; there’s not gate keepers.

This is wrong.  All ISPs gate their customers via KYC.  Not just anyone can set up an account with an ISP, in fact, customers can and do get kicked off for violating Terms of Service.

“The Internet” is just an amalgamation of thousands of ISPs, each of whom have their own Terms of Service.  About a year ago I published an in-depth article about why this analogy is bad and should not be use: Intranets and the Internet.

On p. 18 they write:

Public systems are ones like BItcoin, where anyone with the right hardware and software can connect to the network and access the information therein.  There is no bouncer checking IDs at the door.

This is not quite right.  The “permissionless” characteristic has to do with block making: who has the right to vote on creating/adding a new block… not who has the ability to download a copy of the blockchain.  Theoretically there is no gatekeeper for block making in Bitcoin. Although, there are explicit KYC checks on the edges (primarily at exchanges).

In practice, the capital and knowledge requirements to actually create a new mining pool and aggregate hashpower that is sufficiently capable of generating the right hash and “winning” the scratch-off lottery is very high, such that on a given month just 20 or so block makers are actually involved.29

While there is no strict permissioning of these participants (some come and go over the years), it is arguably a de facto oligopoly based on capital expenditures and not some type of feel-good meritocracy described in this book.30

On p. 18 they write:

Private systems, on the other hand, employ a bouncer at the door. Only entities that have the proper permissions can become part of the network. These private systems came about after Bitcoin did, when enterprises and businesses realized they liked the utility of Bitcoin’s blockchain, but weren’t comfortable or legally allowed to be as open with he information propagated among public entities.

This is not nuanced enough.  What precisely is permissioned on a “permissioned” blockchain is: who gets to do the validation.

While there are likely dozens of “permissioned” blockchain vendors — each of which may have different characteristics — the common one is that the validators are KYC’ed participants.  That way they can be held accountable if there is a problem (like a fork).

For example, many enterprises and businesses tried to use Bitcoin, Ethereum, and other cryptocurrencies but because these blockchains were not built with their use cases in mind, unsurprisingly found that they were not a good fit.

This is not an insult: the “comfort” refrain is tiring because there have been a couple hundred proofs-of-concept on Bitcoin – and variants thereof – to look into whether those chains were fit-for-purpose… and they weren’t.  This passage should be reworded in the second edition.

On p. 18 they write:

Within financial services, these private blockchains are largely solutions by incumbents in a fight to remain incumbents.

Maybe that is the motivation of some stakeholders, but I don’t think I’ve ever been in a meeting in which the participants (banks) specifically said that.  It would be good to have a citation added in the next edition.  Otherwise, as Hitchens said: what can be presented without evidence can be dismissed without evidence.

On p. 18 they write:

While there is merit to many of these solutions, some claim the greatest revolution has been getting large and secretive entities to work together, sharing information and best practices, which will ultimately lower the cost of services to the end consumer. We believe that over time the implementation of private blockchains will erode the position held by centralized powerhouses because of the tendency toward open networks. In other words, it’s a foot in the door for further decentralization and the use of public blockchains.

This is a “proletariat” narrative that is frequently used in many cryptocurrency books.  While there is a certain truth to an angle – collaboration of regulated entities that normally compete with one another – many of the vendors and platforms that they are piloting are actually “open.”

Which brings up the euphemism that some vocal public blockchain promoters like to stake a claim in… the ill-defined “open.”  For instance, coin lobbyists such as Coin Center and coin promoters such as Andreas Antonopoulos regularly advertise that they are experts and advocates of “open” chains but their language is typically filled with strawmen.

For instance, enterprise-specific platforms such as Fabric, Corda, and Quorum are all open sourced, anyone can download and run the code without the permission of the vendors that contribute code or support to the platforms.

Thus, it could be argued that these platforms are “open” too… which they are.

But it is highly unlikely that ideological advocates would ever defend or promote these platforms, because of their disdain and aversion to platforms built by financial organizations. 31

Lastly, this “foot in the door” comment comes in all shapes and sizes; sometimes coin promoters use “Trojan horse” as well.  Either way it misses the point: enterprises will use technology that solves problems for them and will not use technology that doesn’t solve their problem.

In practice, most cryptocurrencies were not designed – on purpose – to solve problems that regulated institutions have… so it is not a surprise they do not use coin-based platforms as FMI.  It has nothing to do with the way the coin platforms are marketed and everything to do with the problems the coins solve.

On p. 19 they write:

Throughout this book, we will focus on public blockchains and their native assets, or what we will define as cryptoassets, because we believe this is where the greatest opportunity awaits the innovative investor.

The authors use the term “innovative investor” a dozen or more times in the book.  It’s not a particularly useful term.32

Either way, later in the book they don’t really discuss the opportunity cost of capital: what are the tradeoffs of an accredited investor who puts their money long term into a coin versus buys equity in a company.  Though, to be fair, part of the problem is that most of the companies that actually have equity to buy, do not publish usage or valuation numbers because they are still private… so it is hard to accurately gauge that specific trade-off.33

On p. 19 they write about Bitcoin maximalism (without calling it that):

We disagree with that exclusive worldview, as there are many other interesting consensus mechanisms being developed, such as proof-of-stake, proof-of-existence, proof-of-elapsed time, and so on.

Proof-of-existence is not a consensus mechanism.  PoE simply verifies the existence of a file at a specific time based on a hash from a specific blockchain.  It does not provide consensus.  This should be reworded in the next edition.

Furthermore, neither proof-of-stake or proof-of-elapsed-time are actual consensus mechanisms either… they are vote ordering mechanisms — a mechanism to prevent or control sybil attacks. 34  See this excellent thread from Emin Gun Sirer.

Chapter 3

On p. 22 they write:

Launched in February 2011, the Silk Road provided a rules-free decentralized marketplace for any product one could imagine, and it used bitcoin as the means of payment.

This isn’t quite true.  Certain guns and explosives were considered off-limits and as a result “The Armory” was spun off.

On p. 22 they write:

Clearly, this was one way that Bitcoin developed its dark reputation, though it’s important to know that this was not endorsed by Bitcoin and its development team.

Isn’t Bitcoin — like all cryptocurrences — supposed to be decentralized?  So how can there be a singular “it” to not endorse something?35

On p. 22 they write:

The drivers behind this bitcoin demand were more opaque than the Gawker spike, though many point to the bailout of Cyprus and the associated losses that citizens took on their bank account balances as the core driver.

This is mostly hearsay as several independent researchers have tried to identify the actual flows coming into and going out of Cyprus that are directly tied to cryptocurrencies and so far, have been unable to.36

On p. 23 they write about Google Search Trends:

We recommend orienting with this tool even beyond cryptoassets, as it’s a fascinating window into the global mesh of minds.

Incidentally, despite the authors preference to the term “cryptoassets” —  according to Google Search Trends, that term isn’t frequently used in search’s yet.

Source: Google

On p. 24 they write:

This diversity has led to tension among players as some  of these cryptoassets compete, but this is nothing like the tension that exists between Bitcoin and the second movement.

Another frequent name typically used to call “the second movement” was Bitcoin 2.0.

For example, back in 2014 and 2015 I interviewed a number of project organizers and attempted to categorize them into buckets, including things like “commodities” and “assets.”  See for instance my guest presentation in 2014 at Plug and Play: (video) (slides).

This label isn’t frequently used as much anymore, but that’s a different topic entirely.

On p. 25 they write an entire section entitled: Blockchain, Not Bitcoin

The authors stated:

Articles like one from the Bank of England in the third quarter of 2014 argued, “The key innovation of digital currencies is the ‘distributed ledger,’ which allows a payment system to operate in an entirely decentralized way, without intermediaries such as banks. In emphasizing the technology and not the native asset, the Bank of England left an open question whether the native asset was needed

[…]

The term blockchain, independent of Bitcoin, began to be used more widely in North America in the fall of 2015 when two prominent financial magazines catalyzed awareness of the concept.

Let’s pull apart the problems here.

First, the “blockchain not bitcoin” mantra was actually something that VCs such as Adam Draper pushed in the fall of 2015.

For instance, in an interview with Coindesk in October 2015 he said:

“We use the word blockchain now. I say bitcoin, and they think that’s the worst thing ever. It just feels like they put up a guard. Then, I switch to blockchain and they’re very attentive and they’re very interested.”

Draper seems ambivalent to the change, though he said he was initially against using it, mostly because he believes it’s superficial. After all, companies that use the blockchain as a payments rail, the argument goes, still need to interface with its digital currency, which is the mechanism for transactions on the bitcoin blockchain.

“When we talk about blockchain, I mean bitcoin,” Draper clarifies. “Bitcoin and the blockchain are so interspersed together, the incentive structure of blockchain is bitcoin.”

Draper believes it’s mostly a “vernacular change”, noting the ecosystem has been through several such transitions before. He rifles off the list of terms that have come and gone including cryptocurrency, digital currency and altcoin.

“It’s moved from bitcoin to blockchain, which makes sense, it’s the underlying tech of all these things,” he added. “I think in a lot of ways blockchain is FinTech, so it will become FinTech.”

If you’re looking for more specific examples of companies that began using “blockchain” as a euphemism for “bitcoin” be sure to check out my post: “The Great Pivot.”

The authors also fail to identify that there were lots of early stage vendors and entrepreneurs working in the background on educating policy makers and institutions on what the vocabulary was and how the various moving pieces worked throughout 2015.

Want evidence?

Check out my own paper covering this topic and a handful of vendors in April 2015: Consensus-as-a-service.  This paper has been cited dozens of times by a slew of academics, banks, regulators, and so forth.  And contra Draper: you don’t necessarily need a coin or token to incentivize participants to operate a blockchain.37

On p. 26 they write:

A private blockchain is typically used to expedite and make existing processes more efficient, thereby rewarding the entities that have crafted the software and maintain the computers. In other words, the value creation is in the cost savings, and the entities that own the computers enjoy these savings. The entities don’t need to get paid in a native asset as reward for their work, as is the case with public blockchains.

First, not all private blockchains are alike or commoditized.

Two, this statement is mostly true.  At least those were the initially pitches to financial institutions.  Remember the frequently cited Oliver Wyman / Santander paper from 2015?  It was about cost savings.  Since then, the story has evolved to also include revenue generation.

For more up-to-date info on the “enterprise” blockchain world, recommend reading:

On p. 26 they write:

On the other hand, for Bitcoin to incentivize a self-selecting group of global volunteers, known as miners, to deploy capital into the mining machines that validate and secure bitcoin transactions, there needs to be a native asset that can be paid out to the miners for their work. The native asset builds out support for the service from the bottom up in a truly decentralized manner.

This may have been true in January 2009 but is not true in July 2018.  There are no “volunteers” in Bitcoin mining as running farms and pools have become professionalized and scaled in industrial-sized facilities.

Also, that last sentence is also false: virtually every vertical of involvement is dominated by centralized entities (e.g., exchanges, hosted wallets, mining manufacturing, etc.).

On p. 27 they write:

Beyond questioning the need for native cryptoassets – which would naturally infuriate communities that very much value their cryptoassets – tensions also exist because public blockchain advocates believe the private blockchain movement bastardizes the ethos of blockchain technology. For example, instead of aiming to decentralize and democratize aspects of the existing financial services, Masters’s Digital Asset Holdings aims to assist existing financial services companies in adopting this new technology, thereby helping the incumbents fight back the rebels who seek to disrupt the status quo.

Ironically, virtually all major cryptocurrency exchanges now have institutional investors and/or partnerships with regulated financial institutions.38 Like it or not, but the cryptocurrency world is deep in bed with the very establishment that it likes to rail at on social media.

Also, Bitcoin again is at most a payments network and does not actually solve problems for existing financial service providers on their many other lines of business.

On p. 27 they write:

General purpose technologies are pervasive, eventually affecting all consumers and companies. They improve over time in line with the deflationary progression of technology, and most important, they are a platform upon which future innovations are built. Some of the more famous examples include steam, electricity, internal combustion engines, and information technology. We would add blockchain technology to this list. While such a claim may appear grand to some, that is the scale of the innovation before us.

If you’re not familiar with hyperbole and technology, I recommend watching and reading the PR for the Segway when it first came out.  Promoters and enthusiasts repeatedly claimed it would change the way cities are built.  Instead, it is used as a toy vehicle to shuffle tourists around at national parks and patrol suburban malls.

Maybe something related to “blockchains” is integrated into various types of infrastructure (such as trade finance), but the next edition should provide proof of some actual user adoption.

For example, the authors in the following paragraph say that “public blockchains beyond Bitcoin that are growing like gangbusters.”

Which ones?  In the approximately 9 months since this book was published, most “traction” has been issuing ICOs on these public blockchains.  Currently the top 3 Dapps at the time of this writings, run decentralized exchanges… which trade ICO tokens.  Now maybe that changes, that is totally within the realm of possibility.39  But let’s take the hype down a few notches until consistent measurable user growth is observed.

On p. 28 they write:

The realm of public blockchains and their native assets is most relevant to the innovative investor, as private blockchains have not yielded an entirely new asset class that is investable to the public.

The wording and attitude should be changed for the next edition.  This makes it sound as if the only real innovation that exists are network-based coins that a group of issuers continually create and that you, the reader, should buy.

By downplaying opportunities being tackled by enterprise vendors, the statement glosses over the operating environment enterprise clients reside in and how they must conduct unsexy due diligence and mundane requirements gathering because they have to follow laws and regulations otherwise their customers won’t use their specific platforms.

These same vendors could end up “tokenizing” existing financial instruments, it just takes a lot longer because there are real legal consequences if something breaks or forks.40

On p. 28 and 29 they ask “where is blockchain technology in the hype cycle.”

This section could be strengthened by revisiting and reflecting on the huge expectations that these coin projects have raised and were raising at the time the book was first being written.  How were expectations eventually managed?

Specifically, on p. 29 they write:

While it’s hard to predict where blockchain technology currently falls on Gartner’s Hype Cycle (these things are always easier in retrospect), we would posit that Bitcoin is emerging from the Trough of Disillusionment. At the same time, blockchain technology stripped of native assets (private blockchain) is descending from the Peak of Inflated Expectations, which it reached in the summer of 2016 just before The DAO hack occurred (which we will discuss in detail in Chapter 5).

The first part is probably wrong if measured by actual usage and interest (as shown by the Google Search image a few sections above).41

The second part of the paragraph is probably right, though the timing was probably a little later: likely in the last quarter of 2016 when the first set of pilots turned out to require substantially larger budgets.  That is to say, in order to be put platforms into production most small vendors with short runways realized they needed more capital and time to integrate solutions into legacy systems.  In some cases, that was too much work and a few vendors pivoted out of enterprise and created a coin or two instead.42

Chapter 4

On p. 31 they write:

Yes, the numbers have changed a lot since.  Crypto moves fast.

This isn’t a hill I want to die on, but historically “crypto” means cryptography.  Calling cryptocurrencies “crypto” is basically slang, but maybe that’s the way it evolves towards.

On p. 32 they write:

Historically, crypotassets have most commonly been referred to as cryptocurrencies, which we think confuses new users and constrains the conversation on the future of these assets. We would not classify the majority of cryptoassets as currencies, but rather most are either digital commodities (cryptocommodities), provisioning raw digital resources, or digital tokens (cryptotokens), provisioning finished digital goods and services.

They have a point but a literature review could have been helpful at showing this categorization is neither new nor novel.

For instance, the title of my last book was: The Anatomy of a Money-like Informational Commodity.  A bit long-winded?

Where did I come up with that odd title?

In 2014, an academic paper was published that attempted to categorize Bitcoin from an ontological perspective. Based on the thought process presented in that paper, the Dutch authors concluded that Bitcoin is a money-like informational commodity.  It isn’t money and isn’t a currency (e.g., isn’t actually used).434445

On p. 32 they write:

In an increasingly digital world, it only makes sense that we have digital commodities, such as computer power, storage capacity, and network bandwidth.

This book only superficially explains each of these and doesn’t drill down into why these “digital commodities” can’t be priced in good old fashioned money or why an internet coin is needed.  If this is a good use case, is it just a matter of time before Blizzard and Steam get on board?  Maybe worth looking at what entertainment companies do for the next edition.

On p. 33 they write about “why crypto” as shorthand for “cryptoassets” instead of “cryptography.”

For historical purposes, Matt Blaze, the most recent owner of crypto.com, provides a good explanation that could be included or cited next edition: Exhaustive Search Has Moved.

On p. 35 they write:

Except for Karma, the problem with all these attempts at digital money was that they weren’t purely decentralized — one way or another they relied on a centralized entity, and that presented the opportunity for corruption and weak points for attack.

This seems to be conflating two separate things: anonymity with electronic cash.  You can have one without the other and do.46

Also, the BIP process is arguably a weak point for attack.47

On p. 35 they write:

One of the most miraculous aspects of bitcoin is how it bootstrapped support in a decentralized manner.

The fundamental problem with this statement is that it is inaccurate.48 Large amounts of centralization continues to exist: mining, exchanges, BIP vetting, etc.

On p. 35 they write:

Together, the combination of current use cases and investors buying bitcoin based on the expectation for even greater future use cases creates market demand for bitcoin.

Is that a Freudian slip?

Speculators buy bitcoin because they think can sell bitcoins at a higher price because a new buyer will come in at a later date and acquire the coins from them.49

For example, last month Hyun Song Shin, the BIS’s economic adviser and head of research, said:

“If people pay to hold the tokens for financial gain, then arguably they should be treated as a security and come under the same rigorous documentation requirements and regulation as other securities offered to investors for a return.”

In the United States, recall that one condition for what a security is under the Howey framework is an expectation of profit.

Whether Bitcoin is a security or not is a topic for a different post.50

On p. 36 they write:

For the first four years of Bitcoin’s life, a coinbase transaction would issue 50 bitcoin to the lucky miner.

[…]

On November 28, 2012, the first halving of the block reward from 50 bitcoin to 25 bitcoin happened, and the second halving from 25 bitcoin to 12.5 bitcoin occurred on July 9, 2016.  The thrid will happen four years from that date, in July 2020. Thus far, this has made bitcoin’s supply schedule look somewhat linear, as shown in Figure 4.1.

Technically incorrect because of the inhomogeneous Poisson process and the relatively large amounts of hashrate that came online, the first “4 year epoch” was actually less than 4 years.

Whereas the genesis block was released in January 2009, the first halving should have occurred in January 2013, but instead it took place in November 2012.  Similarly, the second halving should have — if rigidly followed — taken place in November 2016, but actually occurred in July 2016 because even more hashrate had effectively accelerated block creation a bit faster than expected.

On p. 36 they write:

Based on our evolutionary past, a key driver for humans to recognize something as valuable is its scarcity. Satoshi knew that he couldn’t issue bitcoin at a rate of 2.6 million per year forever, because it would end up with no scarcity value.

This is a non sequitur.51

Maybe Satoshi did or did not think this way, but irrespective of his or her view, having a finite amount of something means there is some amount of scarcity… even if it is a relatively large amount.  Now this discussion obviously leads down the ideological road of maximalism which we don’t have time to go into today.52  Suffice to say that bitcoin is fundamentally not scarce due to its inability to prevent forks that could increase or decrease the money supply.

On p. 37 they write:

Long term, the thinking is that bitcoin will become so entrenched within the global economy that new bitcoin will not need to be issued to continue to gain support. At that point, miners will be compesnated for processing transaction and securing the network through fees on high transaction volumes.

This might happen but hasn’t yet.

For instance, Kerem Kaskaloglu (see p. 71) created a cartoon model to show what this should look like.

But the actual curves do not exist (yet).

Recommended reading: Analysing Costs & Benefits of Public Blockchains (with Data!) by Colin Platt.

Notice how reality doesn’t stack up to the idealized version (yet)?

On p. 39 they write about BitDNS, Namecoin, and NameID:

Namecoin acts as its own DNS service, and provides users with more control and privacy.

In the next edition they should mention how Namecoin ended up having one mining pool that consistently had over 51% of the network hashrate and as a result, projects like Onename moved over to Bitcoin and then eventually its own separate network altogether (Blockstack).

On p. 41 they write:

This is an important lesson, because all cryptocurrencies differ in their supply schedules, and thus the direct price of each cryptoasset should not be compared if trying to ascertain the appreciation potential of the asset.

One way to strengthen this section is to provide a consistent model or methodology to systemically value a coin that doesn’t necessarily involve future demand from new investors.  Maybe in the second edition they could provide a way to compare or at least say that no valuation model works yet, but here is a possible alternative?

On p. 42 they write:

A word to the wise for the innovative investor: with a new cryptocurrency, it’s always important to understand how it’s being distributed and to whom (we’ll discuss further in Chapter 12). If the core community feels the distribution is unfair, that may forever plague the growth of the cryptocurrency.

Two things:

  1. If a cryptocurrency or “cryptoasset” is supposed to be decentralized, how can it have a singular “core” community too?
  2. In practice, most retail buyers of coins don’t seem to care about centralization or even coin distribution.  Later in the book they mention Dash and its rapid coin creation done in the first month.  Few investors seem to care. 53

On p. 42 they write:

Ripple has since pivoted away from being a transaction mechanism for the common person and instead now “enables banks to send real-time international payments across network.” This focus plays to Ripple’s strengths, as it aims to be a speedy payment system that rethinks correspondent banking but still requires some trust, for which banks are well suited.

If readers have time, I recommend looking through the marketing material of OpenCoin, Ripple Labs, and Ripple from 2013-2018 because it has changed several times.54 Currently there are a couple of different products including xRapid and xCurrent which are aimed at different types of users and as a result, the passage above should be updated.

On p. 43 they write:

Markus used Litecoin’s code to derive Dogecoin, thereby making it one more degree of separation removed from Bitcoin.

This is incorrect.  Dogecoin was first based off of Luckycoin and Luckycoin was based on a fork of Litecoin.  The key difference involved the erratic, random block reward sizes.

On p. 45 they write about Auroracoin.

Auroracoin is a cautionary tale for both investors and developers. What began as a seemingly powerful and compelling use case for a cryptoasset suffered from its inability to provide value to the audience it sought to impact. Incelanders were given a cryptocurrency with little education and means to use it. Unsurprisingly, the value of the asset collapsed and most considered it dead. Nevertheless, cryptocurrencies rarely die entirely, and Auroracoin may have interesting times ahead if its developer team can figure out a way forward.

A few problems:

  1. Auroracoin is still basically dead
  2. Over 1,000 other coins have died, so “rarely” should be changed in the next edition
  3. Why does a decentralized cryptocurrency have a singular development team, isn’t that centralization?

On p. 46 they write:

Meanwhile, Zcash uses some of the most bleeding-edge cryptography in the world, but it is one of the youngest cryptoassets in the book and suitable only for the most experienced cryptoasset investors.

In the next edition it would be helpful to specifically detail what makes someone an experienced “cryptoasset” investor.

On p. 46 they write:

Adam Back is considered the inspiration for Satoshi’s proof-of-work algorithm and is president of Blockstream, one of the most important companies in the Bitcoin space.

While Hashcash was cited in the original Satoshi whitepaper, recall above, that the original idea can be directly linked to a 1993 paper entitled Pricing via Processing or Combatting Junk Mail by Cynthia Dwork and Moni Naor.  Also, it is debatable whether or not Blockstream is an important company, but that’s a different discussion altogether.

On p. 46 they write:

Bitcoin and the permissionless blockchain movement was founded on principles of egalitarian transparency, so premines are widely frowned upon.

What are the founding principles?  Where can we find them?   Maybe it exists, but at least provide a footnote.55

On p. 47 they write:

While many are suspicious of such privacy, it should be noted that it has tremendous benefits for fungibility.  Fungibility refers to the fact that any unit of currency is as valuable as another unit of equal denomination.

Cryptocurrencies such as Bitcoin are not fungible.  Be sure to listen to this interview with Jonathan Levin from May.  See also: Bitcoin’s lien problem and also nemo dat.

On p. 48 they write:

Monero’s supply schedule is a hybrid of Litecoin and Dogecoin. For monero, a new block is appended to its blockchain every 2 minutes, similar to Litecoin’s 2.5 minutes.

In the next edition I’d tighten the language a little because a new monero block is added roughly or approximately every 2 minutes, not exactly 2 minutes.

On p. 48 they write:

By the end of 2016, Monero had the fifth largest network value of any cryptocurrency and was the top performing digital currency in 2016, with a price increase over the year of 2,760 percent. This clearly demonstrates the level of interest in privacy protecting cryptocurrency. Some of that interest, no doubt, comes from less than savory sources.

That is a non sequitur.

Where are the surveys of actual Monero purchasers during this time frame and their opinions for why they bought it? 56

For instance, in looking at the two-year chart above, how much on-chain activity in 2016 was due to speculators interest in “privacy” versus coin flipping?  It is impossible to tell.  Even with analytics all you will be able to is link specific users with purchases.  Intent and motivation would require  surveys and subpoenas; worth adding if available in the next edition.

On p. 48 they write:

Another cryptocurrency targeting privacy and fungiblity is Dash.

Is Dash really fungible though?  That isn’t explored in this section.  Plus Dash has a CEO… how is that decentralized?

On p. 49 they write:

In fact, Duffield easily could have relaunched Dash, especially considering the network was only days old when the instamine began to be widely talked about, but he chose not to.  It would have been unusual to relaunch, given that other cyrptocurrencies have done so via the forking of original code. The creators of Monero, for example, specifically chose not to continue building off Bytecoin because the premine distribution had been perceived as unfair.

How is this not problematic: for a “decentralized” cryptocurrency to be controlled and run by one person who can unilaterally stop and restart a chain?

It actually is common, that’s the confusing part.  Why have regulators such as FinCEN and the SEC not provided specific guidance (or enforcement) on the fact that one or a handful of individuals actually are unlicensed / non-exempted administrators of financial networks?

On p. 49 they write:

The Bitcoin and blockchain community has always been excited by new developments in anonymity and privacy, but Zcash took that excitement to a new level, which upon issuance drove the price through the roof.

Putting aside the irrational exuberance for Zcash itself, why do the authors think so many folks are vocal about privacy and anonymity?

Could it be that a significant portion of the coins are held by thieves of exchanges and hosted wallets who want to launder them?  Here are a few recent examples:

On p. 49 they write:

Through his time at DigiCash and longstanding involvement in cryptography and cryptoassets, Zooko has become one of the most respected members in the community.

Let’s put aside Zooko and Zcash.  The phrase, “the community” frequently appears in this book and similar books.  It is an opaque, ill-defined (and cliquish) term that is frequently used by coin promoters to shun certain people that do not promote specific policies (and coins).57  It’s a term that should be clearly defined in the next edition.

On p. 50 they write:

While it is still early days for Zcash, we are of the belief that the ethics and technology chops of Zooko and his team are top-tier, implying that good things lie in wait for this budding cryptocurrency.

The statement above seems like an endorsement.  Did either of the authors own Zcash just as the book came out?  And what are the specific ethics they speak of?  And why do the authors call it a cryptocurrency instead of a “cryptoasset”?

Chapter 5

On p. 51 they write:

For example, the largest cryptocommodity, Ethereum, is a decentralized world computer upon which globally accessible and uncensored applications can be built.

How is it a commodity?  Maybe it is and while they use a lot of words in this chapter, they never really precisely why it is in a way that makes much sense.  Recommend modifying the first few pages of this chapter.

On p. 52 they write about “smart contracts” and mention Nick Szabo.

For a future edition I recommend diving deeper into the different uses and definitions of smart contracts.  Also could be worth following Tony Arcieri suggestion:

I really like “authorization programs” but people really seem married to the “smart contract” terminology. Never mind Martin Abadi’s work on authorization languages (e.g. Binder) predates Nick Szabo’s “smart contracts” by half a decade…

For instance, there has been a lot of work done via the Accord Project with Clause.io and others such as IBM and R3.  Also worth looking into Barclay’s and UCL’s effort with the Smart Contract Templates.  A second edition that aims to be up-to-date should look at these developments and how they have evolved from what Abadi and Szabo first proposed.

On p. 53 they mentioned that Counterparty “was launched in January 2014.”  Technically that is not true.  The fundraising (“proof-of-burn”) took place in January and it was the following month that it “launched.”

On p. 54 they write:

The reason Bitcoin developers haven’t added extra functionality and flexibility directly into its software is that they have prioritized security over complexity. The more complex transactions become, the more vectors there are to exploit and attack these transactions, which can affect the network as a whole. With a focus on being a decentralized currency, Bitcoin developers have decided bitcoin transactions don’t need all the bells and whistles.

This is kind of true but also misses a little history.

For instance, Zerocoin was first proposed as an enhancement directly built into Bitcoin but key, influential Bitcoin developers who maintained the repository, pushed back on that for various technological and philosophical reasons.  As a result, the main authors of that proposal went on to form and launch Zcash.58

On p. 56 they write:

Buterin understood that building a system from the ground up required a significant amount of work, and his announcement in January 2014 involved the collaboration of a community of more than 15 developers and dozens of community members that had already bought into the idea.

I assume the authors mean, following the Bitcoin Miami announcement in January 2014, but they don’t really say.  I’m not sure how they arrive at the specific headcount numbers they did above, would be good to add a footnote in the future.

On p. 56 they write:

The ensuing development of the Bitcoin software before launch mostly involved just two people, Satoshi and Hal Finney.

This assumes that Satoshi is not Hal Finney, maybe he was.  But it should also include the contributions of Ray Dillinger and others.

On p. 56 they write:

Buterin also knew that while Ethereum could run on ether, the people who designed it couldn’t, and Ethereum was still over a year away from being ready for release. So he found funding through the prestigious Thiel Fellowship.

This is inaccurate.

After reading this, I reached out to Vitalik Buterin and he said:59

That’s totally incorrect. Like the $100k made very little difference.

So that should be corrected in the next version.

On p. 57 they write:

Ethereum democratized that process beyond VCs. For perspective on the price of ether in this crowdsale, consider that at the start of April 2017, ether was worth $50 per unit, implying returns over 160x in under three years. Just over 9,000 people bought ether during the presale, placing the average initial investment at $2,000, which has since grown to over $320,000.

There are a few issues with this:

  1. Ethereum did a small private and a larger public sale.  We do have the Terms and Conditions of the public sale but we do not know how many participated in the private sale and under what terms (perhaps the T&Cs were identical).
  2. Over the past 12 months there has been a trend for the “top shelf” ICOs to eschew a public sale (like Ethereum did) and instead, conduct private placement offerings with a few dozen participants at most… typically VCs and HNWIs.
  3. There are lots of dead ICOs.  One recent study found that, “56% of crypto startups that raise money through token sales die within four months of their initial coin offerings.”  Ethereum is definitely an exception to that and should be highlighted as such.

On p. 57 they write:

The extra allocation of 12 million ether for the early contributors and Ethereum Foundation has proved problematic for Ethereum over time, as some feel it represented double dipping. In our view, with 15 talented developers involved prior to the public sale, 6 million ether translated to just  north of $100,000 per developer at the presale rate, which is reasonable given the market rate of such software developers.

Who are these 15 developers, why is that the number the authors have identified?

Also, how much should FOSS developers be compensated and/or the business model around that is a topic that isn’t really addressed at all in this book, yet it is a glaring omission since virtually all of the projects they talk about are set up around funding and maintaining a FOSS team(s).  Maybe some findings will be available for the next version.

On p. 57 they write:

That said, the allocation of capital into founders’ pockets is an important aspect of crowdsales. Called a “founder’s reward,” the key distinction between understandable and a red flag is that founders should be focused on building and growing the network, not fattening their pockets at the expense of investors.

Because coins do not typically provide coin holders any type of voting rights, it is legally dubious how you can hold issuers and “founders” accountable.60

That is why, as mentioned above, there has been an evolution of terms and conditions such that early investors in a private placement for coins may have certain rights and that the founders have certain duties that are all legally enforceable (in theory).

Because no one is publishing these T&Cs, it is hard to comment on what are globally accepted practices… aside from allowing early investors liquidity on secondary markets where they can quickly dump coins.61

Without the ability to legally hold “founders” accountable for enriching themselves at the expense of the project(s), the an interim solution has been to get on social media and yell alot… which is really unprofessional and hit or miss.  Another solution is class action lawsuits, but that’s a different topic.

Also, I put the “founders” into quotes because these seem to be administrators of a network, maybe in the next edition they will be described as such?

On p. 58 they write:

Everyone trusts the system because it runs in the open and is automated by code.

There is lots of different types of open source code that runs on systems that are automated.  For instance, the entire Linux, Apache, and Mozilla worlds predate Bitcoin.  That isn’t new here.62

Also, as mentioned in the previous chapter: Researchers: Last Year’s ICOs Had Five Security Vulnerabilities on Average.  As a result, this has led to the loss of nearly $400 million in ICO funds.

Readers and investors shouldn’t just trust code because someone created a GitHub repo and said their blockchain is open and automated.63

On p. 59 they write:

Most cryptotokens are not supported by their own blockchain.

This is actually true and problematic because it creates centralization risks and the ability for one party to unilaterally censor transactions and/or act as administrators.

For instance, a few days ago, Bancor had a bug that was exploited and about $13.5 million in ETH were stolen… and Bancor was able to freeze the BNT.  That’s because BNT is effectively a centrally administered ERC20 token on top of Ethereum.

Ignoring for the moment whether or not BNT is or is not a security, this is not the first time such issuance and centralization has occurred.  See the colored coin mania from 2014-2015.

On p. 60 they write about The DAO:

Over time, investors in these projects would be rewarded through dividends or appreciation of the service provided.

They mention regulators briefly later on – about SEC views – but most of the content surrounding crowdsales was non-critical and borderline promotional.64  Might be worth adding more meat around this in the next edition.

On p. 61 they write about The DAO:

The hack had nothing to do with an exchange, as had been the case with Mt. Gox and other widely publicized Bitcoin-related hacks. Insted, the flaw existed in the software of The DAO.

Is it really possible to call it a “flaw” or “hack” and not a feature?  See also: “Code is not law” as well as “Cracking MtGox.”

On p. 61 they write:

However, a hard fork would run counter to what many in the Bitcoin and Ethereum communities felt was the power of a decentralized ledger.  Forcefully removing funds from an account violated the concept of immutability.

Just a few pages earlier the authors were saying that the lead developer behind Dash should have restarted the network because that was common and now they’re saying that doing a block reorg is no bueno.  Which is it?

Why should the reader care what a nebulously defined “community” says, if it is is not defined?

The reason we have codes of conduct, terms of service, and EULAs is to specifically answer these types of problems when they arise.

Since public blockchains are supposed to be anarchic, the lack of formal governance is supposed to be a feature, right?   That’s a whole other topic but suffice to say that these two sentences should be reworded in the next edition to incorporate the wisdom found in the Lexicon paper.

On p. 62 they write:

Many complained of moral hazard, and that this would set a precdent for the U.S. government or other powerful entities to come in someday and demand the same of Ethereum for their own interests. It was a tough decision for all involved, including Buterin, who while not directly on The DAO developer team, was an admistrator.

This is the first and only time they point out that key participants collectively making governance decisions are administrators… a point I have been highlighting throughout this review.

I don’t think it is fair to label Vitalik Buterin as a singular administrator, because if he was, he wouldn’t have had to ask exchanges to stop trading ether and/or The DAO token.  Perhaps he was collectively involved in that process, but mining pool operators and exchange managers are arguably just as important if not more so.  See also: Sufficiently Decentralized Howeycoins

On p. 62 they write:

While hard fork are often used to upgrade a blockchain architecture, they are typically employed in situations where the community agrees entirely on the beneficial updates to the architecture. Ethereum’s situation was different, as many in the community opposed a hard fork. Contentious hard forks are dangerous, because when new software updates are released for a blockchain in the form of a hard fork, there are then two different operating systems.

A few things:

  1. Notice the continued use of an ill-defined “the community”
  2. How is agreement or disagreement measured?  During the Bitcoin block size debate, folks tried to use various means to express interest, most of which resulted in sybil attacks such as retweets and upvotes on social media by an army of bots.
  3. Is any fork non-contentious.  Surely if we looked hard enough, we could always find more than a handful of coin owners and/or developers that disagreed with the proposal.  Does that mean you should ignore them?  Whose opinion matters?  These types of questions were never really formally answered either in the case of the Bitcoin Segwit / Bitcoin Cash fork… or in the Ethereum / Ethereum Classic / The DAO fork.  Governance is pretty much an off-chain popularity contest, just like voting for politicians.65

On p. 63 they write:

The site for Ethereum Classic defines the cryptoasset as “a continuation of the original Ethereum blockchain–the classic version preserving untampered history; free from external interference and subjecitve tampering of transactions.”

This could be revised since Ethereum Classic itself has now had multiple forks.

As mentioned in a previous post last year:

Ethereum Classic: this small community has held public events to discuss how they plan to change the money supply; they video taped this coordination and their real legal names are used; only one large company (DCG) is active in its leadership; they sponsor events; they run various social media accounts

There has been lots of external interference, that’s been the lifeblood of public blockchains… because they don’t run themselves, people run and administer them.

Continuing on p. 63 they write:

While many merchants understably complain about credit card fees of 2 to 3 percent, the “platform fees” of Airbnb, Uber, and similar platform services are borderline egregious.

Maybe they are, maybe they are not.66 What is the right fee they should be?  Miners take a cut, exchanges take a cut, developers take a cut via “founder’s funds.”

The next edition should give a step-by-step comparison to show why fee structures are egregious (maybe they are, it just is not clear in this book).

On p. 64 they wrote about Augur.  Incidentally, Augur finally launched in early July while writing this review.  I have an origin story but will keep that for later.

On p. 65 they wrote about Filecoin:

For example, a dApp may use a decentralized cloud storage system like Filecoin to store large amounts of data, and another cryptocommodity for anonymized bandwidth, in addition to using Ethereum to process certain operations.

A couple thoughts:

  1. That’s the theory, though Filecoin hasn’t launched yet — why do they get the benefit of the doubt yet other projects don’t?
  2. There is no price or use comparison in this chapter or elsewhere… the book could be strengthened if it provided more evidence of adoption because we have seen that running decentralized services such as Tor or Freenet have been less than spectacular.

On p. 65 they write:

Returning to the fundamentals of investment theory will allow innovative investors to properly position their overarching portfolio to take advantage of the growth of cryptoassets responsibly.

It is still unclear what an “innovative investor” is — at least the way these authors describe it.67

Chapter 6

On p. 69 Tatar writes:

Not only did I decide to inveset in bitcoin, I decided to place the entirety of that year’s allocation for my Simplified Employee Pension (SEP) plan into bitcoin. When I announced what I had done in my article “Do Bitcoin Belong in your Retirement Portfolio?,” it created a stir online and in the financial planning community.

This was one of just a couple places where the authors actually disclose that they own specific coins, next edition they should put it up front.

On p. 70 Tatar writes:

Was I chasing a similar crash-and-burn scenario with bitcoin? Even my technologically and investment savvy son, Eric, initially criticized me about bitcoin. “They have these things called dollar bills, Dad. Stick to using those.”

Eric is probably right: that the authors of this book accepted traditional money for their book (Amazon doesn’t currently accept cryptocurrencies).

Based on their views presented in this book, the authors probably don’t spend (many) coins they may have in the portfolio, instead holding on to them with the belief that other investors will bid up the price (measured in actual money).

On p. 77 they write about the GFC prior to 2008:

Becoming a hedge fund manager became all the rage for business-minded students when it was revealed that the top 25 hedge fund managers earned a total of $22.3 billion in 2007 and $11.6 billion in 2008.

Coincidentally a similar “rage” for running cryptocurrency-related funds has occured in the past 18 months, especially for ICOs.

More than two hundred “funds” quickly popped up in order to gobble up coins during coin mania.  At least 9 have closed down through April and many more were down double digits due to a bear market (and not hedging).

Chapter 7

On p. 83 they write:

Bitcoin is the most exciting alternative asset in the twenty-first century, and it has paved the way for its digital siblings to enjoy similar success.

It is their opinion that this is the case, but the authors don’t really provide a lot of data to reinforce it yet, other than the fact that there have been some bull runs due to exuberance.68 Worth rewording in the next edition.

On p. 83 they write:

Because bitcoin can claim the title of being the oldest cryptoasset…

Historically it is not.  It may be the oldest coin listed on a liquid secondary market, but there were cryptocurrencies before bitcoin.

On p. 85 Berniske writes:

Similarly, I (Chris) didn’t even consider investing in bitcoin when I first heard about it in 2012. By the time I began considering bitcoin for my portfolio in late 2014, the price was in the mid $300s, having increased 460,000-fold from the initial exchange rate.

I believe this is the only time in the book that Burniske discloses any coin holdings.

On p. 85 they make some ridiculous comparison with the S&P 500, DJIA, NASDAQ 100… and Bitcoin.

The former three are indices of multiple regulated securities.  The latter is just one coin that is easily influenced and manipulated by external unaccountable parties.  How is that an apples to apples comparison?

On p. 87 they continue by comparing Bitcoin with Facebook, Google, Amazon, and Netflix.

Again, these are regulated securities that reflect cash flows and the financial health of multinational companies… Bitcoin has no cash flows and isn’t (yet) setup to be a company… and isn’t regulated (no KYC/AML at the mining farm or mining pool level).

Bitcoin was originally built to be an e-cash transmission network, a decentralized MSB.69 How is comparing it with non-MSBs a useful comparison?

On p. 88 they write:

Remember that, as of January 2017, bitcoin’s network value was 1/20, 1/22, 1/3, and 1/33 that of the FANG stocks respectively. Therefore, if bitcoin is to grow to a similar size much opportunity remains.

This whole section should be probably be modified because these aren’t apples-to-apples comparisons.  FANG stocks represent companies that have to build and ship multiple products in order to generate continuous revenue.

With Bitcoin, it is bitcoin that is the product, nothing else is being shipped nor is revenue being generated70

Maybe the price of a bitcoin — as measured with actual money — does reach a 1:1 or even surpass the stocks above.  But a new version of this book could be strengthened with an outline on how it could do so sustainably.

Also, the whole “market cap” topic should be removed from next edition as well.  About 20% of all bitcoins have been lost or destroyed and this is never reflected in those exuberant “market cap” stories.  See: Nearly 4 Million Bitcoins Lost Forever, New Study Says

On p. 92 they write about volatility:

Upon launch, cryptoassest tend to be extremely volatile because they are thinly traded markets.

Actually, basically all cryptocurrencies including the ones that the authors endorse throughout the book — are still very volatile.

Below is one illustration:

Source: JP Koning

The authors do have a couple narrow, daily volatility charts in the book, but none that provide a similar wideview comparison with something that is remotely comparable (Bitcoin versus Twitter doesn’t make any sense).

On p. 101 they write:

Cryptoassets have near-zero correlation to other captial market assets.

That’s loosey goosey at best.71

For instance, as pointed out in multiple articles this year: Bitcoin and other cryptocurrencies tend to be locked together – and that’s a big problem

On p. 102 they write:

In contrast, the past few years have been more nuanced: bitcoin’s volatily has calmed, yet it retains a low correlation with other assets.

That first part is untrue, as shown by the chart above from JP Koning.  The second part is relative.72

Chapter 8

On p. 107 they write:

The Securities and Exchange Commission has thus far steered clear of applying a specific label to all cryptoassets, though in late July 2017 it did release a report detailing how some cryptoassets can be classified as securities, with the most notable example being The DAO.

That’s pretty much the extent of the authors analysis of the issue.  Granted they aren’t lawyers but this is a pretty big deal, maybe in the next edition beef this up?

On p. 107 they write:

While it’s a great validation of cryptoassets that regulators are working to provide clarity on how to classify at least some of them, most of the existing laws set forth suffer from the same flaw: agencies are interpereting cryptoassets through the lens of the past.

From this wording it seems that the authors want laws changed or modified to protect their interests and the financial interests of their LPs.  This isn’t the first or last time that someone with a vested interest lobbies to get carve outs, exceptions, or entire moratoriums.

Maybe that it is deserved, but it’s not well-articulated in this chapter other than to basically call regulators “old-fashioned” and out of touch with technology.73 Could be worth rethinking the wording here.

On p. 107 they write:

Just as there is diversity in equities, with analsts segmenting companies depending on their market capitalization, sector, or geography, so too is there diversity in cryptoassets. Bitcoin, litecoin, monero, dash, and zcash fulfill the three definitions of a currency: serving as a means of exchange, store of value and unit of account.

This is empirically incorrect.  None of these coins functions as a unit of account, they all depend on and are priced in… actual money.74

There are lots of reasons for why this is case but that is beyond the scope of this review. 7576

On p. 110 they write about ETFs:

It should be noted that when we talk about asset classes we are not doing so in the context of the investment vehicle that may “house” the underlying asset, whether that vehicle is a mutual fund, ETF, or separately managed account.

They don’t really discuss it in the book, but just so readers are aware, there have been about 10 Bitcoin-only ETFs proposed in the US, all of which have been rejected by the SEC (or applications were voluntarily removed).

Curious to know why?  See the March 10, 2017 explanation from the SEC.

Note: this hasn’t stopped sponsors from re-applying.  In the process of writing this review, the CBOE filed for a Bitcoin ETF.

On p. 111 they write:

Much of the thinking in this chapter grew out of a collaboration between ARK Invest and Coinbase through late 2015 and into 2016 when the two firms first made the claims that bitcoin was ringing the bell for a new asset class.

Just to be clear: the joint paper they published in that time frame was a bit superficial as it lacked actual user data from Coinbase exchanges (both GDAX and the consumer wallet).  I pointed that out back then and this book is basically an expanded form of that paper: where is specific usage data on Coinbase?  The only way we have learned any real user numbers about Coinbase is from an IRS lawsuit.

For instance, a future edition should try to differentiate on-chain activity that is say, gambling winnings or miners payouts from exchange arbitrage or even coin shuffling.  Their analysis should be redone once they remove the noise from the signal (e.g., not all transactional activity is the same).

This is a real challenge and not a new issue.  For instance, see: Slicing data.

On p. 112 they write:

Cryptoassets adhere to a twenty-first century model of governance unique from all other asset classes and largely inspired by the open source software movement. The procurers of the asset and associated use cases are three pronged. First, a group of talented software developers decide to create the blockchain protocol or distributed application that utilizes a native asset. These developers adhere to an open contributor model, which means that over time any new developer can earn his or her way onto the development team through merit.

There is no new governance model.

In practice, changes are done via social media popularity contests.  We saw that with the Bitcoin blocksize debate and Ethereum hard fork.  And in some ways, strong vocal personalities (and cults of personality) is how other FOSS projects (like Python) are managed and administered.

The fluffy meritocracy feel-goodism is often not the order of the day and we see this in many projects such as Bitcoin where the commit access and BIP approval process is limited to a small insular clique.

Source: Jake Smith (section 3)

The 4 point plan above is a much more accurate break down of how most coin projects are setup.

On p. 112 they write:

However, the developers are not the only ones in charge of procuring a cryptoasset; they only provide the code. The people who own and maintain the computers that run the code–the-miners–also have a say in the development of the code because they have to download new software updates. The developers can’t force miners to update software. Instead, they must convince them that it makes sense for the health of the overall blockchain, and the economic health of the miner, to do so.

But in many projects: developers and miners are one in the same.  This is why it is so confusing to not have seen additional clarity or guidance from FinCEN because of how centralized most projects are in practice.

Be sure to look at “arewedecentralizedyet.”77

On p. 113 they write:

These companies often employ some of the core developers, but even if they don’t, they can assert significant influence over the system if they are a large force behind user adoption.

Maybe that is the case for some cryptocurrencies.78  Should “core” developers be licensed like professional engineers are?

Also, isn’t their statement above evidence that most projects are fairly centralized because the division of labor results in specialization?

On p. 113 they write:

These users are constantly providing feedback to the developers, miners, and companies, in whose interest it is to listen, because if users stop using the cryptoasset, then demand will go down and so too will the price.  Therefore, the procurers are constantly held accountable by the users.

Except this isn’t what happens in practice.

Relatively little activity takes place at all on most of these coin platforms and most of what does occur involves arbitrage trading and/or illicit activity.

This activity seems to have little direct connection to the price of the coin because the price of the coin is still largely determined by the whims of speculative demand.

For instance, above is a two-year transactional volume chart for bitcoin.  The price of bitcoin in the summer of 2016 was in the $600-$700 range whereas it is 10x that today.  Yet daily transaction volume is actually lower than it was back then.  Which means: the two are separate phenomenon.

Also, arguably the only direct way coin owners can — in practice —  hold maintainers accountable is via antics on social media.  That is why control of a specific reddit, Telegram, or Twitter account is very important and why hackers target those channels in order to influence prices.

On p. 113 they write about supply schedules:

For example, with oil, there’s the famous Organization of the Petroleum Exporting Countries (OPEC), which has had considerable control over the supply levels of oil.

Inadvertently they actually described how basically all proof-of-work coins operate: via a small clique of known miners and mining pools.  A cartel?

Source: Jameson Lopp

While these miners have not yet increased or decreased the supply of bitcoins, mining is a specialized task that requires certain capital and connections in order to be successful at.  These participants could easily collude to change the money supply, censor transactions, etc. and there would be no immediate legal recourse.

On p. 115 they write:

Cryptoassets, like gold, are often constructed to be scarce in their supply. Many will be even more scarce than gold and other precious metals. The supply schedule of cryptoassets typically is metered mathematically and set in code at the genesis of the underlying protocol or distributed application.

How to measure scarcity here?

Despite what alchemists tried for centuries to do: aside from particle accelators, on Earth the only way of increasing the supply of gold and silver is via digging it out of the ground.  For cryptocurrencies, it is relatively easy to fork and clone both code and chains.  Digital scarcity for most — if not all — public chains, seems to be is a myth.

In the next edition, maybe remove the “backed by maths” trope?  None of these chains run themselves, they all depend on humans to run the equipment and maintain the code.

On p. 115 they write:

As discussed earlier, Satoshi crafted the system this way because he needed initially to bootstrap support for Bitcoin which he did by issuing large amounts of the coin for the earliest contributors.  As Bitcoin matured, the value of its native asset appreciated, which means less Bitcoin is over eight years old, it provides strong utility to the world beyond as an investment, which drive demand.

Satoshi likely mined around 1 million bitcoins for himself/herself.  Because of how centralized and small the network originally was in 2009, he/she probably could have unilaterally stopped the network and relaunched it and effectively removed that insta-mine. 79

In addition, there was almost no risk to either be a developer or a miner… the entry/exit costs were very low… so why did he issue large amounts of coins for these contributors?80

Also, how does it provide strong demand beyond investment?  How many people do the authors know regularly use Bitcoin itself for retail payments?81

Also, through Bitcoin’s evolution, arguably some of its utility was removed by going down a specific block size path.  The counterargument is that payments will be done via some other networks (such as Lightning) attached to Bitcoin, but as of this writing, that hasn’t panned out.

One last comment about this passage, FOSS is historically charity work and difficult to build a sustainable operation. A couple notable exceptions are Red Hat and SUSE (which was just acquired by EQT).

On p. 115 they write:

The Ethereum team is currently rethinking that issuance strategy due to an intended change in its consensus mechanism.

In the second edition is it possible to be consistent on this one point: how is an “official” or “centralized” development team congruent with the idea of having a “decentralized ecosystem”?

Also, the administrators of Ethereum Classic modified the money supply last year and most folks were blasé.  Where is the relevant FinCEN guidance?

On p. 115 they write:

Steemit’s team pursued a far more complicated monetary policy with its platform, composed of steem (STEEM), steem power (SP), and steem dollars (SMD).

[…]

They have also chosen to modify their monetary policy post-inception.

The authors of this book need to be consistent in their wording because in other places they criticize centralized financial institutions but do not criticize centralized monetary supply decision of coin makers.  Also, again, why or how does a decentralized project have a singular team?

On p. 116 they write:

Crypotassets can be likened to silicon. They have come upon the scene due to the rise of technology, and their use cases will grow and change as technology evolves.  Currently, bitcoin is the most straightforward, with its use case being that of a decentralized global currency. Ether is more flexible, as developers use it for computational gas within a decentralized world computer.

This isn’t a good analogy.  Silicon exists as a naturally occurring element… whereas cryptocurrencies do not naturally arise — humans create them.

In addition, bitcoin is arguably not the most straightforward due to a long divorce and schism process the past three years.  One distinct group of promoters calls it “digital gold” and another distinct group calls it a “payment system” — the two groups are almost violently opposed to one another’s existence.

On p. 116 they write:

Then there are the trading markets, which trade 24/7, 365 days a year. These global and eternally open markets also differentiate cryptoassets from other assets discussed herein.

The FX markets are open globally almost 24/6 for most of the year, so that’s not really a braggable claim.82 There are legal, regulatory, and practical reasons why most capital markets operate in the time windows they do… it is not because of some technological limitation.  Worth rewording in the next edition.

On p. 116 they write:

In short, the use cases for cryptoassets are more dynamic than any preexisting asset class. Furthermore, since they’re brought into the world and then controlled by open-source software, the ability for cryptoassets to evolve is unbounded.

In the next edition, maybe remove the pomp and circumstance unless there is actual data to back up the platitudes.  We can all easily conjure up lots of potential use cases for just about any type of technology, but unless they are built and used, the hype should be turned down a few notches.

Also, there are many other open source software projects that have actually shipped frequently used productivity tools and no one is yelling from the mountain tops about how they have unbounded potential.  How are internet coins any different?

On p. 117 they write:

Cryptoassets have two drivers of their basis of value: utility and speculative.

In theory, perhaps.  But in practice, most coins just have potential utility because with few exceptions, most buyers typically hold with the expectation the coin will appreciate.  Maybe that change in the future.

On p. 117 the write:

For example, Bitcoin’s blockchain is used to transact bitcoin and therefore much of the value is driven by demand to use bitcoin as a means of exchange.

Perhaps, though in the next edition recommend modifying the wording to include: “… as a means of exchange or investment…”  Currently, we know a large portion of activity is likely movement (arbitrage) between exchanges.8384

But even ignoring this data (from analytics companies) this scenario has been diced-up elsewhere:

On p. 117 they write:

Speculative value is driven by people trying to predict how widely used a particular cryptoasset will be in the future.

If there are systematic surveys of actual buyers and sellers perhaps add those in the second edition.85

On p. 118 they write:

With cryptoassets, much of the speculative value can be derived from the development team. People will have more faith that a cryptoasset will be widely adopted if it is crafted by a talented and focused development team. Furthermore, if the development team has a grand vision for the widespread use of the cryptoasset, then that can increase the speculative value of the asset.

This is false.

For starters, the value of a new coin is almost entirely a function of the marketing effort from the coin issuers: that’s why nearly all ICOs carve out a portion of their funding pie to market, promote, and advertise… spreading the sexy gospel of the new coin.

This is a big bucks opaque industry, with all sorts of shenanigans that take place just to get listed on secondary markets… with coin issuers paying more than $1 million to get listed.

While $1 million or even $3 million may sound like a lot to get listed, the issuers know it is worth it because the retail speculators on the other end will at least temporarily pump the coin price up often long enough for the original insiders and investors to cash out.

Now the coin issuers may talk a big game and at eloquent length about how their grand vision: that their coin will end world hunger and save the environment, but they often have no ability to execute and build the product(s) they claimed in their whitepaper.

As mentioned above, one recent study found that, “56% of crypto startups that raise money through token sales die within four months of their initial coin offerings.”

Also, how does a decentralized cryptocurrency have an official singular development team?

On p. 118 they write:

As each cryptoasset matures, it will converge on its utility value. Right now, bitcoin is the furthest along the transition from speculative price support to uility price support because it has been around the longest and people are using it regularly for its intended utility use case.

And what is its intended use case?  The maximalist vision (digital gold) or the originalist payments vision?

On p. 118 they write:

For example, in 2016, $100,000 of bitcoin was transacted every minute, which creates real demand for the utility of the asset beyond its trading demand. A great illustration of bitcoin’s price support increasingly being tied to utility came from Pantera Capital, a well-respected investment firm solely focused on cryptoassets and technology. in Figure 8.2 we can see that in November 2013 bitcoin’s speculative value skyrocketed beyond its utility value, which is represented here by transactions per day using Bitcoin’s blockchain (CAGR is the compound annual growth rate).

But this didn’t happen.

Pantera has a habit of cherry picking dates and using different types of graphs (such as log versus linear) in order to talk its book.

For instance, they conjured up and pushed the “bitcoin absorbs the value of gold” narrative back in late 2014.  Then a year later, they became part of the “great pivot” by rebranding everything “blockchain” instead of bitcoin.

Putting those aside, the transactional part of the graph (Figure 8.2) from Pantera was published in early 2017 and has not held up to further scrutiny by mid-2018.

Source: Pantera

Compare that with the actual transactional volume for the past two years, including the most recent bull run:

Perhaps for some unknown reason the up-and-to-the-right hockey stick graph that Pantera tried to create with its dotted lines will germinate.  But for now, as of this writing, their transactional / utility thesis is incorrect.

Why?  Because the assumptions were the same as the authors of this book: they assume retail or institutional users will flock to using bitcoin for non-speculative reasons, but that has not occurred yet.

On p. 119 they write:

Speculative value diminishes as a cryptoasset matures because there is less speculation regarding the future markets the cryptoasset will penetrate. This means people will understand more clearly that demand for the asset will look like going forward. The younger the cryptoasset is, the more its value will be driven by speculative vlaue, as shown in Figure 8.3. While we expect cryptoassets to ossify into their primary use cases over time, especially as they become large system that supports significant amounts of value, their open-source nature leaves open the possiblity that they will be tweaked to pursue new tangential use cases, which could once again add speculative value to the asset.

Their wording in this and other passages has definitive certainty without any hedging.

This is unfounded.  Recall, what can be presented without evidence can be dismissed without evidence.  This also makes a circular argument that the next edition needs to provide evidence for (or just remove it).

Chapter 9

On p. 122 the write:

For example, currently the bond markets are undergoing significant changes, as a surprising amount of bond trading is still a “voice and paper market,” where trades are made by institutions calling one another and tangible paper is processed. This makes the bond market much more illiquid and opaque than the stock market, where most transactions are done almost entirely electronically: With the growing wave of digitalization, the bond markets are becoming increasingly liquid and transparent. The same can be said of markets for commodities, art, fine wine, and so on.

In re-reading this I can’t tell if the authors recognize that the bond market, as well as all of the other markets listed, started out in pre-electronic and even pre-industrial times.

That’s not to defend the status quo, only that if modern day trading platforms and automation existed a couple hundreds years ago, it is likely that bonds trading would have migrated much earlier than 2018… maybe even on a blockchain!

On p. 122 they write:

Cryptoassets have an inherent advantage in their liquidity and trading volume profile, because they are digital natives. As digital natives, cryptoassets have no physical form, and can be moved as quickly as the Internet can move the 1s and 0s that convey ownership.

This is conflating digitization/digitalization with blockchains.  You can have one without the other and in fact, do.

For instance, with US equities, beginning in the ’60s through the ’70s, stocks were dematerialized then immobilized in CSDs and ownership is now transferred electronically.86

Perhaps there is something to be said about this market infrastructure further evolving in time with a blockchain of some kind.

For example in the US, the DTCC (a large CSD) has:

Virtually every major CSD, stock exchange, and clearing house has likewise publicly opined or participated in some blockchain-related initiatives.  But that is a separate topic maybe worth looking into for the next edition.

On p. 123 they write:

Even though they are growing at an incredible clip, separation between cryptoasset markets and traditional investor capital pools still largely remains the case.

How much real money has actually entered the cryptocurrency market?

There have been several attempts to quantify it and it is still rather small, maybe up to $10 billion came in during 2017.

On p. 125 they write:

For example, in 2016, Monero experienced a sizeable increase in notoriety–largely because its privacy features began to be utilized by a well-known dark market–which sent its average trading volume skyrocketing. In December 2015, daily volume for the asset was $27,300, but by December 2016 it was $3.25M, well over a hunderfold increase. The price of the asset had appreciated more than 20-fold in the same period, so some of the increase in trading volume was due to price appreciation, but clearly a large amount was due to increased interest and trading activity in the asset.

But how do the authors know this “clearly” was the case?  Did they do some random sample surveys?  The next edition they need to prove their assumption, not just make them.  After all, it is hard — perhaps impossible — to externally ascertain what is going on at an exchange simply by looking at self-published volumes.

Also, the exchanges that these coins trade on are still typically unregulated, with little optics into how often manipulation occurs.  That is why a number of them have been subpoenaed by various governmental bodies; in the US this includes the SEC, CFTC, IRS, FBI, and even separate states acting in coordination.

On p. 129 they write:

From these trends, we can infer that this declining volatility is a result of increased market maturity. Certainly, the trend is not a straight line, and there are significant bumps in the road, depending on particular events. For example, monero had a spike in volatility in late 2016 because it experienced a significant price rise. This shows volatility is not only associated with a tanking price but also a skyrocketing price. The general trend, nonetheless, is of dampening volatility […].

This is not true either.  Maybe there are cherry picked dates in which there is relatively lower volatility than normal, but this year alone prices as measured in real money, declined between 60-100% for basically all crypotocurrencies and this involved a roller coaster to achieve.

In fact, in the process of writing this review, there were multiple days in which prices increased 5-10% for most coins and then a few days later, saw the same size of loses.  Erratic volatility has not disappeared.

On p. 133 they write:

Despite the many PBOC interventions, Chinese citizens used bitcoin to protect themselves against the erosion in value of their national currency.

Who in China did this?

I have spent an enormous amount of time visiting China the past several years on business trips and not once did someone say they had shifted their wealth from RMB into bitcoin because of RMB depreciation.  There are many speculators and miners, but to my knowledge there has not been a formal survey of buyers and their motivations… and the result being because of RMB depreciation.

The next edition should either remove this statement or add a citation.

On p. 134 they write:

As bitcoin rose and fell, so too did these assets. This reinforces the need for the innovative investor to become knowledgeable about these assets’ specific characteristics and recognize where correlations may or may not occur.

Recommend removing “innovative investor” in this location.87

Chapter 10

On p. 137 they write:

On its path to maturity, bitcoin’s price has experienced euphoric rise and harrowing drops, as have many cryptoassets. One of the most common complaints among bitcoin and cryptoasset naysayers is that these fluctuations are driven by the Wild West nature of the markets, implying that cryptoassets are a strange new breed that can’t be trusted. While each cryptoasset and its associated markets are at varying levels of maturity, associating Wild West behavior as unique to cryptoasset markets is misleading at best.

No it isn’t.  The authors do not even define or provide some kind of way to measure “maturity.”  This paragraph creates a strawman.

The burden-of-proof rests on the party making the positive claim.  In this case, the party claiming that a coin is becoming mature must provide objective evidence this is taking place.  Should reword in the next edition.

On p. 138 they write:

Broadly, we categorize five main patterns that lead to markets destabilizing: the speculation of crowds, “This time is different,” Ponzi schemes, Misleading information from asset issuers, Cornering.

Those are valid patterns, in full agreement here.  But this edition does not help in dispelling these problems and arguably even contributes to some of the speculative frenzy.

On p. 138 they write:

Sometimes they do this to capitalize on short-term information they believe will move the market, other times they do it because they expect to ride the momentum of the market, regardless of its fundamentals. In short, they try to profit within the roller-coaster ride.

What are the fundamentals of any coin described in this book?  Next edition, clearly write out 5-10 if possible.

On p. 139 they write:

As America was struggling through the Great Depression, which many pinned on the stock market crash of 1929, there was strong resentment against speculators. Every crisis loves a scapegoat.

And in Bitcoinland there is no difference.  Bitcoiners love to blame: bankers, the Illuminati, naysayers, concern trolls, academics, the government, Jamie Dimon, big blockers, small blockers, weak hands, statists, other coins, China, George Soros, Warren Buffett, Mike Hearn… virtually every month there is a new boogeyman to blame something on.  I’ve even been blamed many times and I’m not involved at all in the market.

On p. 143 they write:

Cheap credit often fuels asset bubbles, as seen with the housing bubble that led to the financial crisis of 2008. Similarly, cryptoasset bubbles can be created using extreme margin on some exchanges, where investors are effectively gambling with money they don’t have.

Fully agree, good point.

On p. 144 they write:

The best way to avoid getting burned in this manner is to do proper due diligence and have an investment plan that is adhered to.

Fully agree, good point.

On p. 145 they write:

The key to understanding bitcoin’s value is recognizing it has utility as “Money-over-Internet-Protocol”( MoIP)–allowing it to move large amounts of value to anyone anywhere in the world in a matter of minutes–which drives demand for it beyond mere speculation.

This might be partially true but is has the same feel-good narrative that folks like Andreas Antonopoulos have been getting paid handsomly to regurgitate.  Bitcoin (the network) does not move anything beyond bitcoins (the coin).  Users still have to convert bitcoins into actual money at end points.

Converting a large amount — greater than $10,000 — will likely require KYC and AML and maybe even sanctions checks.  This adds time and money which is one of the reason why the remittance use-case didn’t really get much traction after the hype in 2014 – 2015 and why companies such as Abra had to pivot a few times.

With that said, their metapoint is valid on the edges: despite the frictions that may exist, some participants are willing to go through this experience in order to gain more anonymity for uses they might not otherwise be able to do using traditional methods.88

Over the past three years there has also been an expansion of country- and region-based payment schemes worldwide to achieve near-real-time transfers, with Europe being one of the most significant accomplishments.89

In parallel, there are on-going experimentation and scaling of private blockchain-based ‘rails’ like Swift gpi or Alipay with GCash which have a potential to surpass volumes of the Bitcoin network.90

On p. 145 they write:

When Mt. Gox was established, bitcoin finally became accessible to the mainstream.

One nitpick:

Up until recently it was difficult for even diehard users to get onboarded onto most exchanges.  And specifically in 2010 with the launch of Mt. Gox, Jed McCaleb used Paypal to help facilitate the transfer of money… until Paypal dropped Mt. Gox because of too many chargebacks.  To get money into and out of Mt. Gox often was a frictionfull task, unless you lived in Japan.

On p. 149 they write:

As shown in Figure 10.4, steem’s price in bitcoin terms would fall from its mid-July peak by 94 percent three months later, and by 97 percent at the end of the year. This doesn’t mean the platform is bad. Rather, it shows the speculation and excitement about its prospects fueled a sharp rise and fall in price.

In hindsight, everything is 20-20.  The same truism in their last sentence can be said just about with every coin that sees the meteoric rise that Steemit did in 2016.91

On p. 150 they write:

While zcash has since stabilized and continues to hold great promise as a cryptoasset, its rocky start was caused by mass speculation.

Two comments:

  • Do the authors own any Zcash (or other cryptocurrencies mentioned in this book besides bitcoin)?
  • In late 2016 there were oodles of “thought leaders” talking about how Zcash was — for a moment — valued at a trillion dollars because of the very thin supply that was trading on exchanges.  It was a headscratching meme that illustrates a shortcoming to the common “market cap” valuation mehtod.92

On p. 152 they write:

The idea of valuation, which we will tackle in the next chapters, is a particularly challenging one for cryptoassets. Since they are a new asset class, they cannot be valued as companies are, and while valuing them based on supply and demand characteristics like that of commodiites has some validity, it doesn’t quite suffice.

Then why spend an entire chapter (Chapter 7) comparing coins such as bitcoin, to companies and their stock?

You can’t have it both ways.  Either heavily modify Chapter 7 in the next edition, or remove this comment.

Chapter 11

On p. 155 they write:

Given the emerging nature of the cryptoasset markets, it’s important to recognize that there is less regulation (some would say none) in this arena, and therefore bad behavior can persist for longer than it may in more mature markets.

And there are now full-time lobbyists and trade associations — sponsored by donors whom have benefited from this unregulated / underregulated market — that actively push back against sensible regulations being applied.  But that’s a different conversation beyond this post.

On p. 155 they write:

As activity grows in bitcoin and crypotasset markets, investors must look beyond the madness of the crowd and recognize that there are bad actors who seek easy prey in these young markets.

Even for a book published in late 2017, this is pretty much lip service.  Volumes of books can be written about the shenanigans within nearly every public ICO and high-profile coin project.  The authors should either modify the statement above or ideally expand it to detail specific egregious examples besides just OneCoin.

For instance, a new study found that: More Than Three-Quarters of ICOs Were Scams.  And these were ICOs done in 2017.

On p. 158 they write:

While a truly innovative crypotasset and its associated architecture requires a heroic coding effort from talented developers, because the software is open source, it can be downloaded and duplicated. From there, a new cryptoasset can be issued wrapped in slick marketing. If the innovative investors doesn’t do proper due diligence on the underlying code of read other trusted sources who have, then it’s possible to fall victim to a Ponzi scheme.

Enough with the “heroic” adjectives, let’s not put anyone on a pedestal, especially if the platform is not being used by anyone besides speculators and illicit actors.

Secondly, a minor grammar question: other uses of “open-source” in this book have a dash and the one above does not.

Lastly, recommend readers look into “Nakomoto Schemes” described in this article: The Problem with Calling Bitcoin a “Ponzi Scheme”

On p. 158 they write:

Millions of dollars poured into OneCoin, whose technology ran counter to the values of the cryptoasset community: its software was not open source (perhaps out of fear that developers would see the holes in its design), and it was not based on a public ledger, so no transactions could be tracked.

First, what are the “values” that the “community” has?  Are these explicity written somewhere?  Who decided those?

Second, those actually don’t sound too uncommon.

For instance, one recent study found: “Security researchers have found, on average, five security flaws in each cryptocurrency ICO (Initial Coin Offering) held last year. Only one ICO held in 2017 did not contain any critical flaws.”

And remember, these projects are “open source” yet most buyers and investors didn’t bother looking at the code.  OneCoin is par for the course.

On p. 159 they write:

The swift action revealed the strength of a self-policing, open-source community in pursuit of the truth.

In my most popular post last year, I went through in detail explaining how self-policing is an oxymoron in the cryptocurrency world.

For example, “the community” actively listed OneCoin on secondary markets and profited from its trading.  Did exchange operators return those gains to victims?  In addition, “the community” has thus far, not set up any self-regulating organization (SRO) that has any ability or teeth to enforce a code-of-conduct.

In fact, it was agencies from Sweden, the UK, and other governments that acted and cracked down on OneCoin… not a collective effort from exchanges or VCs or twitter personalities.

On p. 159 they explain googling for code on GitHub:

If nothing pops up with signs of the code on GitHub, then the cryptoasset is likely not open source, which is an immediate red flag that a cryptoasset and investment should be avoided.

Sure, but it doesn’t include the fact(s) that even in 2017 we knew that many coin projects had bugs in it… because there is no incentive to independently audit this code or to publish it in an objective manner.

For example, often when someone tries to help highlight problems, they are demonized as a “concern troll” as the coin tribes brigade their Twitter and reddit threads.  There are a couple of sites like ConcourseQ that now do help highlight problems, but most “crypto thought leaders” on social media spend their time rallying retail investors to buy coins instead of busting or calling out the legitimate coin scams.

On p. 161 they write about John Law:

Fortunately, today it’s quite easy to find information on just about anyone through Google searches.

Yes and no.  And that still doesn’t act as a shield against fraud.  The founders of Centra had shady, criminal pasts but were still able to raise more than $30 million in an ICO.  Their misdeeds only became widely known after a New York Times article explored it… this was not a story that was investigated by any of the “coin media” who collectively have a vested interested not to “self-police” the market they cover.

Furthermore, prior to getting busted and sued, Centra became a dues paying member of: Hyperledger, the Enterprise Ethereum Alliance, and the Chamber of Digital Commerce.  What are the filtering mechanisms in place at these types of organizations?  How do they determine who can join and if a coin is a security?

On p. 165 they write:

As with most panics, the contagion spread from the Gold Exchange.  Because of Gould’s cornering of the market, stock prices dropped 20 percent, a variety of agricultural exports fell 50 percent in value, and the national economy was disrupted for several months. Gould exited with a cool $11 million profit from the debacle, and scot-free from legal charges. It is all too common that character like Gould escape unscathed by the havoc they create, which then allows them to carry on with their machinations in other markets.

These kinds of panics and manipulation are part and parcel to retail traders on cryptocurrency exchanges.  Scapegoats and the blame game consist of a myriad of boogeymen — but typically the culprits are never found.93

On p. 167 they write:

In addition to miners, in Dash there are entities called masternodes, which are also controlled by people or groups of people. Masternodes play an integral role in performing near instant and anonymous transaction with Dash.

Putting aside whether Dash is or is not anonymous… the fact that the authors state that humans play a direct role in running the infrastructure raises a bunch of questions that I have repeated in this review.

How are these participants held accountable?  How is governance managed?  Have these participants registered with FinCEN?  Why or why not?

On p. 168 they write about the Bitcoin Rich List:

Another 116 addresses hold a total of 2.87 million bitcoin, or 19 percent of the total outstanding, which is sizeable. Unlike dash, however, these holders aren’t necessarily receiving half the newly minted bitcoin, and so their ability to push the price upward is less.

Should there be a thorough investigation of how any one party or set of parties can artificially move prices around based on control of the money supply?  In our current real-world framework, there are frequent public hearings and audits done.  When will minters of cryptocurrencies be publicly audited?

Chapter 12

On p. 171 they write:

Each cryptoasset is different, as are the goals, objectives, and risk profiles of each investor. Therefore, while this chapter will provide a starting point, it is by no means comprehensive. It’s also not investment advice.

Throughout the book the authors have repeatedly endorsed or not-endorsed specific coins.  The second edition needs to be a lot more consistent.

On p. 172 they write:

Currently, there is no such thing as sell-side research for cryptoassets, and this will require innovative investors to scour through the details on their own or rely on recognized thought leaders in the space.

This is a sad truth: it is nearly impossible to get neutral, objective research on any coin that has been created.

Why?  Because all coin holders basically have an incentive to promote and advertise the coins they own and talk down other coins they perceive as competition.  Paying “researchers” has happened and will continue to do so.

Also, here’s another appearance of “innovative investor” — can that be removed altogether?

And lastly, how to know who the “recognized thought leaders” are?  Based on the amount of twitter followers they have?  That has been gamed.  Based on how popular their Youtube account is?  That has been gamed.

For example, these two article explain some of this payola world:

Another instance, a couple weeks ago a government department in China (CCID) released its second ranking table of coins: China’s Crypto Ratings Index Puts EOS in Top Slot, Drops Bitcoin

It’s unclear if this is due to lobbying efforts or maybe the researchers owned a bunch of EOS coins.  At this time, the EOS block producing and arbitrator framework are both broken.  Block producers paused the network a few weeks ago and the arbitrators / constitutions will probably be scrapped.

How can this rating system be trusted?

On p. 173 they write about white papers:

Any cryptoasset worth its mustard has an origination white paper. A white paper is a document that’s often used in business to outline a proposal, typically written by a thought leader or someone knowledgeable on a topic. As it relates to cryptoassets, a white paper is the stake in the ground, outlining the problem the asset addresses, where the asset stands in the competitive landscape, and what the technical details are.

During the Consensus event this past May, someone accidentally dropped a napkin on the floor and someone loudly said: watch out, that’s the latest multimillion dollar white paper.

And that’s the situation where we are in now.  Readers: the passage above was not at all critical of the real mess we are in today.  For instance, Tron literally plagiarized in its whitepaper, raised a ton of money in its ICO and recently bought BitTorrent.

There is no direct connection between a “good” or “bad” whitepaper and the performance of the coin.  Retail investors do not typically care and haven’t done much research.  Yet another reason agencies such as the SEC will be overwhelmed in the coming years due to rampant fraud and deceit.  Worth looking into the next edition.

On p. 173 they write:

Some of these white papers can be highly technical, though at the very least perusing the introduction and conclusion is valuable.

This seems like an incongruent statement compared to other advice in the book about doing deep research.  Recommend revising.

On p. 174 they write:

A number of cryptoasset-based projects focus on social networks, such as Steemit and Yours, the latter of which uses litecoin. While we admire these projects, we also ask: Will these networks and their associated assets gain traction with competitors like Reddit and Facebook? Similarly, a cryptoasset service called Swarm City (formerly Arcade City) aims to decentralize Uber, which is already a highly efficient service. What edge will the decentralized Swarm City have over the centralized Uber?

And that in a nutshell is why the second edition of the book arguably needs to be slimmed down by 25%+.  Virtually all of the use cases in this book are simply potential use cases and have shown little or even no traction in reality.  For example, if the authors were as critical to Bitcoin and Zcash as they were to Swarm City then the second edition might be perceived as more balanced.

Specifically, in their promotion of Bitcoin as a payments platform, they have not done a deep dive into other existing payment networks, such as Visa or an RTGS from a central bank.94 They should do that in the next edition otherwise these come across as one-sided arguments.

Also, Yours switched from Litecoin over to Bitcoin Cash last year (around the time the book was published) and Swarm City is still not very active at the time this review was written.

On p. 175 they write about The Lindy Effect

The same applies to cryptoassets. The longest-lived cryptoasset, bitcoin, now has an entire ecosystem of hardware, software developers, companies, and users built around it. Essentially, it has created its own economy, and while a superior cryptocurrency could slowly gain share, it would have an uphill battle given the foothold bitcoin has gained.

This is untrue in theory and practice.

While maximalists would vocally claim that there can only be one-chain-to-rule-them-all, there is no real moat that Bitcoin has to prevent users from exiting or switching to other platforms (see discussion on substitute goods).

In practice, effectively all proof-of-work cryptocurrencies depend on external capital to stay afloat, often in the form of venture capital. ((See Robert Sams on rehypothecation, deflation, inelastic money supply and altcoins)) Part of the reason is that miners need to pay their bills in traditional currency and therefore must liquidate some or all of their coins to do so.  Another issue is that because many participants think or believe that coin prices as measured in real money will increase in the future, they hold.  Yet the expenses of service providers (exchanges, wallets, etc.) typically need to be paid with traditional money.

As a result, this creates sell-side pressure.  And unlike the traditional FX market which has “natural” buyers in the form of international merchants and multinational corporations: there still is no “natural” buyers of cryptocurrencies outside of illicit activity (e.g., darknet market participants).

To compound this situation is that there is still no real circular flow of income, no real economy for any of these cryptocurrencies.95  And with the exception of a few cases each year, miners typically do not directly invest their coin holdings into companies, so crypotcurrency-related startups are dependent on foreign currency.

On p. 175 they write:

The demise of The DAO significantly impacted Ethereum (which The DAO was built on), but through leadership and community involvement, the major issues were addressed, and as of April 2017 Ethereum stands solidly as the second largest cryptoasset in terms of network value.

In the second edition, could the authors explicitly lay out how they define “leadership” in this context as well as what the “community” is?  If it is singular and centralized, how is that fitting for an entity that is supposed to be decentralized?

Also, for readers interested in The DAO, here’s a short fiery thread on that topic.

On p. 176 they discuss “utility value and speculative value”

For bitcoin, its utility is that it can safely, quickly, and efficiently transfer value to anyone, anywhere in the world.

That may have been the original vision expressed in the whitepaper but it is not what the maximalists now claim Bitcoin is.  Who’s promotion around utility is something we should take into consideration?

Also, considering how easy and common it is to hack cryptocurrency intermediaries such as exchanges, I think it is debatable that Bitcoin is “safe” for unsophisticated retail users, but that’s a separate topic.

On p. 176 they write:

The merchants wants to use bitcoin because it will allow her to transfer that money within an hour as opposed to waiting a week or more. Therefore, the Brazilian merchant buys US$100,000 worth of bitcoin and sends it ot the Chinese manufacture.

They explain a little more but the difficulties with this example starts here.  The authors only focus on the bitcoins themselves, they don’t explore the actual full lifecycle that international merchants and manufacturers have to go through in order to exchange bitcoins into real money that they can use to pay bills.

That is to say: the Brazilian merchant and Chinese manufacture do not hold onto coins, so it is not just a matter of how fast they can send or receive the coins.  What ultimately matters to them is how quickly they can receive the real money from a bank.

So the next edition needs to include the full roundtrip costs and frictions including the on-ramps and off-ramps into the traditional financial system.  This is why many Bitcoin remittance companies struggled and ultimately had to pivot out of that cross-border use case (such as Abra).  For the next edition, a side-by-side cost comparison would be helpful.96

On p. 177 they write:

That means on average each of these addresses is holding US$5.5 million worth of bitcoin, and it’s fair to assume that these balances are not those of merchants waiting for their transactions to complete. Instead, these are likely balances of bitcoin that entities are holding for the long term based on what they think bitcoin’s future utility value will be. Future utility value can be thought of as speculative value, and for this speculative value investors are keeping 5.5 million bitcoin out of the supply.

This seems like euphemisms.  We understand that time preferences and discounted utility come into dramatic effect here.  Maybe worth rewording?

For example, a large portion of those coins could be permanently destroyed (e.g., someone deleted the private key or threw away the hard drive).  Though a significant portion could also be maximalists holding onto their coins with the hope that other investors create sufficient demand to move the price — as measured in real money — upward and upward.  So they can then cash out.

If daily and weekly anecdotes on twitter and reddit are any indication, that’s arguably the real utility value of most coins, not just bitcoin.  And there is some analytics to back up that argument too.

On p. 177 they write:

At the start of April 2017, there were just over 16 million bitcoin outstanding. Between international merchants needing 10 million bitcoin, and 5.5 million bitcoin held by the top 1,000 investors, there are only roughly 500,000 bitcoin free for people to use.

Citation needed. If the authors have any specific information that can share with the audience about any of these numbers, that’d be very helpful.  Especially regarding the merchants needing 10 million bitcoin.  If anything, there may be fewer merchants actively accepting bitcoin today than there were a couple years ago.

On p. 177 they write:

If demand continues to go up for bitcoin, then with a disinflationary supply schedule, so too will its price (or velocity).

Couple of things:

  • Bitcoin’s current supply schedule is perfectly inelastic (whereas say gold, is elastic).
  • It would be good to see what the authors think the velocity of bitcoin is.  I’ve tried to track down and write about it in the past.  See all of Chapter 9.

On p. 177 they write:

In other words, those investors no longer feel bitcoin has any speculative value left, and instead its price is only supported by current utility value.

As mentioned above, it would be helpful in the next edition if the authors included specific definitions and characteristics in a chart for what utility versus speculative value are.

Also, I don’t endorse the post in its entirety, but about five years ago Rick Falkvinge wrote an interesting note about the transactional value from illicit activity as it relates to Bitcoin.  That has some actual data in it (though very old now).

On p. 178 they write:

For bitcoin, instead of looking at the “domestically produced goods and services” it will purchase in a period, the innovative investor must look at the internationally produced goods and services it will prucahse. The global remittances market–currently dominated by companies that provide the ability for people to send money to one another internationally–is an easy graspable example of service within which bitcoin could be used.

This whole section should probably be culled because this isn’t really a viable, scalable use case that bitcoin itself can solve.

For example, between 2014-2016, tens of millions of dollars were invested in more than a dozen “rebittance” companies (Bitcoin-focused remittance) and most either failed or pivoted.

Those that still exist had to build additional services and bitcoin were a means to an end.  In all cases, these companies had to build their own cryptocurrency exchange and/or partner with several cryptocurrency exchanges in order to liquidate the coins — they need to hedge and limit their exposure to volatility.  Bitcoin also doesn’t solve for the last-mile problem at all… but that is a separate topic.97

On p. 179 they write:

If each bitcoin needs to be worth $952 to service 20 percent of the remittance market and $11,430 to service the demand for it as digital gold, then in total it needs to be worth $12,382. There is no limit to the number of use cases that can be added in this process, but what is extremely tricky is figuring out the percent share of the market that bitcoin will ultimately fulfill and what the velocity of bitcoin will be in each use case.

This is highly debatable.  And it is exactly what Pantera stated four years ago.  Sources should be cited in the next edition; and also provide a velocity estimate for the potential use cases.

On p. 180 they write:

Taking the concepts of supply and demand, velocity, and discounting, we can figure out what bitcoin’s value should be today, assuming it is to serve certain utility purposes 10 years from now. However, this is much easier said than done, as it involves figuring out the sizes of those markets in the future, the percent share that bitcoin will take, what bitcoin’s velocity will be, and what an appropriate discount rate is.

An actual asset would certainly need these blanks filled, but Bitcoin doesn’t behave like a normal asset.  For instance, it goes through enormous speculative bubbles and busts.  It reached just under $20,000 per coin in mid-December last year not for any utility reason but pure speculation… yet many of the “thought leaders” at the time said it was because new buyers were going to use it for its utility.

On p. 180 they write:

Already there have been reports, such as those from Spence Bogart at Needham & Company, as well as Gil Luria at Webush, that look at the fundamental value of bitcoin.

I’ve read most of their reports, they’re nearly all based on edge-case assumptions or one-off anecdotes that never saw much traction (such as remittances).  In addition, arguably both of their analysis may have been colored by their coin investments at the time they published their work.  That’s not to say their material is discredited but I would discount some of their cryptocurrency-related reports.98

On p. 180 they write:

The valuations these analysts produce can be useful guides for the innovative investor, but they should not be considered absolute dictations of the truth. Remember, “Garbage in, garbage out.” We suspect that as opposed to these reports remaining proprietary, as is currently the case with much of the research of equities and bonds, many of these reports will become open-source and widely accessible to all levels of investors in line with the ethos of cryptoassets.

This has not happened.  If anything, the market has been flooded with junk marketing material that masquerades as “research.”  Universities are now getting funded by coin issuers and asked to co-publish papers.  Even if there are no explicit shenanigans going on, there is now a shadow of doubt that hangs over these organizations.

Also, the next edition needs to define what “the ethos of cryptoassets” is somewhere up front.  And dispense with “innovative investor”?99

On p. 182 they write about getting to know “the community and the developers”:

In getting to know the community better, consider a few key points. How committed is the developer team, and what is their background? Have they worked on a previous cryptoasset and in that processrefined their ideas so that they now want to alunch another?

[…]

If information cannot be found on the developers, or the developers are overtly anonymous, then this is a red flag because there is no accountability if things go wrong.

Satoshi clearly wouldn’t have been able to pass this test.  Nor BitDNS originally (which later became Namecoin).

It is a double-standard to want accountability here yet promote an ill-defined “decentralization” throughout this book.  You really can’t have it both ways.

Remember, the reason why administrators and operators of financial market infrastructure are heavily regulated is to hold participants legally responsible and accountable for when mistakes and accidents occur.

Cryptocurrencies were designed to be anarchic and purposefully were designed to not make a single participant accountabile.  Trying to merge those two worlds creates the worst of both: permissioned-on-permissionless.

On p. 183 they write:

If Ethereum gets big enough, there may eventually be those who call themselves Ethereum Maximalists!

Yes, they exist and largely self-selected themselves into the Ethereum Classic world… you can see that by their antics on social media.

On p. 183 they write about issuance models:

Next, consider if the distribution is fair. Remember that a premine (where the assets are mined before the network is made widely available, as was the case with bytecoin) or an instamine (where many of the assets are mined at the start, as was the case with dash) are both bad signs because assets and power will accrue to a few, as opposed to being widely distributed in line with the egalitarian ethos.

Let’s tone down the talk on egalitarianism in a market fueled by greed and a perpetually high Gini coefficient.

In practice as of July 2018, many ICOs are pre-mined or pre-allocated, most as ERC20 tokens that are controlled by a singular entity (usually an off-shore foundation).100

Is this a “bad sign”?  It would be helpful to see what the explicit criteria around token distribution should be in the next edition.101

On p. 183 they write:

For example, Ethereum started with one planned issuance model, but is deciding to go with another a couple years into launch. Such changes in the issuance model may occur for other assets, or impact those assets that are significatnly tied to the Ethereum network.

Those decision are made by individuals.  Perhaps by the next edition we will know what FinCEN and other regulatory positions on individuals creating monetary policy and running financial market infrastructure.

On p. 184 they write:

With Dogecoin we saw that it needed lots of units outstanding for it to function as a tipping service, which justifies it currently having over 100 billion units outstanding, a significantly larger amount than Bitcoin. With many people turning to bitcoin as gold 2.0, an issuance model like Dogecoin’s would be a terrible idea.

What?  Why?  This passage conflates many different things.

  1. As Jackson Palmer has repeatedly said: Dogecoin was set up as a joke, based on a meme.  The authors seem to be taking its existence a little too seriously.
  2. Dogecoin was originally based on Luckycoin which had a random money supply, so its original hashrate charts were all over the map, bipolar.
  3. Its money supply was changed in part because it ran into an exitential crisis that it later (mostly) solved by merge mining with Litecoin in 2014

How does any of this have to do with maximalist narrative of “gold 2.0”?

On p. 186 they write:

The only way attackers can process invald transactions is if they own over half of the computer power of the network, so it’s critical that no single entity ever exceeds 50 percent ownership.

Technically this is not quite right.

The actual figure to sucessfully censor and/or reorg the chain may be as low as 33% and perhaps even 25% (dubbed “selfish mining“).102  More than 50% would mean the participants could do so repeatedly until their hashrate declines and/or a permanent fork occurs.

Aside from pressure on social media, there is nothing to prevent such “ownership” from taking place.  And there is no legal recourse or accountability in the event it happens.  And such “attacks” have occured on many different cryptocurrencies.103

On p. 186 they write:

In other words, miners are purley economically rational individuals–mercenaries of computer power–and their profit is largely driven by the value of the crypotasset as well as by transaction fees.

This should be reworded from the next edition because it is not true.  Miners and mining pools are operated by people and they have various incentives, including to attack networks or abandon them altogether.

On p. 186 they write:

A clearly positively reinforcing cycle sets in that ensures that the larger the asset grows, the more secure it becomes–as it should be.

This is not true for proof-of-work coins.

If anything, mining and development have both trended towards centralization.  For instance, it is estimated that Bitmain-manufactured hashing equipment currently generates 60-80% of the network hashrate and Bitmain-affiliated mining pools comprise about 50%+ of the current Bitcoin network.  Maybe that is just momentary but singular entities on the mining side dominate many other cryptocurrencies as well.  Perhaps that changes later in the year so it is worth revisiting in the next edition.

Recommended reading:

On p. 187 they write:

At the risk of being repetitive, more hash rate signifies more computers are being added to support the network, which signifies greater security.

This is a non sequitur.  A new hashing machine capable of generating 10 times the amount of hashes as the previous machine could — ceteris paribus — result in other machines being turned off.  In practice, you often have the Red Queen Effect take place (see Chapter 3).

Either way, depending on the costs of more efficient ASIC design, there could actually be fewer (or more) hashing machines added to a network depending on the expected price of the coin minus operating costs.

And in some cases, the network may become more centralized and therefore arguably less secure.  Worth revising in next edition.

On p. 188 they write:

While hash rate often follows price, sometimes price can follow hash rate. This happens in situations where miners expect good things of the asset in the future, and therefore proactively connect machines to help secure the network. This instills confidence, and perhaps the expected good news has also traveled to the market, so the price start going up.

This passage has entered Rube Goldberg territory, where a series of specific events turn into a virtuous cycle in which prices go up and up but not down?  How can we ever know what caused certain price increases or decreases with this type of asymmetric information occurring in the background?  Suggest scrapping it in the next edition.

On p. 188 they write:

Ethereum’s mining network, on the other hand, is less built out because it’s a younger ecosystem that stores less value. As of March 2017, a 230 megahash per second (MH/s) mining machine could be purchased for $4,195, and it would take 70,000 of these machines to recreate Ethereum’s hash rate, totaling $294 million in value. Also, because Ethereum is supported by GPUs and not ASICs, the machines can more easily be constructed piecemeal by a hobbyist on a budget.

There are a few issues with this:

  1. How do the authors measure or quantify “less built out”?  Is there a line that is crossed in which Ethereum or other coins are “more built out” or the right size?
  2. About a year ago a coin reporter asked me to detail the hypothetical lower bound costs for recreating the hashrate of the Bitcoin network.  I provided those numbers based on Bitmain’s latest device… but the article instead ignored any of that and instead quoted some random conspiracy theory from a Twitter personality.  Rather than rehashing the full story here, keep in mind that the geographic distribution and control of mining equipment is arguably as important as the aggregate network hashrate.
  3. Their last sentence does not make much sense.  How to define a hobbyist?  If a hobbyist is defined as an individual who can afford to spend $4,195… then they can probably also buy ASIC equipment as well for other cryptocurrencies, including Ethereum today.

On p. 188 they write:

This range is a good baseline for the innovative investor to use for other cryptoassets to ensure they are secured with a similar level of cpaital spend as Bitcoin and Ethereum, which are the two best secured assets in the blockchain ecosystem.

There is another appearance of the “innovative investor,” remove in next edition?

Also, if security is solely measured by hashrate then yes, Bitcoin (BTC) and Ethereum (ETH) might be the “best secured.”  But that assumes a purely Maginot Line attack and not a BGP or wrench attack.

On p. 189 they write:

Overall, hash rate is important, but so too is decentralization. After all, if the hash rate is extremely high but 75 percent of it is controlled by a single entity, then that is not a decentralized system. It is actually a highly centralized system and therefore vulnerable to the whims of that one entity.

This probably should come at the beginning of the chapter, not in this location.  Also recommend adding some citations to the Onename and BGP posts.

On p. 189 they write:

It’s apparent that Litecoin is the most centralized, while Bitcoin is the most decentralized. A way to quanitfy the decentralization is the Herfindahl Hirschman Index (HHI), which is a metric to measure competition and market concentration.

HHI is used with known, legally identifiable parties.  With cryptocurrencies such as Bitcoin, Litecoin, and Ethereum — the mining entities were not originally supposed to be known at all — over time they self-doxxed themselves.104

Should the Department of Justice and similar organizations coordinate and carry out HHI analysis on mining pools to prevent monopolization, oligopolization, and/or coordination?   What happens if participants refuse to comply?

On p. 191 they write:

Blockchain networks should never classify as a highly concentrated marketplace, and ideally, should always fall into the competitive market place category.

Okay, but what if they don’t and no one cares?  Who should enforce this?

Recommend reading a relevant paper published this past winter: Decentralization in Bitcoin and Ethereum Networks

On p. 193 they write:

At times, Bitcoin has been a moderately concentrated marketplace, just as Litecoin mining is currently a moderately concentrated marketplace. Litecoin recognizes the impact that large mining pools can have on the health of its ecosystem and the quality of its coin. To that point, Litecoin developers have instituted an awareness campaign called “Spread the Hashes” for those mining litecoin to consider spreading out their mining activies. The campaign recommends that litecoin computers mine with a variety of mining pools rather than concentraing solely in one.

The anthropomorphism needs to be removed in the second edition.  “Litecoin” does not recognize anything because Litecoin is not a singular autonomous entity.

There are individual people, developers who work on a certain implementation of Litecoin that may promote something — and if they coordinate (which they do) then perhaps they could be classified as administrators.

Either way, this “Spread the Hashes” campaign didn’t seem to work:

Source: Litecoinpool.org visited on July 11, 2018

As the pie chart above illustrates, just 5 entities currently account for about 90% of the network hashrate.  And the largest 3 effectively could coordinate to control the network if they wanted to.

Worth noting that similar marketing campaigns to “spread the hashes” have been done on other networks.  Back in 2014 when GHash.io reached the 50% mark, reddit was filled with discussions imploring miners to switch to P2Pool.

Why don’t miners move to smaller pools?  Two words: reliable revenue.  Recommended reading: The Gambler’s Guide To Bitcoin Mining

On p. 194 they write:

Not all nodes are made equal. A single node could have a large number of mining computers behind it, hence capturing a large percentage of the overall network’s hash rate, while another node could have mining computer supporting it, amounting to a tiny fraction of Bitcoin’s hash rate.

Sort of.  There are two different nodes: nodes that fully validate and attempt to append the blockchain by submitting a proof-of-work that meets the necessary difficulty threshold… and nodes that don’t.  In practice, today we call the former “mining pools” and the latter, just nodes.

For instance, in Bitcoinland there was a vicious war of words from 2015-2017 waged by several parties who did not operate mining pools, or nodes that generated proofs-of-work.105  One subset of these parties used various means and channels to insist that miners did not ultimately matter, that it was “users” who truly controlled the network and they labeled themselves “UASF.”  And some of the most vocal members of this “populism wing” insisted that the nodes run by mining pools were no more important than the nodes run by some hobbyist in an apartment.

The views were irreconcilable and the ultimate result is that one group involved in that battle, forked off and created a new chain called Bitcoin Cash (BCH), whereas many of the other parties coalesced with what is called Bitcoin (BTC).  There is a lot more to the story, a messy emotional divorce that still continues today.

Technically the decision to fork or not fork is made by mining pools and the nodes they each manage, but there are more nuances and politics involved that go beyond the scope of this review.

On p. 194 they write:

William Mougayar, author of The Business Blockchain, has written extensively about how to identify and evaluate new blockchain ventures and sums up the importance of developers succinctly: “Before users can trust the protocol, they need to trust the people who created it.” As we touched upon in the prior chapter, investigate the prior qualifications of lead developers for a protocol as much as possible.

Two problems with this:

  1. I wrote a lengthy book review of Mougayar’s book and found it disappointing and do not recommend because of statements like the one above.
  2. What were Satoshi’s qualifications?  No one knows, but no one really cares either.  Similarly, what were Vitalik Buterin’s qualifications?  He was 19 when he announced Ethereum at Bitcoin Miami and had recently dropped out of college.  Similarly, Gavin Wood was a 34 year-old developer building music-related apps prior to co-founding Ethereum.  Would these two key guys been deemed qualified?  What are the qualifications necessary to be a blockchain wizard?

On p. 194 they write:

Developers have their own network effect: the more smart developers there are working on a project, the more useful and intriguing that project becomes to other developers. These developers are then drawn to the project, and a positively reinforcing flywheel is created. On the other hand, if developers are exiting a project, then it quickly becomes less and less interesting to other developers, ultimately leaving no one to captain the software ship.

A couple of thoughts:

  1. This is a nice sounding theory, but that’s not really what happens with most of these projects.  Generally developers are attracted due to the compensation they can receive… they do a risk-reward analysis.  I’ve met and spoken to dozens, perhaps north of 100 cryptocurrency-related teams in the past 12 months across the globe.  Attracting talented developers is not nearly as easy and clear cut as the authors make it sound above.
  2. Also, having a single “captain of the ship” seems like a single point of failure and a centralization risk.  Is that part of the undefined ethos?

On p. 195 they write:

Recall that this is how Litecoin, Dash, and Zcash were created from Bitcoin: developers forked Bitcoin’s code, modified it, and then re-released the software with different functionality. Subscribers refer to people wanting to stay actively involved with the code. In short, the more code repository points, the more developer activity has occured around the cryptoasset’s code.

That’s not necessarily true, and in fact, has been gamed by coin issuers who want to make it look like there is a lot of independent activity and traction with developers… by creating spam accounts and very small changes to simple documents (like grammar).

It can be a helpful metric but you need someone technically inclined to dive into the code that is being added/removed/modified.  See: Increased Github Scrutiny Means Lazy ICO Developers Have No Place to Hide

Readers may also be interested in CoinGecko to see how this acitivity is weighted.

On p. 198 they write:

A different approach is to monitor the number of companies supporting a cryptoasset, which can be done by tracking venture capital investments. CoinDesk provides some of this information as seen in Figure 13.13. Though as we will address in Chapter 16 on ICOs, the trend in this space is moving away from venture funding and toward crowdfunding.

Actually, as mentioned a couple time earlier, there has been a noticeable divergence the past 12 months: coin sales that are done as private placements versus coin sales that have a public facing sale.

In general, most of the coins that have raised capital through private placement deals typically have less than 100 investors, many of which are the aforementioned “crypto hedge funds” and coin-focused venture funds such as Andreessen Horowitz and Union Square Ventures.

The public facing sales are generally eschewed by venture funds.  If venture funds are involved in a coin that does a public sale, they typically are involved in what is called a “pre-sale” where they receive preferential terms and conditions, such as discounted coins.

Upon the conclusion of the “pre-sale” the actual public sale begins with heavy marketing on social media towards retail investors.  Sometimes these sales have hundreds or even thousands of individual participants.  That could be called a “crowdsale” and these participants typically get worse terms than those who participated in the pre-sale.

On p. 199 they write:

Another good proxy for the increased acceptance of a cryptoasset and its growing offering by highly regulated exchanges is the amount of fiat currency used to purchase it.

Maybe consider revising because we have all been told that cryptocurrencies would not only displace “fiat currency” but also topple and replace the existing financial system… how does measuring these new internet coins with old money help achieve that?

For instance, at the time of this writing none of the US-based retail exchanges with domestic bank accounts have recently listed an ICO (with the exception of ETH and ETC).  This includes: itBit, Bitflyer, Coinbase, and Gemini.106  Kraken’s retail exchange uses payment processors and banking partners outside of the US.107

On p. 199 they write:

in the one-year period from March 2016 to March 2017, ether went from being traded 12 percent of the time with fiat currency to 50 percent of the time. This is a good sign of the maturation of an asset, and shows it is gaining wider recognition and acceptance.

Why is that specific ratio or percentage deemed good?  The next edition should include a table explaining this in further because it is unclear why it is good, neutral, or bad.

On p. 201 they write about wallets from Blockchain.info:

Clearly, having more users that can hold a cryptoasset is good for that asset: more users, more usage, more acceptance. While the chart shows an exponential trend, there are a few drawbacks for this metric. For one, it only shows the growth of Blockchain.info’s wallet users, but many other wallet providers exist. For example, as of March 2017, Coinbase had 14.2 million wallets, on par with Blockchain.info. Second, an individual can have more than one wallet, so some of these numbers could be due to users creating many wallets, a flaw which extends to other wallet providers and their metrics as well.

In the past I have written extensively on how these headline wallet numbers are basically gimmicks and don’t accurately measure users or user activity.

Why?  Because it costs nothing to open one.  And often there is no KYC or AML involved in creating one as well.  As a result, bots can be used to create many each day to inflate the metric.

Coinbase has actually removed usage data in the past and they still don’t define what the difference between a user or wallet is.  Nor do either company provide traditional DAU / MAU metrics.  It’s not hard to do and it is unclear why they don’t.  The only way we have some semblance of an idea of what Coinbase user numbers were between 2013-2015 is because of the IRS lawsuit mentioned above.

On p. 201 they write about a search trend, “BTC USD,” first described by Willy Woo:

If we assume this to be true, then Woo’s analysis indicating a doubling in bitcoin users every year and an order of magnitude growth every 3.375 years. He calls this Woo’s Law in honor of Moore’s Law […] It will be interesting to see how Woo’s Law holds up over time.

How has it done?  “Woo’s Law” has thus far not held up.

For instance, below is a 5 year trend chart of the same search term promoted by Woo and others last year:

As we can see above, this term has some correlation between interest in coins specifically during price bubbles.  But this has not translated into large quantities of new daily users.108

The next edition of this book should remove this faux eponym because it has not withstood the test of time and doesn’t measure actual users.

On p. 202 they write:

Figure 13.17 shows the hyper growth of Ethereum’s unique address count. With Ethereum, an address can either store a balance of either, like Bitcoin, or it can store a smart contract. Either denotes an increase in use.

Below is a screenshot of a recent address count:

Source: Etherscan

The next edition should include a caveat because it is unclear from this chart alone what kind of use is taking place.  Is it coin shuffling, miner payouts, gambling payouts, Crypokitty activity, etc.?  Maybe it is just someone spamming the network?

For instance, according to DappRadar which tracks 650 ethereum Dapps, over the past 24 hours there have only been 9,926 users sending 43,652 transactions.  That may sound intriguing but… nearly about 2/3rd of all these users are using decentralized exchanges (DEX).  If trading and arbitraging are the “killer apps” of cryptocurrencies, then the next edition of this book could be a lot slimmer than it is now.

As described in “Slicing data,” not all transactions are the same and a deep dive needs to be done to fully describe the behavior taking place.

On p. 204 they cite a “Dollar Value of Transactions” chart:

Source: Blockchain.info

But this is just an estimate from Blockchain.info and is likely widely exaggerated because Blockchain.info — like most wallet providers — probably has no idea what the intent behind those transactions are.  We need data from all of the exchanges, payment processors, and merchants that accept coins in order to conclusively know what activity was commercial versus non-commercial in nature.

For instance, a large portion of those transactions could simply be “change address.”

Not to get too technical, but with Bitcoin, in order to manually send X amount of bitcoin on-chain, users typically must enter a “change address” unless the whole amount of UTXO is consumed.  It’s kind of like a bank teller moving money from one till to another between shifts.  No new economic activity is actually taking place in the bank or in the real economy, but in this specific chart above, there is no way to differentiate “change address” activity with real commercial activity and so it all gets mixed and muddied.

On p. 204 they write:

If the network value has outpaced the transactional volume of that asset, then this ratio will grow larger, which could imply the price of the asset has outpaced its utility. We call this the crypto “PE ratio,” taking inspiration from the common ratio used for equities.

Except, without a thorough deep dive from an analytics provider who has mapped out activity into all of the exchanges, payment processors, and merchants — it is very difficult to actually differentiate the noise from the actual transactional utility.109

Here the authors take all on-chain transaction volume at face value.  The next edition should scrap this section unless they get access to a thorough deep dive.

On p. 204 they write:

One would assume that an efficient price for an asset would indicate a steadiness of network value to the transaction volume of the asset. Increasing transactional volume of an asset should be met by a similar increase in the value of that asset. Upside swings in pricing without similar swings in transaction volume could indicate an overheating of the market and thus, overvaluation of an asset.

That is a popular model but could be incorrect.

I recommend readers check-out this excellent recent thread started by Nathaniel Popper as well as Debunking Bitcoin’s Remittance Valuation. Featuring a Lead Pipe by Anshuman Mehta.

On p. 207 they write about technical analysis:

In Figure 13.22 the top line is called the resistance line, indicating a price that bitcoin is having trouble breaking through. Often these lines can be numbers of psychological weight, in this case the $300 mark.

I looked it up and couldn’t find a definition for what “psychological weight” is, so this should either be defined in the book or removed in the next edition.110

On p. 209 they write:

You’ll find many instances of newer cryptoassets experiencing wild price swings after their creation, but over time these younger assets begin to follow the rules of technical analysis. This is a sign that these assets are maturing, and as such, are being followed by a broader group of traders. This indicates they can be more fully analyzed and evaluated using technical analysis, allowing the innovative investor to better time the market and identify buy and sell opportunities.

Technical analysis may have its uses but by itself it is basically cargo cult science.

Recommend rephrasing it and maybe inserting this great reference: The Vomiting Camel has escaped from Bitcoin zoo

Chapter 14

On p. 211 they write:

Since cryptoassets are digital bearer instruments, they are unlike many other investments that are held by a centralized custodian. For example, regardless of which platform an investor uses to buy stocks, there is a centralized custodian who is “housing” the assets and keeping track of the investor’s balance. With cryptoassets, the innovative investor can opt for a similar situation or can have full autonomy and control in storage. The avenue chosen depends on what the innovative investor most values, and as with much of life there are always trade-offs.

This is true: there are many choice.  But in practice, as noted above by Jonathan Levin, a significant majority of transactions typically involves a 3rd party intermediary.

Why?  Because Securing a bearer instrument can be a major hassle, as a result companies like Coinbase and Xapo offer custodial services.  While re-introducing an intermediary helps with coin management that kind of defeats the purpose of having a pseudonymous bearer asset in the first place.111 But that’s a different discussion.112

On p. 212 they write:

Anyone with a computer can connect to Bitcoin’s network, download past blocks, keep track of new transactions, and crunch the necessary data in pursuit of the gold hash. Such open architecture is one of Bitcoin’s strongest points.

It may sound like a irrelevant nitpick but this is not unique to Bitcoin.  Nearly every cryptocurrency listed on Coinmarketcap has the same set of “features.”  Similarly, many enterprise vendors also are open source and anyone could set up their own network with the software.  Future editions should include a more nuanced definition of “open.”

On p. 213 they write:

The first computer – or mining rig – with ASIC chips that were specifically manufactured for the process was connected in January 2013.

The citation the authors included was for Avalon.  This is true insomuch as these systems were available for purchase to the general retail public.  But the first known ASIC-mining system was launched in late 2012: ASICMiner privately run out of Hong Kong (from BitQuan and BitFountain). 113

On p. 214 they write:

For perspective, the combined compute power of Bitcoin’s network is over 100,000 times faster than the top 500 supercomputers in the world combined.

This type of stat is frequently repeated throughout the Bitcoin world but it is not an apples-to-apples comparison and should be removed in the next edition.  The supercomputers are largely comprised of CPUs and GPUs which — as their names suggest — are flexible and capable of handling many different types of general purpose tasks.

ASICs on the other hand, are focused and specialized: capable of doing just one set of tasks over and over.  ASICs found in a Bitcoin mining farm are not even capable of creating blocks to propagate on the network: they simply generate hashes.  That is how limited they are in functionality.

On p. 214 they write:

Conceptually, mining networks are a perfect competition, and thus as margins increase, new participants will flood in until economic equilibrium is once again achieved. Thus the greater the value of the asset, the more money miners make, which draws new miners into the ecosystem, thereby increasing the security of the network. It’s a virtuous cycle that ensures the bigger the network value of a cryptoasset, the more security there is to support it.

I think this could be rewritten in the next edition to be closer with what happens in practice.114

For instance, as coin prices decrease, margins are squeezed and “marginal” operators exit, leaving fewer overall miners.  In the past this has led to bankruptcies, such as KnC and HashFast.

Does this lead to a less secure network?

Maybe, maybe not.  Depends on how we define secure and insecure.  Pure hashrate is just one attribute… geographical location, amount of participants, and diversity of participants could be others as well.  For example, see the discussion earlier on selfish-mining.

On p. 215 they write:

Before investing in a cloud-based mining pool, conduct research on the potential investment. If it sounds too good to be true, it probably is.

This is good advice.

Also worth mentioning that “cloud-based mining” kind of the defeats the purpose of pseudonymous mining.  If you have to trust the infrastructure provider to manage and operate the hashing equipment, why not just buy the coins?  Why take that risk and also have to divulge your identity?

Incidentally, NiceHash is one of the most well-known cloud mining services available today.  It partly cemented its notoriety (this is not an endorsement) as its mining units have been rented and used to attack several different cryptocurrencies.  A site called Crypto51.app categorizes the costs of doing a brute force attack on dozens of coins and even lists the amount of hashrate NiceHash has in order to perform a hypothetical attack.

On p. 216 they write:

However, Ethereum will potentially switch to proof-of-stake early in 2018, as it is more efficient from an energy perspective, and therefore many claim is more scalable.

Quick note: this transition has been delayed again until at least the end of 2018 and more likely sometime in 2019 (although it has been moved many times before as well).

On p. 217 they write:

To this end, today numerous quality exchange are available to investors looking to gain and transact the more than 800 cryptoassets that currently exist.

In the next edition it is worth clarifying and defining what “quality” means because just about every retail / consumer-facing exchange has had its share of problems, including hacks and thefts.115 This is one of the reasons the SEC has denied ETF proposals.

With that said, there are a number of OTC trading desks run by reputable financial organizations that enable investors to trade, however, typically the minimum order size (buy/sell) is $100,000.116

On p. 218 they write:

Cryptoasset transactions are irreversible; therefore chargebacks are impossible. While an irreversible transaction may sound scary, it actually benefits the efficiency of the overall system. With credit card chargebacks, everyone has to bear the cost, whereas with cryptoassets only those who are careless bear the cost.

Two comments worth considering for the next edition:

  1. Transactions in cryptocurrencies are possible through block reversals, which can and do happen.  Often times they are relatively expensive to do, but during a “51% attack” it can occur, thus it is not impossible.  In fact, as part of the Nano class action lawsuit, one of the suggested remedies is a roll-back.
  2. As far as credit card chargebacks: this is largely borne by the merchant (not everybody).  In fact, charge backs are largely a consumer-friendly feature, a type of insurance.117

On p. 221 they discuss insurance at exchanges.

At this time, no retail cryptocurrency exchange actually insures a users coin deposit.  As a result, most custodians and intermediaries have had to self-insure (e.g., create their own insurance entity).  There are institutional products (vaults) which are attempting to get 3rd party insurance.

For example, see: Insurers gingerly test bitcoin business with heist policies

On p. 224 they write:

Prior to the hack, Bitfinex had settled with the CFTC for $75,000 primarily because its cold storage of bitcoin ran afoul of CFTC regulations. The move to place all clients’ assets into hot wallets is cited by many as due to the fine and CFTC regulations. Either way, this hack proved that no matter the security protocols put in place, hot wallets are always more insecure than properly executed cold storage because the hot wallet can be accesssed from afar by anyone with an Internet connection.

This passage should be revised in the next edition for a few reasons:

First, as mentioned earlier, Bitcoiners like to find a good boogeyman and in this hacking incident, they blamed the CFTC.

For example, Andreas Antonopoulos tweeted:

Source: Twitter

Several people told him he got the facts wrong.

For instance, I reached out to Zane Tackett who — at the time — was head of communications for Bitfinex.

According to Tackett: “We migrated to the bitgo setup before any discussions or anything with the CFTC happened”

I then publicly pointed out, to Antonopoulos and others, that the CFTC blame game was false.  But instead of deleting that tweet and focusing on who actually hacked Bitfinex, the ideological wing of the Bitcoin tribe continues to push this false narrative.

Tackett even explicitly answered this question in detail on reddit that same day.

So either Tackett is lying or Antonopoulos is wrong.  In this case, it is likely the latter.

The second point worth adding to the passage above in the book is that after nearly two years we still haven’t been told exactly what happened with the hack and theft.  This, despite the fact that Bitfinex has said on more than one occasion that it would provide an audit and public explanation.

Incidentally, this hack and the response, set in motion a series of events that included socialized loses, a lost correspondent banking relationship, and even a heightened reliance on Tether.118 For more, see: How newer regtech could be used to help audit cryptocurrency organizations

Chapter 15

On p. 231 they write:

Founded by Barry Silbert, a serial entrepreneur and influential figure in the Bitcoin community, some would say that DCG is in the early stages of becoming the Berkshire Hathaway of Bitcoin.

Perhaps DCG achieves that, however it hasn’t been done in a classy manner.  For example, see: Ex-banker cheerleads his way to cryptocurrency riches and Barry Silbert and the Cost of Bitcoin’s Malfeasance Culture

On p. 235 they write

An ETF is arguably the best investment vehicle to house bitcoin.

This is debatable.  Last year Jack Bogle – founder of Vanguard, a firm that popularized broad market index ETFs – implored the public to avoid bitcoin like the plague for several reasons.  Critics say he is out of touch, but even if that were true that doesn’t mean his expert views on structuring ETFs should be dismissed.

On p. 238 they write:

Regardless of what people expected going into the SEC decision most everyone was taken aback by the rigidity of the SEC’s rejection. Notably the SEC didn’t spend much time on the specifics of the Winklevoss ETF but focused more on the overarching nature of the bitcoin markets. Saying that these markets were unregulated was an extra slap to the Winklevosses, who had spent significant time and money on setting up the stringently regulated Gemini exchange. In focusing on the bitcoin markets at large, the rejection implied that an ETF will not happen in the United States for some time.

For the next edition, this paragraph should probably be removed.

The facts of the Bitcoin markets today are as follows:

  1. Mining is the process of minting new coins as well as processing transactions and… is largely unregulated in any jurisdiction.
  2. Many exchanges, in particular those outside the US, comply with a hodge podge of regulations, often without the same strict KYC / AML / sanctions checks required for US exchanges.

Gemini and the Winklevoss have no ability to police these unregulated trading venues and unregulated coin minters.  That probably won’t change in the near future.

Perhaps the SEC will eventually approve an ETF, but they arguably were not being rigid — they were being practical.  In their view: why allow an unregulated asset whose underlying genesis and trading market is still very opaque and frequently is used for illicit activity?

Lastly the next edition should include a citation for who “most everyone” includes, because in my own anecdotal experience, the majority of traders at US exchanges I interact with did not think it would be allowed at that time.  Note: my deep dive on the COIN ETF and its ever changing history, can be found here.

On p. 238 they write:

On Monday, naysarers were faced with the reality that bitcoin was once again back over $1,200, and the network for all cryptoassets had increased $4 billion since the SEC decision. Yes, $4 billion in three days.

A couple of thoughts:

  1. Typo: naysarers should be naysayers
  2. Recommend removing this sentence in the next edition because the attitude comes off as a little smug and has an ad hominem.  People are allowed to have different views on the adoption of technology which is separate from what the price of a coin will be.  And justifying a trading position based on price movements which are based on the mood of retail investors should probably not be the takeaway message for a mainstream book.

On p. 240 they write:

By purchasing XBT Provider, GABI strengthened the reliability of the counterparty to the bitcoin ETNs and added a nice asset to its growing bitcoin investing platform for institutions.

For the next edition, recommend removing “nice” because that is a subjective word.  There are other ways to describe this acquisition.

On p. 242 they write:

It also created an independent advisory committee, including bitcoin evangelist Andreas Antonopoulos to oversee its pricing model, which utilized prices from various exchanges throughout the world.

Why is this specific person considered an expert on futures?  There are a lot of articulate developers involved in promoting cryptocurrencies, but their expertise is typically not in finance.  If anything, this specific person has a vocal disdain for regulators, financial institutions, and regulated instruments… just see his tweet above in Chapter 14.119

Maybe in the next edition discuss the controversy of having a futures contract that is not physically deliverable.  Could also include how the CFTC has subpoenaed the four partner exchanges working with the CME: Coinbase, Kraken, itBit, and Bitstamp.  These four exchanges create the price used in bitcoin futures by the CME.

Chapter 16

On p. 249 they write:

For first-time founders who want to approach venture capitalists for an investment, often they must know someone-who-knows-someone. Having such a connection allows for a warm introduction as opposed to being among the hundreds of cold calls that venture capitalists inevitably receive. To know someone-who-knows-someone requires already being in the know, which creates a catch-22.

This is a very good point.  However, it would be worth adding in the next version how most ICOs and coin sales now require knowing someone because most private sales involve roughly the same insular, exclusive set of funds and investors as the “old method” did.

On p. 252 they write:

Before we dive into the specifics of how a cryptoasset offering is carried out, the innovative investor needs to understand that the model of crowdfunding cryptoassets is doubly disruptive. By leveraging crowdfunding, cryptoasset offering are creating room for the average investor to stand alongside venture capitalists, and the crowdfunding structure is potentially obviating the need for venture capitalists and the capital markets entirely.

In the next edition, worth mentioning that this was the general pitch for ICOs starting with Mastercoin (2013) all the way up through 2016.  But over the past two years and certainly in the past 12 months it has dramatically shifted back towards the traditional venture route.

One of the reasons why is because of the filtering and diligence process.  Those that don’t get selected and/or those ICOs that don’t meet the requirements of this small group of funds often decide to do a public sale.  And many of these ideas were half-baked and sometimes fraudulent, according to one recent report: More Than Three-Quarters of ICOs Were Scams

On p. 253 they write:

Monegro’s thesis is as follows: The Web is supported by protocols like the transmission control protocol/Internet protocol (TCP/IP), the hypertext transfer protocol (HTTP), and simple mail transfer protocol (SMTP), all of which have become standards for routing information around the internet. However, these protocols are commotidized, in that while they form the backbone of our internet, they are poorly monetized.

It could be argued that Monegro’s thesis has failed to live up to its hype thus far.  And counterfactually, if “tcpipcoin” existed, it may have actually stunted the growth of the internet as Vinton Cerf and Bob Kahn would have allocated more time promoting the coin rather than the technology.    We can disagree about this alternative scenario, but I have mentioned it before in Section 8.

For example, we frequently see that dozens of nonsensical conferences and meetups conducted on a weekly basis globally try to promote a shiny new protocol coin of some kind.  Trying to monetize a public good with a coin thus far has not removed the traditional incentive and sustainability issues around a public good.  That would also be worth discussing in the next edition.120

On p. 253 they write:

All the applications like Coinbase, OpenBazaar, and Purse.io rely on Bitcoin, which drives up the value of bitcoin.

Worth updating this because Purse.io added support to Bitcoin Cash.  And OpenBazaar switched over to Bitcoin Cash altogether.

Also, Coinbase has become less maximalist over time and now provides trading support for four different coins.121  Though it probably wouldn’t be technically correct to call Coinbase or Purse a Bitcoin application.  In the case of Coinbase, users use an off-chain database to interact and Coinbase controls the private key as a custodian / deposit-taking institution.

On p. 254 they write:

Interestingly, once these blockchain protocols are released, they take on lives of their own. While some are supported by foundations, like the Ethereum Foundation or Zcash Foundation, the protocols themselves are not companies. They don’t have income statements, cash flows, or shareholders they report to. The creation of these foundations is intended to help the protocol by providing some level structure and organization, but the protocol’s value does not depend on the foundation.

This is another reason to heavily modify chapter 7 in future versions because it is not an apples-to-apples comparison: coins and coin foundations are not the same thing as for-profit companies that issue regulated instruments (stocks, bonds, etc.).

Also, the very last sentence is highly debatable because of how often foundation and foundation staff are integral to the longevity of a coin.

Recall that blockchains do not maintain or market themselves, people do.  And is often the case: staff and contractors of these foundations frequently use social media to promote potential upgrades as well as publicize the coins attributes to a wider audience.  In many cases it could be the case that the protocol’s value does depend on the work and efforts of others including specifically those at a coin foundation.122

On p. 254 they write:

Furthermore, as open-source software projects, anyone with the proper merits can join the protocol development team. These protocols have not need for the capital markets because they create self-reinforcing economic ecosystems. The more people use the protocol, the more valuable the native assets within it become, drawing more people to use the protocol, creating a self-reinforcing positive feedback loop. Often, core protocol developers will also work for a company that provides application(s) that use the protocol, and that is a way for the protocol developers to get paid over the long term. They can also benefit from holding the native asset since inception.

There are several points here that should be modified or removed in the next edition:

For instance, with Bitcoin, due to a variety of political fights and personality conflicts, multiple “core” developers have had their access rights removed including: Jeff Garzik, Mike Hearn, Gavin Andresen, and Alex Waters.  Thus it is not true that anyone can join a team.  It is also unclear what those merits may be as most of the projects don’t explicitly provide those in written format yet.

In addition, internet coins are often traded on secondary markets in order to provide liquidity to coin holders such as developers.  They all need access to capital markets to stay afloat.  No project is self-sustainable at this time because no coin is being used as a unit of account — miners and developers must liquidate coins in order to pay their bills which are denominated in foreign currency.

Lastly, in practice, there are many coins that have died or lost any developer support yet initially they may have had a small army of programmers and media attention.  According to Coinopsy, more than 1,000 coins are dead.  Thus in the next edition the “self-reinforcing” loop should probably be removed too.

On p. 256 they write:

ICOs have a fixed start and end date, and often there is a bonus structure involved with investing earlier. For instance, investing at an early stage may get an investor 10 to 20 percent more of a cryptoasset. The bonus structure is meant to incentivize people to buy in early, which helps to assure that the ICO will hit its target offering. There’s nothing like bonuses followed by scarcity to drive people to buy.

This should definitely be removed.  In May, the SEC released a parody website called “HoweyCoins” which explicitly points to this precise FOMO behavior as a big no-no for both issuers and investors alike.

Also recommend the inclusion of the Munchee Order in this chapter as it would help illustrate what regulators such as the SEC perceive as improper fundraising techniques.  Specifically, include this in the “announcing the ICO” section.

On p. 258 and 259 they discuss the Howey Test.  It is strongly recommended that these two pages be reworded and modified based on the enforcement actions and guidance from the SEC and other securities regulators.

For instance, they write:

A joint effort by Coinbase, Coin Center, ConsenSys, and Union Square Ventures with the legal assistance of Debevoise & Plimpton LLP, produced a document called, “A Securities Law Framework for Blockchain Tokens.” It is especially important for the team behind an ICO to utilize this document in conjunction with a lawyer to determine if a cryptoasset sale falls under SEC jurisdiction. The SEC made it clear in July 2017 that some cryptoassets can be considered securities.

The first sentence should probably be moved into a footnote and the second sentence removed altogether because this document did not age well.

In fact, the current version of the document – as it exists on Coinbase – informs readers in bright red that:

Please note that since this document was originally published on December 7, 2016, the regulatory landscape has changed. The information contained in this document, including the Framework may no longer be accurate. You should not rely on this document as legal advice and you should seek advice from your own counsel, who is familiar with the particular facts and circumstances of what you intend and can give you tailored advice. This Framework is provided “as is” with no representations, warranties or obligations to update, although we reserve the right to modify or change this Framework from time to time. No attorney-client relationship or privilege is created, nor is this intended to be attorney advertising in any jurisdiction.

On p. 259 they write:

Does the token sale tout itself as an investment? It should instead be promoted for its functionality and use case and include appropriate disclaimers that identify it as a product, not an investment.

This is arguably not good advice and should be removed.  Why?  Courts in the US will likely see through this euphemism.  For other things not to do, recommend reading the ICO Whitepaper Whitepaper from Stephen Palley.

On p. 260 they write:

One of the oldest groups of angel investors in the blockchain and bitcoin space is called BitAngels. Michael Terpin of BitAngels has been active in angel investing in blockchain companies for as long as the opportunities have existed. Terpin’s annual conference, CoinAgenda, is one of the best opportunities for investors to see and hear management from blockchain startups present their ideas and business models.

For the next edition, I’d reconsider including this type of endorsement.123 There are some interesting stories that involving these specific entities worthy of a different post.

Chapter 17

On p. 263 they write:

For instance, if Bitcoin influences how remittances are handled, what impact may that have on stocks like Western Union, a remittances kingpin? If Ethereum takes off as a decentralized world computer, will that have any effect on companies with cloud computing offerings, such as Amazon, Microsoft, and Google? If companies can get paid more quickly with lower transaction fees using the latest cryptocurrency, will that have an impact on credit card providers like Visa and American Express.

For the next edition, this paragraph — or at least argument — should come earlier, perhaps even in Chapter 7 (since there is a discussion of specific publicly traded companies).

Another thing that should have been added to this section is actual stock prices for say, the past five years of the companies mentioned: Western Union, Visa, and American Express.

I have included those three below:

If the narrative is that Bitcoin or the “latest cryptocurrency” will erode the margins and even business models of existing payment providers, then at some point that should be reflected in their share prices.

As shown above, that does not seem to be the case (yet).

Perhaps that will change in the future, but consider this: all three of the companies above have either directly invested in and/or are collaborating in blockchain-related platforms — most of which do not involve any coin.  Perhaps these firms never use a blockchain.  In fact, maybe they find blockchains to be unhelpful as infrastructure altogether.

That is possible, hence the need to update this chapter to reflect the actual realities.

In addition, the other three companies listed by the authors have publicly discussed various blockchain-related efforts beyond just pilot offerings.

For instance, both Amazon and Microsoft have supported blockchain-as-a-service (BaaS) offerings in production for over a year.  Google has been a laggard but has internal projects attempting to leverage some of these ideas as well.

On p. 266 they write:

In 2016, the father-son team of Don and Alex Tapscott published the book Blockchain Revolution: How the Technology behind Bitcoin Is Changing Money, Business, and the World, and William Mougayar published the book, The Business Blockchain: Promise, Practice, and Application of the Next Internet Technology.

I wrote lengthy reviews of both.  The short summary is that both were fairly superficial in their dive into use cases and vendors.  The Mougayar book felt like it could use a lot more detailed meat.  The Tapscott book was riddled with errors and unproven assertions.  Would reconsider citing them in the next edition (unless they each dramatically update their content).

On p. 266 they write:

For companies pursuing a DLT strategy, they will utilize many of the innovations put forth by the developers of public blockchains, but they don’t have to associate themselves with those groups or share their networks. They pick and choose the parts of the software they want to use and run it on their own hardware in their own networks, similar to intranets (earlier referred to as private, permissioned blockchains).

These are pretty broad sweeping comments that should be modified in the next edition.  Not every vendor or platform provider uses the same type of chain or ledger.  These are not commoditized (yet).

There are many nuances and trade-offs for each platform.  For the next edition, it would be helpful worth doing a comparison of: Fabric, Pantheon, Quorum, Corda, and other enterprise-focused platforms.  In some cases, they may have an on-premise requirement and in others, nodes can run in a public cloud.

But the language of “intranets and the internet” should not be used in the next edition as it is a misleading analogy.

On p. 267 they write:

We see many DLT solutions as band-aids to the coming disruption. While DLT will help streamline existing processes–which will help profit margins in the short term–for the most part these solutions operate within what will become increasingly outdated business models.

Perhaps that it is true, but again, this language is very broad sweeping and definitive.  It needs citations and references in the next edition.

On p. 267 they write:

The incumbents protect themselves by dismissing cryptoassets, a popular example being JPMorgan’s Jamie Dimon, who famously claimed bitcoin was “going to be stopped.” Mr. Dimon and other financial incumbents who dismiss cryptoassets are playing exactly to the precarious mold that Christensen outlines:

[…]

Disruptive technologies like cryptoassets initially gain traction because they’re “cheaper, simpler, smaller.” This early traction occurs on the fringe, not in the mainstream, which allows incumbents like Mr. Dimon to dismiss them. But cheaper, simpler, smaller things rarely stay on the fringe, and the shift to mainstream can be swift, catching the incumbents off guard.

For the next edition it would be good to remove the misconceptions repeated in the statement above.  Jamie Dimon was specifically dismissing the exuberance of coin mania, not the idea of enhancing IT operations with something like a blockchain.

Worth adding to future versions: JPMorgan has financial sponsored Quorum, an open-source fork of Ethereum modified for enterprise-related uses.  The bank has also invested in Digital Asset.  It is also a member of three industry organizations: EEA, Hyperledger, and IC3.  In addition, JP Morgan has filed blockchain-related patents, has launched a blockchain-based payment network with several banking partners, and also partnered with the parent company of Zcash to integrate ZSL into Quorum.

While Jamie Dimon may not share the same bullish views about coins as the authors do, the firm he is the CEO seems to be taking “blockchains” seriously.

On p. 267 they write:

One area long discussed as ripe for disruption is the personal remittances market, where individuals who work outside of their home countries send money back home to provide for their families.

This specific use case is a bit repetitive as it has been mentioned 5-6 times before in other chapters.  Should probably remove this in future editions unless there is something different to add that wasn’t already explained before.

On p. 268 they write:

It’s no stretch then to recognize that bitcoin, with its low cost, high speed, and a network that operates 24/7, could be the preferred currency for these types of international transactions. Of course, there are requirements to make this happen. The recipient needs to have a bitcoin wallet, or a business needs to serve as an intermediary, to ultimately get the funds to the recipient. While the latter option creates a new-age middleman–which potentially has its own set of problems–thus far these middlemen have provided to be much less costly than Western Union. The middleman can be a pawnshop owner with a cell phone, who receives the bitcoin and pays out local currency to the intended recipient.

This should be modified in the next versions because it is a stretch to make those claims.  That is the reason why multiple Bitcoin-focused remittance companies have pivoted or branched out because “moving” bitcoins across borders is the only easy part of the entire process.  For instance, the KYC / AML checks during the on- and off-ramps are costly and are required in most countries.  This should be included in any analysis.

Also, there are no citations in this paragraph.  And the last sentence is describing the pawnshop owner as a money transmitter / money service business which is a regulated operation.  Maybe the laws change, which is possible.  But for the next version, the authors should include specific corridors and the costs and margins for MSBs operating in those corridors.

Lastly, any future analysis on this topic should also include the online and app-based product offerings from traditional remittance players such as Western Union.  In nearly all cases, these products and services are faster and cheaper in the same corridors relative to traditional in-person visits.

Recommended reading:

On p. 268 they write:

The impact of this major disruption in teh remittance market should be recognized by the innovative investor not only because of the threat it creates to a publicly traded company like Western Union (WU) but for the opportunities it provides as well.

It is strange to hear this repeated multiple times without providing quantifiable specifics on how to measure this threat.

As mentioned a few pages earlier, if competitors (including, hypothetically cryptocurrencies) were to erode the margins of publicly traded companies, we should be able to see that eventually reflected in the share price.  But Western Union has been doing more or less the same as it has the past couple of years.

What about others?

Above is the five year performance of Moneygram, another remittance service provider.

What happened the past two years?  Did Bitcoin or another cryptocurrency pound its share value into the ground?  Nope.

What happened is that one of Alibaba’s affiliates – Ant Financial – attempted to acquire Moneygram.  First announced in early January 2017, Ant Financial wanted to acquire it for $880 million.  Despite approval from the Moneygram board, the deal faced scrutiny from US regulators.  Then in January 2018, the deal was axed as the US government blocked the transaction on national security grounds.

This hasn’t stopped Alibaba and its affiliates with finding other areas to grow.  For instance, last month Alipay (part of Ant Financial) announced it had partnered with G Cash to in the Hong Kong – Philippines corridor, using a blockchain platform for remittances.  No coin was needed in this process so far.

There may be some success stories of new and old MSBs that utilize cryptocurrencies in ways that make them more competitive, those should be included in the next edition along with more metrics readers can compare.124

On p. 270 they write:

For the long term investor, careful analysis should be undertaken to understand if insurance companies are pursing DLT use cases that will provide a lasting and meaningful solution. Lastly, some of the major consulting firms may be so entrenched in incumbent ideology that they too may be blind to the coming distruption.

A few comments that should be finnesed in the next version:

  1. What is the definition of “incumbent ideology”?
  2. Virtually every major insurance and reinsurance company is hands-on involved with some kind of blockchain-related consortium and/or enterprise-focused platform.  This includes both B3i and RiskBlock as well as Asia-based reinsurers.  Recommended reading: RiskBlock’s blockchain targets entire insurance industry
  3. Similarly, every major consulting company and systems integrator has a team or two dedicated to helping clients build and integrate applications with specific enterprise-related “blockchain” platforms.  Many of them have joined related consortia too.  There are too many to even list here so it is unlikely they will get collectively blind-sighted as alluded to in the passage above.

On pgs. 272 and 273 they write about consortia:

Another consortium, The Hyperledger Project, offers more open membership than R3. Remember, one of the strengths and defining aspects of an effective blockchain project is its open source ethos.

[…]

While the [EEA] consoritum will work on software outside of Ethereum’s public blockchain, the intent is for all software to remain interoperable in case companies want to utilize Ethereum’s open network in the future.

Based on the passages above the next edition should incorporate a few changes.

The Hyperledger Project (HLP) is a non-profit group that does not itself aim to commercialize or deploy or operate any technology.125 The membership dues are largely used to maintain code repositories and sponsor events which educate attendees on projects incubated within HLP.  It currently has around 200 members, including R3 which was a founding member.  There are more than 5 codebases that are officially incubated, the most well-known is Fabric.  However, HLP seeks to maintain a neutral position on which platform its members should use.  Other notable platforms incubated within HLP include Iroha and Sawtooth (Lake).

In contrast, R3 is a for-profit company that set up a consortium in order to commercialize and deploy technology within the regulated financial industry.126 Its membership model has changed over time and it is the main sponsor for Corda, an open source platform.  The consortium composition initially started with 42 banks and now includes about 200 entities including insurance companies, central banks, financial market infrastructure operators, and others.

The third most known consortium is the Enterprise Ethereum Alliance (EEA).  It is kind of like the combination of the two above.  It is a non-profit organization and itself does not aim to commercialize or deploy or operate any technology.  It seeks to be a neutral entity within the greater Ethereum ecosystem and has many different working groups that span topics similar as the other two consortia above.  It has hundreds of members and the main efforts have been around formalizing an enterprise-focused specification (EEA 1.0) that other vendors can create implementations of (such as Pantheon).

Like the members of the other two consortia above, nothing prevents an EEA member from using any other platform.  Thus the authors usage of “open network” is superfluous because all of the codebases in each of these three consortia is open, anyone can download and use.  The key differences are: what are the trade-offs with using each platform versus what are the benefits of membership for joining the consortia.  These are two separate points that could be discussed further in the next edition.

On p. 276 they write:

The CFTC Director of Enforcement, Aitan Goelman, tried to clarify his opinion with this satement, “While there is a lot of excitement surrounding bitcoin and other virtual currencies, innovation does not excuse those acting in this space from following the same rules applicable to all participants in the commodity derivatives markets.” It is clearly confusing that the Direct of Enforcement of the agency that ruled bitcoin a commodity also called it a “virtual currency.”

For the next edition the authors should remove the unnecessary attitude in the last sentence.

Up through 2017, most US and even foreign regulators used the term “virtual currency” — not as a slight against Bitcoin or cryptocurrencies, but because that was the catchall term of art used for many years.

For instance, in March 2013, FinCEN released its guidance and it was entitled: “Application of FinCEN’s Regulations to Persons Administering, Exchanging, or Using Virtual Currencies”

Throughout the guidance, the term “virtual currency” is used more than 30 times.

And one relevant passage – especially for this book review – involves the definition of an administrator.  According to FinCEN’s guidance:

“An administrator is a person engaged as a business in issuing (putting into circulation) a virtual currency, and who has the authority to redeem (to withdraw from circulation) such virtual currency.”

As it relates to the CFTC, earlier this year a federal judge in New York ruled that: “virtual currencies can be regulated by CFTC as a commodity.”

The ruling (pdf) specifically uses the phrase “virtual currency” not as a slight, but as a term of art.  Perhaps other terms are used over time.  For instance, in its new customer advisory issued this week, the CFTC mentioned potential scams that describe themselves as “utility coins” or “consumption coins.”  Worth revisiting in the next edition.

Chapter 18

On p. 280 they write:

Here’s another Burniske-Tatar Rule: Don’t invest in bitcoin, ether, or any other cryptoasset just because it’s doubled or tripled in the last week. Before investing, be able to explain the basics of the asset to a friend and ascertain if it fits well given the risk profile and goals of your investment portfolio.

This is good advice.  And while the eponymous rule was coined several chapters ago,  future editions should probably drop the name of that rule… because similar advice with slightly different wording has existed for decades (e.g., don’t invest more than you can afford to lose, do your own research, etc.).

On p. 282 they write:

Are millenials turning to bitcoin and cryptoassets for their investment? Is a Vanguard fund or a small investment in Apple any better?  Whereas the Vanguard fund has a minimum investment amount and buying an equity will require commission, millennials see cryptoasset markets as a way to begin investing with a modest amount of money and in small increments, which is is often not possible with stocks or funds.

They also include a footnote that reads:

Each bitcoin can be divided into 100 million units, making it easy to buy 1/2, 1/10, 1/100 or 1/1000 of a bitcoin

Would recommend removing this passage altogether because there really aren’t many good surveys that indicate who actually bought coins versus who was just interested in them.

For instance, a flawed Finder.com survey that is still being cited, says that 8% of Americans have invested in cryptocurrencies.127  While it says the majority of investors are “millenials,” the survey doesn’t ask the most important question: does the investor control the private key.  If you do not control the private key then you do not control the coin, someone else does.

In addition, there are online brokerages that do allow investors to invest with modest amounts, the most notable being Robinhood (which coincidentally also allows users to purchase several different cryptocurrencies).  There are also a variety of spare change investment apps and robo-advisor products that allow users to have some exposure to regulated capital market too.

Lastly, regarding the footnote they provide: due to the fees required by Bitcoin miners, in practice over the past several months 1/1000 of a bitcoin is typically the minimum transaction fee.  This is one reason why many investors simply leave coins on cryptocurrency exchanges: so they don’t have to pay fees to move them to other wallets.128

On p. 282 they write:

The important point is that at least they’re doing something to invest their funds and build the groundwork for a healthy financial future. We have seen firsthand millenials who have learned about investing from buying cryptoassets and have implemented investing approaches, such as taking profits at certain price points, seeking diversification into multiple assets, and so on.

This should probably be removed too because the same thing can be said to a new cohort of investors twenty years ago, such as the ones that invested in dotcom-related companies.  Who remembers Beenz?

Conclusion

I fully expect some reaction towards this review along the lines that it was too picky or too pedantic.  Perhaps this a little true but consider: what is the right size for a thorough book review in the age of so-so fact-checking?129 Also, most of my previous reviews were about the same length, or at least used the same page-by-page model.

There is obvious room for disagreement in areas involving opinions, but there are many technical and non-technical mistakes that the authors made, not just a small handful.  By highlighting these, not only could the next edition be significantly improved but it helps readers new to this space get a better understanding of what the prevalent themes versus realities are.

The goal of this review was not to be overbearing but to be dispassionate about supposed common wisdom promoted in the cryptocurrency world.

For example, just the other day I noticed in a chatroom the following statement from a maximalist:

HODLer = DAU.  Bitcoin has the most DAUs on any protocol.

HODLing is bitcoinspeak for “hoarding.”

Several people in the room agreed with those this statement and they are not alone.  If the reader is interested in learning about the sociology and subculture of many Bitcoin enthusiasts, its worth skimming reddit and twitter occasionally to see how passionate coin investors think.130

But for businesspeople who are not part of the inner sanctum of Bitcoinland, the statement above from the chatroom may make you shrug.

After all, HODLing a dollar doesn’t make you a dollar user.  HODLing a barrel of oil doesn’t make you a oil user.  HODLing a brick of gold doesn’t make you a gold user.  HODLing a digitized Pokemon card doesn’t make you a Pokemon user.  HODLing a Stradivarius violin doesn’t make you a violin player.  HODLing an Olympic medal doesn’t make you an Olympic athlete.  And so forth.  The valuation of an auction house isn’t measured by the amount of rare collectibles it sells in a day, why should internet coins and their platforms be an exception to that rule?131

Inactivity isn’t how activity is measured.  Or to look at this argument from another angle: HODLing is not ‘active’ anything.  If all an investor did was buy bitcoin and then lose their keys, they would accomplish the same thing described in the chatroom.132

Sure it is possible to redefine what Bitcoin or cryptocurrencies are supposed to do, but that’s after the fact.  For example, if Satoshi had wanted to explicitly build “digital gold” he/she would likely have mentioned it in the original paper at least once and even architected Bitcoin to be something different than what it looked like in 2009.133  As mentioned above, the first app he looked at building was for poker.

This is definitely a topic worth including in the next edition, but I digress.134

Other general areas for improvement:

  • Add a glossary.
  • Add financial disclosures of coins owned by each author.
  • Provide specific definitions for vague terms like “the community,” “administrator,” and the attributes of a target investor; ditch the “innovative” investor nomenclature.
  • Chapter 7 probably should be removed until more accurate comparisons can be found and Chapter 17 seemed a bit unfocused and covered a wide array of topics instead of just one or two… even dropping in thoughts about regulators. Future versions likely need an entire set of chapters focused on regulations, not just mentioned in passing.
  • Based on the incorrect view of financing mentioned in Chapter 5, interview Vitalik Buterin and other co-founders regarding how Ethereum was bootstrapped.
  • In one of the future regulatory chapters, would be good to have a discussion around PFMI, CBDCs, and settlement finality.
  • Provide a lot more references and citations regarding cryptocurrency-focused use cases, especially remittance providers.  This seemed to be the most repeated use case but nary a mention of a specific Bitcoin remittance company, its valuation, or volume corresponding to the use case.

Have a book or paper you’d like me to look at?  Feel free to send it across.  Also, it just came out but this one sounds like a doozy already.  See my other book reviews.

End notes

  1. To be fair, Burniske is not the only analyst-turned-VC who has not publicly disclosed his trading positions of coins, but that’s a separate topic. []
  2. One reviewer mentioned: “Likely it was partially intentional to release in late 2008 / early 2009, but did in fact coincide mainly with internal constraints. We could also argue that the GFC commenced in mid-2007 when BNP Paribas froze two mortgage-backed security funds which became the catalyst of the summer 2007 credit crunch, but that is neither here nor there. I also debate the argument that it was ‘intended’ as anything other than a solution to the double-spend problem, be it a payments system or an investment.” []
  3. As an aside, Brian Kelly, frequently promotes various coins on CNBC.  Unclear what his trading positions are on each coin at the time of recording.  While that may not be illegal, it’s arguably not classy. []
  4. One reviewer mentioned: “This was literally the ethos that led to the GFC. Securitization and Mark-to-model were heralded as “innovation” and championed for their ability to move faster than the academic foundation and until 2007 seen as a way to ‘completely engineer risk out of from the system.'” []
  5. See: Robert Sams on rehypothecation, deflation, inelastic money supply and altcoins []
  6. See tcpipcoin in Section 8 []
  7. See: Digitalization or Automation – Is There a Difference? from Gartner []
  8. One reviewer mentioned: “The authors also miss that “value” is still a function of ‘the market’, i.e. supply and demand. Simply by fixing supply does not equalize demand. I also take massive issue with the governance in “a [de]centralized and democratic manner.” Are the authors able to write C++ or GOLang protocol code for Bitcoin Core or GETH? Likely not. So if anything this walks us towards a new form of governance, except where we elect leaders in the US who ultimately appoint Fed governors in cryptocurrencies there are generally no elections. Long story short, in all cases, it ain’t democratic and it probably remained at least partially centralised at a given point in time.” []
  9. See Central bank digital currencies from the BIS.  I know, I’ll get spammed by all the “sound money” promoters out there who insist that Bitcoin will replace central banks — it’s a religious zeal to many. []
  10. For example, about a month ago, Jonathan Levin from Chainalysis did an interview and mentioned that: “So we can identify, it is quite hard to know how many people. I would say that 80% of transactions that occur on these cryptocurrency ledgers have a counterparty that is a 3rd party service. More than 80%.” []
  11. For instance, on p. xxvi they list “the top 50” coins at the end of 2016 and don’t disclose if they own any specific ones at all, but talk about many of them in positive ways.  Adding a disclosure would be helpful. []
  12. Bitcoin has ‘no intrinsic value,’ Brookfield CEO says: ‘It’s not for us’ from Financial Post []
  13. The Economist wrote a nice short article on this behavior — the greater fool – last year. []
  14. For example, on p. 9 they write: “Shortly thereafter, Satoshi vanished.  Some speculate it was for the good of Bitcoin. After all, being the creator of a technology that has the potential to replace much of the current financial system is bound to eventually invoke the wrath of powerful government and private sector forces.”  This seems like a strawman.  Bitcoin was designed for just one simple thing: payments.  The financial system is an interwoven network of hundreds of regulated and unregulated goods and services, not just payments.  Also, this paragraph, like a few others later, has elements of conspiratorial boogeymanism.  Just around the corner, the government is preparing to shut down Bitcoin!  Nothing like that has happened in the past 9+ years.  In fact, the opposite has been true as most jurisdictions have been pretty accommodating, arguably even too lenient on the issuance and usage of cryptocurrencies, but that is a topic for a different post. []
  15. See Layer 2 and settlement []
  16. See Breakthrough IT Banking from McKinsey and Bank IT spending to hit $241bn across four major global regions from ComputerWeekly []
  17. One reviewer mentioned: “Are the authors aware that CMOs first appeared in 1983, and that in many countries where they were heavily utilised including in the late 2000s they worked as advertised? In fact many CMOs in the US performed as modelled. The issue was, and is, always liquidity, over-leverage and most of all deteriorating lending standards. Cryptocurrencies will most likely be looked at as catalysts of these risks should their notional rise substantially, not their saviour.” []
  18. One reviewer commented: “Are they arguing that people would have been more able to pay their mortgages or that home values wouldn’t have fallen if CMOs were on a blockchain?” []
  19. One reviewer explained: “When someone claims that blockchain would have prevented the mortgage crisis, they are revealing their ignorance of their ignorance.  I worked with some of that CMO data. One former colleague works for one of the large consulting firms ‘blockchain’ practices. He posted something about how blockchain would address the problems with mortgage servicing . When I privately asked him how it would do so,and that the problems with mortgage servicing that I was aware of were either failure to do certain required activities or their failure to record that they did them, as opposed to someone changing the record after it was entered, he did not respond.” []
  20. See also: The Problem with Calling Bitcoin a “Ponzi Scheme” by Preston Byrne []
  21. For example, at the time of this writing, Coinmarketcap tracks 1641 different types of coins and tokens.  Many of these are likely ERC20 tokens and thus rely on Ethereum itself and are not independent blockchains. []
  22. Worth re-reading the recent DoJ indictment of GRU officers as the DoJ provides a reason for why Bitcoin was used versus other transmission methods. []
  23. Someone should create a website that tracks all of the gigantic bullish claims from Bitcoin promoters on how it will topple banks and destroy governments.  There are at least more than 100 such public predictions each month. []
  24. But “be your own payment processor” isn’t a catchy phrase. []
  25. Readers should check out: “The Path of the Blockchain Lexicon (and the Law)” by Angela Walch. []
  26. It ignores how mining pools can unilaterally determine what transactions to include and how much a fee a transaction should include in order to be included in a block. []
  27. For example, KARMA : A Secure Economic Framework for Peer-to-Peer Resource Sharing by Vivek Vishnumurthy, Sangeeth Chandrakumar and Emin Gun Sirer []
  28. Recommended reading: The Economic Limits of Bitcoin and the Blockchain by Eric Budish []
  29. Some literature describes the proof-of-work process used in Bitcoin as a “scratch-off puzzle.” []
  30. One reviewer mentioned: “A model that I like to describe this with is how the main professional soccer leagues are selected in Europe and other regions. For example, France specifically has an annual selection of the “League 1” after the Coupe de French. Basically any team can enter, but practically there is minimal turnover because a team from a town of 5,000 people is unlikely to reasonably beat a team like Paris or Lyon which has multi-million euro budgets. There are few upsets, but these can generally be modeled by statistical chance.” []
  31. For example, Coin Center circulated a borderline defamatory note to ESMA with regards to Corda – even before the Corda introductory whitepaper was released – likely because its author was unfamiliar with how the platform actually worked. []
  32. It seems to be a euphemism and code word for “someone with money who should buy coins.” []
  33. Based on public information, over the past four years pretty much the only cryptocurrency-related companies that probably were profitable equity investments were: exchanges and handful of mining companies operating outside of the US (e.g., some service providers have also generated steady income including several law firms and conference organizers). []
  34. In both cases, consensus is achieved by the longest chain rule. []
  35. May not be a Freudian slip here, but keep in mind all blockchains have operators and maintainers.  See “arewedecentralizedyet” for more. []
  36. It arguably could have been a self-fulfilling prophecy: investors outside of Cyprus hear news about the Cyprus bailout and bitcoin… thereby marketing bitcoin to new retail investors who then go out and buy bitcoins to try it out. []
  37. See also the background of R3 / DLG as well. []
  38. It is common to see Bitcoin promoters regularly demonize these companies who are trying to improve and automate infrastructure, vilified as a bourgeoisie activity that must be shunned.  Worth revisiting to see if this changes over time. []
  39. One of the few exceptions is the Brave browser. []
  40. Creating and marketing coins to retail investors is relatively easy… building infrastructure that customers actually regularly use for commerce is another level altogether. []
  41. If measured by price, there was a large bubble that popped in December 2017, but that was something that happened after publication. []
  42. I have given several public presentations in the past year explaining the “trough of disillusionment” phenomenon in this context, including in Seoul and Tokyo during July 2017. []
  43. See also: Tokens: Investment Vehicle or Medium of Exchange (Not Both) by Cathy Barrera and MV=P…Que? Love and Circularity in the Time of Crypto by Anshuman Mehta and Brian Koralewski []
  44. Furthermore, in September 2014 I gave a presentation (video) (slides) that similarly tried to bucket different types of proposed coins as “commodities” and the like.  And I know I wasn’t the first to try and do so.  Recommend readers do a bit more digging on this topic if they’d like to see a more thorough origin story. []
  45. One reviewer mentioned: “The native tokens / coins / assets inside a ledger are “cryptocurrencies”, they are currency in the single sense that they the only form of compensation accepted by the miner / staker in a network. This cryptoasset business really only makes sense in the context of units which are not used to pay for the security of a blockchain.” []
  46. But that doesn’t necessarily excite speculators and coin holders. []
  47. See: Bitcoin Is Now Just A Ticker Symbol and Stopped Being Permissionless Years Ago []
  48. There are few religious undertones here that could be removed in the next edition. []
  49. As mentioned above, The Economist wrote a nice short article on this behavior — the greater fool – last year. []
  50. The authors of this book are likely unintentionally promoting coin buying with a security-like mentality, the wording could be modified in the next edition. []
  51. One reviewer mentioned: “Unless the authors explain how ETH is worth precisely zero based on the same logic then their statement seems disingenuous. Not that I believe that is the case, but I am not the one stating that scarcity in the future is the reason for the value.” []
  52. See Saifedean Ammous: The Bitcoin Standard — making the Austrian School case for Bitcoin by David Gerard, The Bitcoin Standard – a critical review by Frances Coppola, and The Politics of Bitcoin by David Golumbia []
  53. Why?  Most probably are unaware and the typical retail investors seems to just want the USD number to go up so they can sell the coin to someone else. []
  54. Also worth reviewing Consensus-as-a-service and The Blockchain Threat Has Drastically Sped Up Cross-Border Payments []
  55. Since the authors are making this claim, would they be willing to disclose or be transparent about their own coin holdings for the date when they published this book? []
  56. The most likely answer is: speculators bought these coins because they knew others would buy it too thus driving the price higher. []
  57. Or conversely, you are considered “one of us” if you promote the policies and antics of said coin promoters. []
  58. Note: it should be apparent at this stage that “Bitcoin developers” should be in quotes because it is certain key individuals — and centralized organizations such as “Core” — who have the power to sway decisions such as BIP approval.  These are arguably administrators of financial market infrastructure.  See also: In Code(rs) We Trust: Software Developers as Fiduciaries in Public Blockchains []
  59. Personal correspondence on June 5, 2018 []
  60. This is mentioned in the new CFTC warning: CFTC Issues Customer Advisory on Digital Tokens []
  61. It is these types of passages that make a reader scratch their head as to whether or not the lessons for why equity ownership — and the rights afforded to equity holders — evolved to where they have in developed countries. []
  62. This narrative needs to be buried but probably won’t. []
  63. This is a common refrain that needs to stop being repeated. []
  64. A few months before Cryptoassets was published, the SEC published a report that said they found The DAO to have all the hallmarks of a security but they never enforced any specific legal action on its creators. []
  65. See Appendix A: Internal governance []
  66. On p. 63 they write: “For example, a fully functional decentralized insurance company, Airbnb, or Uber all hold great promise, and developer teams are working on similar use cases.”  Why do these hold great promise?  Because everyone else says that on stage? []
  67. One takeaway is that other speculators may buy your coins at a later date when the prices go up, so you should get in before they do. []
  68. One of the biggest flaws in Chapter 7 is that all of the pricing information for the coins are based on markets that are opaque and unregulated… some of whom may be considered bucket shops of yesteryear.  Lack of transparency is one of the reasons why all of the Bitcoin-related ETFs have been (so far) axed by the SEC.  See: Comments on the COIN ETF. []
  69. Are Public Blockchain Systems Unlicensed Money Services Businesses in Disguise? by Ciaran Murray []
  70. With the exception from maybe transaction fees to miners, but those could arguably also be classified as donations.  See p. 65 in The Anatomy []
  71. See: Spurious correlations []
  72. For example, later on p. 104 they write: “More surprisingly, the portfolio with bitcoin would have had lower volatility.” Because of the time period?  We could probably find other things with the same or lower volatility.  That seems like cherry picking. []
  73. Maybe they are both, but that still doesn’t mean that the coins, say that Placeholder Capital invested in, shouldn’t be classified as securities. []
  74. See also: Tokens: Investment Vehicle or Medium of Exchange (Not Both) by Cathy Barrera and MV=P…Que? Love and Circularity in the Time of Crypto by Anshuman Mehta and Brian Koralewski []
  75. Also, these are all arguably poor stores of value because of their relatively high volatility.  For instance, “number goes up” or rapid price increases is not the definition for a store of value.  Claiming bitcoin is a good store of value because it sees swift increases in price appreciation as measured by actual money is a contortionist view which ignores the empirical reality of how money is used. []
  76. For example, later on p. 110 they write: “While many cryptoassets are priced by the dynamics of supply and demand in markets, similar to more traditional C/T assets, for some holder of bitcoin — like holder of gold bars — it is solely a store of value. Other investors use cryptoassets beyond bitcoin in a similar way, holding the asset in the hope that it appreciated over time.” Spoiler alert: everyone that owns internet coins hope they appreciate over time. []
  77. And there are specific projects — such as Bitcoin — in which one clique of developers waged an effective propaganda campaign against miners.  For more on this, look into the actors and organizations behind the Segwit / Segwit2x / UASF online debates. []
  78. Not to rekindle the flames of the Bitcoin blocksize debate but in retrospect, several Blockstream employees and contractors were arguably more effective at swaying public opinion than Coinbase was, even though the latter generates significantly more revenue and has actual customers whereas the former is largely just a R&D dev shop. This discussion deserves its own post but neither company is very forthcoming about client or partnerbase… although Coinbase has published a bit more information over the years relative to Blockstream. []
  79. See also: The Problem with Calling Bitcoin a “Ponzi Scheme” by Preston Byrne []
  80. A large portion of blocks between 2009-2010 also included relatively few transactions, yet miners were being rewarded the same revenue irrespective of the volume or labor involved. []
  81. This is a topic I’ve written extensively about in the past, see (1) A pre-post-mortem on BitPay and (2) Looking at public information for quarterly usage []
  82. There is a small window between when FX markets in San Francisco close on a Friday afternoon and when FX markets open in New Zealand on Monday morning. []
  83. See Bitcoin’s $30 billion sell-off from Chainalysis []
  84. Does trading between exchanges represent 90+% of the total volume on- and off-exchanges?  Without full optics into all major intermediaries, that would be a tough claim to definitively prove. []
  85. In informal surveys most speculators of coins have the same mentality of speculators of other things that are traded on secondary markets: they think the number will go up. []
  86. See When Paper Paralyzed Wall Street: Remembering the 1960s Paperwork Crisis from Finra and The Remaking of Wall Street, 1967 to 1971 from HBS and Dole Food Had Too Many Shares from Matt Levine []
  87. Also recommend Spurious correlations []
  88. The book downplays illicit activity as if it is not a valid, reliable use case when it is.  For instance, the GRU allegedly used bitcoin to finance some of its operations focused on the 2016 US elections and they did so to obfuscate their tracks. []
  89. See The new TARGET instant payment settlement (TIPS) service from the ECB []
  90. For more on this, see: (1) Debunking Bitcoin’s Remittance Valuation. Featuring a Lead Pipe by Anshuman Mehta and (2) Does Bitcoin/Blockchain make sense for international money transfers? from SaveOnSend []
  91. A fundamental problem with this book is that it wants to have it both ways, with no clear goal posts for what a good or bad platform is and how to measure it.  How can an investor know if a coin is any good?  A table of attributes is recommended for the next edition. []
  92. Simply multiplying the amount of mined / pre-mined / pre-allocated coins by the market price to arrive at a “market cap” is a disservice to how market capitalization is actually determined.  See Section 6. []
  93. As an aside, even though there is no law preventing consumers and merchants from using or accepting gold (or silver) as a means of payment in the US, basically no one does because they’d rather hold it with the expectation of future price appreciation. I am sure lots of angry trolls will point out that legal tender laws in the US do not currently include precious metals and neither are cryptocurrencies.  Yet there are other economic reasons why people would rather hold onto an internet coin or a gold bar versus use it as money, and simply blaming legal tender laws is missing those. []
  94. Recommended reading: Distributed ledger technology in payments, clearing, and settlement by the Federal Reserve and Central bank digital currencies from the BIS []
  95. See several articles: The myth of a cheaper Bitcoin network: a note about transaction processing, currency conversion and BitcoinlandWhat is the “real” price of bitcoin?, and What impact have various investment pools had on Bitcoinland? []
  96. Also, as a pre-emption: one of the main reasons why these merchants and manufacturers do not hold on to these coins is because of… volatility.  As shown earlier in this review, that still hasn’t disappeared despite years of promotion that it has.  See also: (1) Debunking Bitcoin’s Remittance Valuation. Featuring a Lead Pipe by Anshuman Mehta and (2) Does Bitcoin/Blockchain make sense for international money transfers? from SaveOnSend []
  97. And as mentioned in the section above, both Zelle and Swift (gpi) will likely make a lot of inroads in the same national and international areas that cryptocurrency advocates were touting… but without needing a coin.  The struggle is real. []
  98. Note: both have since left those jobs.  Bogart became a partner at Blockchain Capital (a venture fund focused on coins) and Luria joined D.A. Davidson []
  99. In the next edition if possible, try to include Placeholder’s research so we can have an idea of the firm’s internal thinking on these issues. []
  100. Recommended: Digital Tulips? Returns to Investors in Initial Coin Offerings by Hugo Benedetti and Leonard Kostovetsky []
  101. Does Placeholder Capital invest in such ICOs? []
  102. Note that selfish mining has some odd game theoretic properties which may not hold up in the real world. But if the selfish mining pool manages to stay a block ahead on average, they can reveal a longer chain whenever they see transactions they want to censor.  It comes with the caveats that it’s not completely reliable in that they aren’t guaranteed to be a block ahead of the rest of the network 100% of the time (due to the inhomogenous Poisson process mentioned earlier). However, if they manage to effect a cohort of self-interested selfish miniers, they could… and that’s the equivalent of a “51% attack.” []
  103. Recommended reading: The Economic Limits of Bitcoin and the Blockchain by Eric Budish []
  104. Recommended: Analysing Costs & Benefits of Public Blockchains (with Data!) by Colin Platt. []
  105. Based on hash rate, the vast majority of mining pools supported Segwit2x and did not support UASF. []
  106. Coincidentally, these have all obtained a Bitlicense from NYS DFS. []
  107. Kraken uses Silvergate for its OTC trading. []
  108. A user can be defined as a person who controls their private keys without relying on a 3rd party intermediary. []
  109. Several analytics providers include: Chainalysis, Blockseer, Elliptic, Scorechain, and CipherTrace. []
  110. This is reminiscent of the BearWhale nonsense a few years ago. []
  111. Recall that historically, humanity went from only having to bearer assets up through the 19th century.  And that for a variety of reasons these became registered and immobilized and then later dematerialized altogether.  Cryptocurrencies recreates a financial order that had already existed. []
  112. See Learning from the past to build an improved future of fintech and Distributed Oversight: Custodians and Intermediaries []
  113. Butterfly Labs began accepting pre-orders in the summer of 2012 but delivered them late in 2013… and got sued by the FTC. []
  114. Regarding ‘perfect competition,’ four years ago Jonathan Levin opined that: “Another simple thing about this is that it is unsurprising that the bitcoin network got into this mess as it is economically rational to join the biggest pool. Minimises variance and ceteris paribus reduce orphans increasing expected return per hash. The other point is that there is still hardware bottlenecks so designing the theoretically most robust system may fail due to market imperfections. Implicitly in many arguments I hear about mining people assume perfect competition. Do we need to remind people what are the necessary conditions for perfect competition? Perfect information, equal access to markets, zero transportation costs, many players ……. this is clearly not going to be a perfectly competitive decentralised market but it certainly should not favour inherently the big players.”  See p. 114 of The Anatomy []
  115. Some of these are detailed in: Comments on the COIN ETF []
  116. For illustrative purposes, this includes: Circle, JUMP Trading, and Cumberland (DRW). []
  117. See also: New Visa chargeback system aims to speed dispute resolution by John Egan []
  118. See U.S. Regulators Subpoena Crypto Exchange Bitfinex, Tether from Bloomberg []
  119. In his public speaking events and social media accounts, Andreas Antonopoulos is quite candid about his dislike of the establishment. []
  120. See Chapter 2 in The Anatomy []
  121. See Brian Armstrong’s tweet in Section 5 []
  122. This raises questions that related to FinCEN and SEC purview but neither has opined at this time on this specific point. []
  123. CoinAgenda Singapore, which took place in June 2018, only had 168 attendees — with ticket prices up to $3,000 apiece. []
  124. Coins.ph and Luno come to mind as examples. []
  125. See What is the difference between Hyperledger and Hyperledger? []
  126. See A brief history of R3 – the Distributed Ledger Group []
  127. Needs a larger sample size conducted in a public venue, and/or with the help of an experienced sampling organization. []
  128. This then leads to incentives to attack and hack exchanges, because they end up acting as deposit-taking institutions, aka banks. []
  129. There were probably 50% more hand-written notes or comments that I could have added that I skipped over. []
  130. The HODLing “digital gold” meme which was only passingly mentioned in this book ultimately degenerates into goldbugism but that’s a topic for a different post. HODLing arguably became a thing once the ideologues realized Bitcoin itself wasn’t a competitive payment system.  An enormous amount of revisionism has taken place since 2014 regarding what Bitcoin was and is and should be. []
  131. Debunking Bitcoin’s Remittance Valuation. Featuring a Lead Pipe by Anshuman Mehta []
  132. One reviewer mentioned: “By hoarding then actively purchasing more coins to hoard, they might temporarily create an effect whereby each marginal contribution to Bitcoin through mining rewards in expanding the effective monetary base is partially neutralized.  In addition to marketing campaigns, this can lead to higher USD values and may incentivize additional mining power, which in turn creates higher hashrate.  However, you cannot make the same argument for gold because simply driving the price of gold up doesn’t make gold harder to find or more secure, and in fact we see the opposite.” []
  133. For instance, the supply of gold is actually elastic whereas many cryptocurrencies including Bitcoin have an inelastic money supply.  Where in the whitepaper does it talk about a store of value?  If that was the goal, surely it would’ve been mentioned in the whitepaper or the first few emails upon Bitcoin’s initial release. []
  134. Recommended reading: The Economic Limits of Bitcoin and the Blockchain by Eric Budish []

Sufficiently Decentralized HoweyCoins

[Note: this was originally published at Diar.co]

SEC Director Hinman gave a public speech about three weeks ago which was subsequently affirmed by testimony from Chairman Clayton the following week.  A key point in his speech for many was his observation that ether (ETH) was no longer a security because it had become sufficiently decentralized.

In Hinman’s speech, he also provided an ad hoc checklist for issuers to go through to make sure they do not fall afoul of securities registration requirements.

But in doing so, the guidance does not really seem helpful as it raises more questions than answers which are discussed below.  Note: the discussion for how – if at all – the rules are updated or changed is not within scope of this short article.

|| Forks

The first is technical and pedantic: ETH as we know it, is actually the first major fork of Ethereum Classic (ETC).  Recall that following The DAO attack (hack) in June 2016, key participants in the Ethereum ecosystem coordinated a hard fork which resulted in two separate chains – what we now call ETH and ETC – and that ETC represents the original chain.  So transitively, does Hinman actually mean ETC is sufficiently decentralized too?  Or is it just a property for the fork, ETH?

While most people are aware that it was the exchanges — specifically Poloniex — which decided to recognize and associate specific chains with specific ticker symbols, exchanges were also key – existentially critical — during the first moments after The DAO attack (hack) was discovered.

How integral were they?  And how did they coordinate? 

A public chat log from June 17, 2016 details the coordination between core Ethereum developers and exchanges.  One such dialogue is the following:

Source: https://pastebin.com/aMKwQcHR

The specific passage highlighted above shows how key developers requested that exchange operators stop trading ETH and after some discussion, the major exchange operators – such as Poloniex – temporarily acceded to the request.  It bears mentioning that the chat above is missing some additional context around locked DAO tokens (which were still locked up for several more weeks) and that this provisional trading freeze was being done to protect all coin holders.

This wasn’t the first time that core developers attempted to coordinate with exchanges after a mistake has occurred.  In March 2013, a group of Bitcoin developers, miners, and exchanges did something perhaps more glaring – coordinated off-chain to stop a hard fork — in an IRC chat room during an unintended hard fork of Bitcoin.

If you follow the dialogue in either chat room, it is clear that a relatively small set of participants has influence and especially in the Bitcoin fork instance, arguably administrates the chain and its governance during these critical time periods.

And at least one question arises from this: is the ongoing success of the system (and the token’s value) reliant on the ongoing efforts of others?  If not, why not.

Arguably the answer is yes for most of these public blockchains.  And based on the handy “arewedecentralizedyet” chart we can see that similar – and probably more – types of centralization exists for many other cryptocurrencies too.

But recall that Hinman’s speech seems to assume that ether was a security at one point and then through some process that is still not explained, is no longer a security.  What day did that transition take place?  Was it before or after the ICO in 2014?  Before or after the coordinated hard fork in July 2016 (as a solution to The DAO attack (hack))?  Before or after <insert other milestones or forks>. 

For those counting at home, following the July 2016 hard fork, this means that the ETC chain was actually created twice and in both cases was the work of a small group of known people, some of whom continue to maintain it.  After all, blockchains don’t automagically fix themselves.

Is it possible for a coin or token to become un-decentralized?  And if so, do the maintainers get something like a 90 day grace period to make it re-decentralized otherwise the coin is sent to some kind of securities purgatory?

While we wait for more clarity and specific answers to these questions, another potential issue is with HoweyCoins.

|| Parody

HoweyCoins is a parody ICO website published by the SEC on May 16, 2018 – right smack in the middle of “Blockchain Week” in New York City.  The website is supposed to serve as a lampoonish illustration to coin issuers of what not to do when fundraising – and also serve as a warning to investors for what to look out for as red flags such as early participation discounts.  It’s definitely good fun – my friends and I frequently refer to it in jest.

And while Hinman’s speech explicitly punted on how Ethereum was initially funded, the Ethereum public sale back in July 2014 also relied on discounts (or bonuses) to early investors during its six week sale.  The first two weeks, participants received 2,000 ETH per BTC, which linearly declined until the final epoch in which investors received 1,337 ETH per BTC.  Were the designers of the HoweyCoins website aware of this discounting?

In looking at the actual HoweyCoins whitepaper there is no technical meat that issuers or investors alike can count on for guidance.  That is to say: there is no technical attributes describing the functionality of how HoweyCoin mechanically works.  In its 8 pages it describes a couple use-cases but – like most ICO whitepapers – is very vague at how it will accomplish or achieve them.

But ignoring the Ethereum initial fundraising period and its Terms and Conditions, a problem that is not resolved in either Hinman or Clayton’s recent speech and testimony is that HoweyCoins, for all of its vague promises of high yield returns is a strawman that does not really help provide guidance as it relates to the facts and circumstances around how Ethereum – or any crowdfunded coin – can become sufficiently decentralized

After all, what is to stop someone from spinning up their own blockchain called “HoweyCoins,” raise ~$17 million through a public sale  and 12 months later, formally launch the mainnet (as Ethereum did)?

The wording and justification for why Ethereum is not still a security – that it somehow at some point became sufficiently decentralized – seems ripe for debate and will surely be gamed by future coin and token sales.  Without explicit parameters, if Ethereum is sufficiently decentralized, then so to – at some point in the future – could HoweyCoins.  And then it’s no longer a parody.

|| RICO

A third and final point is that while Hinman alluded to them, even if these chains are finger quote “decentralized,” and thus not falling strictly under the “common enterprise” in the literal sense (i.e. where there is literally a single legal entity determining the success), how does a “community enterprise” present less risk to investors?   Tangentially, isn’t this the same type of argument that mob bosses frequently used and as a result RICO Acts were created to pierce through?

If we take the view that the spirit of the regulations (1933, 1934, 1940 Acts) which led to the Howey ruling was actually to protect small investors, does a non-singular, and quasi-independent, but systemically important influential organization actually reduce risk? 

If that is the view that they are taking, it would be helpful to see how the commission has come to that conclusion.   

After all, it is plain as day to see that most coin foundations are heavily influential in the maintenance and success or failure of a coin.  And representatives from investment groups like DCG are routinely making statements which have the single effect of moving the price and/or direction of coins such as ETC.  Even if these groups are superficially independent of the mining and operation, on the day-to-day they are directly traceable to the volatility in the market and to a large extent the success or failure of projects. 

Most, if not all of the coin foundations, market and advertise milestones which depend on the coordinated effort and work of developers that are paid with investors’ money.  Coin foundations typically register and own trademarks and other IP so (theoretically) they could force exchanges to associate a specific ticker symbol with a specific chain.  And often there is a hierarchy within a coin foundation with respect to the “community” it manages and oversees: it owns IP, controls investor funds, manages the verified social media accounts, and empirically calls the shots. 

Look no further than Nano and dozens of other coin projects that have been hacked or “exit scammed” because of how centralized the command and control structures typically are.  Another instance just last week, EOS block producers got on a conference call and paused their network (and later proposed scrapping their constitution).  Ignoring their year-long $4 billion ICO, is that series of actions sufficiently decentralized?

|| Conclusion

To be fair, the SEC has an unenvious role to try and regulate something (a network-based coin) in just one jurisdiction whereas these coins are also trading and custodied in other jurisdictions.  For instance, the FCA doesn’t currently regulate tokens (e.g., that are not equity or debt instruments).  And the Howey test is not applicable in the UK. 

Perhaps opening a public comment period to provide suggestions could be helpful in conceptualizing objective measurements and quantifying decentralization (assuming it is not an oxymoron).  Though, that inbox would likely just get spammed so maybe just start with credible opinions such as those of the BIS.

In closing, a hypothetical HoweyCoins and its benevolent overseers and thought leaders at the HoweyCoins Foundation could mimic other sufficiently decentralized projects and host an annual HoweyCon; simultaneously emceed by none other than Howie Mandel and Howie Long.  If and when this occurs, is the only thing that HoweyCoins did “wrong” was promise to provide discounts to early investors? 

Maybe not, at least if they donate some of their proceeds to coin lobbying groups to help explain to policy makers and regulators that HoweyCoins is not a security, because it is sufficiently decentralized (e.g., more than one Howie exists).  Either way, I bet there will be some amazing schwag at HoweyCon, really looking forward to it.  There may also be an announcement about the forthcoming HoweyCoins Classic fork. 

Stay tuned.

Events and activities through April

The first several months of the year have been pretty packed with undeserved pomp and circumstance.  In general the “cryptocurrency world” has lost whatever remaining marbles it had and gone backwards to repeating the same tropes from 2014.  Many of the same sub-par ideas are being proposed (like colored coins) yet there were several fundamental reasons these types of ideas didn’t get off the drawing board four years ago and will not for the same reasons again.

The noise around “blockchain” hype has gotten so bad that just about anything that can be said, has been said and as a result, new projects find themselves having to make even bigger promises that they will be unable to keep.  Expectation management is nigh impossible and it is a global craze (I visited Asia three times already and saw this exuberance first hand)

Along the way, I found some interesting, quiet groups: in addition to a couple stealth projects, I joined Blockseer as an advisor and Elm as a consultant.

Below are some of the activities I was involved and participated in.

Interviews

Cited and acknowledged

Panels and presentations and op-eds

Blockchain 2040: the year we burn the last mound of coal

Yesterday I was part of a panel at UC Berkeley where we given a prompt: what will the world look like in 2040 as it relates to blockchains.

Obviously no one knows, so I had a little fun with it… tying in the post-apocalyptic films “Escape from New York” and “Escape from L.A.”

It was about a 10 minute presentation followed by Q/A, see the slides below:

Is the Pitato why we can’t have nice things?

[Note: I originally wrote the bulk of this article as an unpublished memo about 18 months ago. I have updated it to include new information.  The views and opinions expressed in this article are mine and do not necessarily reflect the views of my clients.]

The big news this past week was that Coinbase acquired Earn.com (née 21.co, née 21e6 LLC). According to Recode, the offer “was slightly more than $100 million” but also lower than Earn.com’s most recent valuation (in 2015) which was $310 million.

From the current coverage, it is unclear what the revenue for any of the products or services for Earn.com was.  Instead most stories have focused on one specific aspect: the current Earn.com CEO, Balaji Srinivasan, will join Coinbase as the CTO.

There have been a lot of questions around why Coinbase would purchase a company that seemed to have poor product-market fit with unknown KPIs. This post will look into several areas for answers.

Taking a step back

Following the official acquisition announcement from Coinbase, Srinivasan published a self-congratulatory Medium post that basically paints him as the savior of 21.co: that it was the previous management that were bad and he came in and turned it all around.1

His revisionism arguably whitewashed what happened, so let’s dive into a little bit of the company’s history.

In May 2013, 21inc (formerly 21e6 LLC) was co-founded by five men including Balaji Srinivasan. According to a story from Nathaniel Popper:

The company was also structured as an limited liability company, rather than the C Corp typical of startups, so that people could invest with their own money.

Why is that important to some investors?

According to Popper:

The 21e6 investment was attractive in part because venture capital firms generally felt that they couldn’t buy Bitcoins directly. 21e6, on the other hand, offered to pay its investors back with Bitcoin dividends, allowing the firm to get Bitcoins without buying them outright.

What does this mean?

Venture funds often have clauses restricting their partners from investing in asset classes that may be seen as a conflict of interest or something that could reduce the firm’s reputation (e.g., cannabis startups). In this case, cryptocurrencies may be seen as a direct speculative bet on a commodity or foreign exchange which could be prohibited by an investment funds by-laws.2

Altogether the 21e6 team, over three separate rounds, raised approximately $116 – 125 million – which at the time was more money than any other cryptocurrency-related company.3 The sum total varied depending on news source but Srinivasan frequently made it a point to casually insert comments such as: we are the “most funded” or “best funded” company in Bitcoin into interviews and talks during 2015-2016.

In the beginning

In its early days 21e6 focused exclusively on designing custom ASIC chips for Bitcoin mining and then integrating and deploying Bitcoin mining hardware for private, non-retail usage. This included installing hundreds of hashing systems in data centers which for several reasons eventually became uncompetitive against those based in China and the Republic of Georgia.45

Based on publicly available information and allegedly leaked slides we know that:6

It closed its Series A for $5 million in May 2013.

  • Investors included: Peter Thiel, David Sacks, Max Levchin, Marc Andreessen, Ben Horowitz, Naval Ravikant, Winklevoss Capital, Mark Pincus
  • Estimated $3.8 million revenue in 2013

In June 2013, then-CEO Matthew Pauker filed a Form D, Notice of Exempt Offering of Securities, which stated that 55 investors had already invested in its offering.7 While that may sound unusual for an early stage company to have so many investors, recall what Popper pointed out above, that individual investors could invest directly into 21e6 because of its LLC status.

It closed its Series B for approximately $65 million in December 2013.

  • Andreessen Horowitz (the VC fund) invested $25 million as the lead investor; and $10 million came from existing investors (such as $100,000 from Pantera)
  • $30 million also came in the form of “venture debt”
  • Estimated $41 million in revenue in 2014
  • 19 employees in November 2014

The funds from its first two rounds were used in part to design and deploy “Gandalf” (its 2nd generation ASIC chip) and “Yoda” (its 3rd generation ASIC chip) in the aforementioned data centers.

How much capital is required to build a state-of-the-art ASIC chip? Depending on how much is done in-house or out-sourced as well as the fabrication facilities, it can be upwards of $15 – $20 million.8

First major pivot

The company rebranded from 21e6 to 21.co and announced its Series C on March 10, 2015, with $56 million led by RRE Ventures. 9

That morning, The Wall Street Journal led with the story:

Secretive Bitcoin Startup 21 Reveals Record Funds, Hints at Mass Consumer Play

This marked the beginning of its pivot from purely building mining hardware and instead marketing itself as supposedly moving into the Internet of Things (IoT) and API marketplace.  Around this time you frequently saw 21.co and its supporters publicly talk about machine-to-machine (M2M) payments as being a killer app.10 One of the 21.co engineers was even interviewed on a (now deleted) podcast where he spoke about how drone owners would pay tolls denominated in bitcoin to cut across airspace over yards in your neighborhood. You know, the usual word salad and shower thoughts on social media.

When I first drafted this memo 18 months ago, based on LinkedIn profiles, 21.co had about 25 full-time employees; as of now their page says 22 employees but most of them are just people adding 21.co in their profiles without formally being affiliated with it. Most of the current employees unsurprisingly have shifted to Earn.com’s official LinkedIn profile. Its tally is 63 people but again, some of these profiles are from people who are likely unaffiliated with the organization.

Other known investors through 2016:11

  • Data Collective
  • Khosla Ventures
  • Yuan Capital
  • Drew Houston
  • Dara Khosrowshahi
  • Avant Global
  • Karl Mehta
  • Capricorn Management / Jeff Skoll Group
  • Qualcomm Ventures
  • World Innovation Labs

Other board members/observers:

  • Alan Chang (Jeff Skoll’s family office via Capricorn Management) in Series B
  • Richard Tapalaga (Qualcomm Ventures) in Series C
  • Gen Isayama (World Innovation Labs) in Series C

According to Nathaniel Popper, as of March 2015 when it announced the closing of its Series C round, “the company has paid back all of its investors.” It did so partially via payouts in bitcoin.

In his self-canonization this week, Srinivasan wrote that:

And with this deal, the total value of cash, cryptocurrency, and equity returned to our shareholders is now in excess of the capital invested in the company.

How much of the cryptocurrency above is from the not-yet-released Earnable Token? Get the whitepaper while you still can.

Since March 2015, there has also been noticeable churn at the top:12

  • Matthew Pauker, co-founder, was replaced as CEO in spring 2015 by Balaji Srinivasan
  • Albert Esser was the COO from December 2013 through August 2015
    • Replaced by John Granata from March 2016 to the present
  • Nigel Drego co-founder, was chief architect from May 2013 through March 2016
    • Replaced by Jian Li as CTO from March 2016 through 2017
  • Lily Liu became CFO during summer 2015 to the present

Because of the economic incentives that tilt in favor of mining countries like China, 21.co stopped its operations in the Bitcoin mining sector and those subject-matter experts seem to have left the ranks.

Second major pivot. Or part of the first?

What has it built since the pivot after Series C?

The 21 Bitcoin Computer was their first consumer-facing product that was announced on September 21, 2015 and released with great fanfare as an exclusive to Amazon Launchpad on November 16, 2015 at a price of $400.  It also picked up the “toaster” nickname from the Financial Times.13

Several enthusiasts explored the component prices via a piece-by-piece breakdown and found that it likely cost around $247 to build each 21 Computer.14 It was subsequently nicknamed the “Pitato” because the main component at its heart was basically a Raspberry Pi, a popular DIY kit that sells for less than $200.

The only other notable piece of tech was a custom built ASIC chip that could be used for mining.  However, ever before it had shipped, the mining chip was already uncompetitive and obsolete.  Even if you had free electricity you likely would not generate enough bitcoin in order to recoup the full cost of buying the 21 Computer, especially since the few satoshi you generated would be stuck as dust.15

What were the maths behind this?

In September 2015, after it was announced, Vitalik Buterin crunched the numbers and worked out that:

So you’re paying $399 upfront and getting $0.105 per day or $38.3 per year, and this is before taking into account network difficulty increases, the upcoming block halving (yay, your profit goes down to $0.03 per day!) and, of course, the near-100% likelihood that you won’t be able to keep that device on absolutely all of the time. I seriously hope they have multiple mining chips inside of their device and forgot to mention it; otherwise you can outcompete this offering pretty easily by just preloading a raspberry pi with $200 of your favorite cryptotokens.

Why the relatively large markup for a device?  Part of it is that Amazon Launchpad gets a 25% cut.

But like just about all things Bitcoin, sales numbers were so bad that they were never disclosed and it was eventually discontinued. Prior to its discontinuation, 21.co representatives approached multiple well-known Bitcoin developers to help resell the devices. In short, these developers were offered to buy 21.co devices at wholesale prices and expected to resell them at the retail price. It is unclear how many (if any) developers did so.

For real, the second major pivot

On April 1, 2016, 21.co launched an app “marketplace” and initially seeded it with 50 apps that were built in-house. At the time, the only way to externally measure usage or traction is to manually observe the amount of ratings (stars) an app had each day. Interestingly, in early July 2016 the amount of apps stood at 95 whereas six weeks later it fell to 76 and basically fluctuated for the remainder of the year.

In May 2016, Srinivasan took the stage at Consensus and announced his vision of a “machine payable web” and introduced several ideas but notably did not mention the Bitsplit which was rumored to have been in the works for over a year.16

Throughout the remainder of the year, 21.co sponsored and hosted meetups and had an active Slack room, and most of the ideas that were used or borrowed as API and app ideas, languished due to… a lack of users.17  If you are new to my site, one reoccurring observation is that in general: cryptocurrency owners typically are not actual users, but that’s a whole different discussion.

The 21.co Marketplace now redirects to the Earn.com homepage.

Pivot three

On October 27, 2017, 21.co emailed its users that it was ending server-side support for three things: the Bitcoin Computer, 21 command line interface (CLI), and marketplace. 18

Three days later, 21.co announced that it was rebranding as Earn.com and pivoting away from its second vision as a VC-backed quasi protocryptojacking play towards taking on Amazon Mechanical Turk, but with Bitcoin. It also announced a non-ICO ICO called Earnable Token, which as you can tell from its name: was earnable from doing the same kind of tasks as you could before like: filling out surveys or answering bots who email you.

Earn.com also migrated the unique profile pages it first introduced with 21.co, which is basically a static page that users can claim and use a bit like LinkedIn, but with more Bitcoin-related spam.19

Source: Twitter

Unregistered securities?

This last part is of particular interest in today’s regulatory climate because Earn.com, which hosts these user-controlled accounts, has accidentally assisted and enabled the promotion of alleged unregistered securities (ICOs) as a business line.  Recall that Google, Facebook, Snap, Twitter, Mailchimp, and other tech companies have reduced or removed the ability for ICOs and cryptocurrency promoters to solicit retail investors, Earn.com has done the opposite and been a refuge.  At what point is this an unsuitable risk profile for a “bank” like Coinbase?20

What does that mean?

In its January 2018 update, Earn.com announced that:

This week we were thrilled to announced the launch of Earn.com Airdrops — a new way for blockchain entrepreneurs to give 100,000+ Earn.com users a free trial of any new coin or token. Airdrops allows token projects to instantly bootstrap your new blockchain project with 100,000+ cryptocurrency early adopters.

We announced our first Airdrop partner, CanYa — a decentralized marketplace for services — as well as the next three upcoming Airdrops: Bloom, Bee Token, and Vezt. Sign up for an account on Earn.com, verify your account, and download the Earn.com mobile apps on iOS or Android apps to become eligible.

I am not a lawyer but in the past – like the dotcom era – companies (including startups) have attempted to give away equity in some very creative ways… and depending on the circumstances, it can be a no-no.21 That’s not to say that the tokens above are securities or that any airdrop is a violation of securities laws. But highlighting this type of feature has inadvertently led to Earn.com becoming a magnet for ICO issuance and promotion.

Where’s the beef?

What was the long term deliverable for roughly $125 million in nearly 5 years?

Throughout 2016 – including at Consensus in NYC – Srinivasan explained that they will announce a “surprise” in the coming months, maybe all of the aforementioned products and chips were the alpha phase of a much larger operation?  Maybe they were, but we probably won’t find out.

Either way, it is worth keeping in mind that between 2013-2016, cryptocurrency-specific startups collectively received a little more than $1 billion in external funding, with nearly 15% of that funneled into just one startup. One who has had to pivot multiple times to find the right product-market fit and tech-market fit.  Keep in mind too that other companies such as Bitfury and Bitmain were able to make superior chips and do so initially without major venture backing.22

If the most funded, best connected startup continually struggled to see consumer traction, what are the prospects for less funded and less connected cryptocurrency startups?  This is worth revisiting in another long-read, especially in seeing what the $125 million was actually spent on (salaries? chips? toasters?).

How involved was he?

Source: Twitter

One of the investors in 21.co responded to Nathaniel Popper above claiming that Srinivasan wasn’t actively involved in the first two years.

Does it matter? Sure, when you are claiming successes and denying failures that should or shouldn’t be attributed to you.

Below is a quick series of interrelated anecdotes.

In December 2014, Srinivasan and I both attended and presented at what would become the second of three round table events organized by R3 (a family office then called R3 CEV).  This was prior to the formal creation of the DLG consortium.23 Unfortunately I do not have his presentation, but the layout and design were nearly identical to the leaked slides that have circulated for years — just with different content.  For instance, the design of his slides at a public talk in the spring of 2015 is pretty close to the other two decks.

In January 2015, I was unexpectedly shown a long set of slides for a company called 21e6, most of which look similar to what has been leaked in the past and linked to above.24

Later that same month – due to a variety of circumstances – I met up with Srinivasan in Palo Alto and he quickly paged through the leaked presentation and stated it was an older deck from October / November 2014.

While there is a little more to our subsequent interactions, I think the key part here and the only reason I brought up this personal anecdote is the fact that Srinivasan was able to dismiss the deck of having any relevance on the current fundraising 21e6 was doing (remember, this was less than two months before the round was publicly announced).25

So while he may not have been “day to day” as he disclaims in his post, he clearly was involved in the fundraising process if not more (deck creation?).  He said as much in a post published in March 2015.

So what to make of all of this news?

An exit is an exit, right?

What ultimately appears to have happened is that Andreessen Horowitz took one of its floundering portfolio companies and merged it with another portfolio company… and declared it a great success.2627

The circle of life...

Source: Twitter

There also appear to be a few parallels with Juicero.28 For those unfamiliar, Juicero is a now-defunct Silicon Valley-based startup that built and sold a custom $400 machine that would squeeze juice packets.  It raised $120 million and unceremoniously shut down last year after reporters showed that the hands from mere humans were capable of squeezing the same juice packets.

In much the same way, during the second pivot of 21.co, no one really bothered to buy the “Pitato” because users could easily do the math: that it was far more effective to either buy bitcoins outright or buy and use more capable mining hardware.

Why hasn’t anyone written about this before?

Most of the knowledge above is public, or at least, pretty well known if you have spent much time in Bitcoinland.  Other reasons involve some tinfoil hat theories around retaliation.29

Funnily enough, back in March 2015 I had a long email exchange with Michael Casey and Paul Vigna over at The Wall Street Journal regarding 21.co and other several other topics.

This culminated in the quote:

Tim Swanson, a consistently skeptical digital-currency consultant who makes a habit of challenging bitcoiners’ unbridled optimism, is unequivocal. 21′s plan is “a dumb idea,” he says, adding that “the investors deserve to get what’s coming to them.”

And while a few of those investors probably did, it is Coinbase share holders that likely got it on the chin this week.30 If you’re looking for more memorable gems, be sure to read this older WSJ article.  It is chocked-full of hubris, kind of like Juicero.31

In closing, raise your hand if you’d like to get paid every time you respond to an email and moreso to a cold email?  I know I would.

So maybe with all of the kinks, toasters, pivot denialism, and chest thumping there is still a future for a pay-to-respond model to thrive.  Maybe Coinbase can turn the ICO sanctuary of Earn.com into a legitimate mainstream product that is integrated with various webmail providers and social media platforms. Or maybe this ends up like ChangeTip, whose platform was basically used to spam coin dust on Twitter… to ultimately shutting down after an acquihire from Airbnb.

Either way, there was a bit more to this story than what was let on in Srinivasan’s original Medium post on Monday.

Update: (see note) 32

Endnotes

  1. Would that be a Bitcoin-powered bus that the management team was thrown under? []
  2. Over the past several years, multiple venture funds have had their by-laws amended or re-written to allow them to purchase cryptocurrencies and directly invest into ICOs. []
  3. In March 2015, 21inc announced that it had raised a total of $116 million, however according to Nathaniel Popper’s account of their history, they had raised about $125 million. For one reason or another, historically many cryptocurrency companies do not typically reveal their active user numbers or revenue figures. Instead they prefer talking about how much outside funding they have raised. And 21.co was not an exception to this. []
  4. There are several reasons why this was the case.  With the right guanxi: a combination of electricity, land, and taxes could be cheaper in certain parts of China versus the US.  In addition, 21e6 and other US-firms were consistently unable to manufacture mining machines and operate farms at a similar scale as their peers.  Part of this was logistics as well: large portions of the supply chain were based overseas (primarily in Guangdong and Taiwan). I have written about this in multiple different posts over the past several years, such as this piece. []
  5. One of the interesting things that Srinivasan’s article confirms was a rumor I first heard two years ago from one of their mining competitors: that 21e6 had signed leases with data centers whose energy rates were so abysmal that you might as well just bought coins instead as it would basically be impossible to recoup those costs. Another unconfirmed rumor was around immersion cooling: that between 2014-2015 21e6 had experimented and burnt through a large quantity of chip inventory in a radical attempt to reduce the cooling needs and costs of mining chips. []
  6. Some of this information comes from: reddit, CoinDesk, Financial Times, and Jorge StolfiGoogling around too. []
  7. Form D – note that the domains 21e6.com and .net and .org all registered around March/April 2013. []
  8. Why Are Computer Chips So Expensive? from Forbes. In addition to non-recoverable engineering, there are also component costs and testing thereof: PCB, SMT, power supply, fans, integration. Testing and trouble-shooting cannot be ignored. For instance, Hashfast was an example of a company who built a relatively fast chip but had problems with managing the power source and consequently went bankrupt. []
  9. At the time it was frequently reported that 21.co had raised $116 million but that was the sum total of all funding rounds.  The Series C was ~$56 million. []
  10. Srinivasan did talk about micropayments as early as March 2014. []
  11. Sources: CrunchBase / AngelList []
  12. In May 2015 it was reported that Cisco may invest or may have invested in 21inc. Padma Warrior, former Chief Technology and Strategy Officer at Cisco, was rumored to be a key individual involved in that deal. Note: as of August 2016, a site redesign on 21.co removed investors and corporate information from the homepage. []
  13. This is mainly because an earlier 21e6 pitch stated that the company would integrate mining chips in always-on consumer electronics and appliances. []
  14. Breakdown of Hardware Costs for New 21 Inc Bitcoin Computer by Sam Patterson []
  15. One reviewer commented: “I’d say one more thing worth adding is that it’s worth critiquing not just the feasibility of the Pitato but also the ethics. Because Pitatoes are inherently less efficient than regular mining farms due to economies of scale, the only way that they could be competitive relative to just buying bitcoin is if they were using free electricity; that is, basically all profitable usage of Pitatoes would be people using other people’s electricity in workplaces, universities, Starbucks, hotels, homes if the landlord pays for it, etc. I predict that if it actually became popular, then we’d see all the places that provide free electricity today become much more cautious about it, which could greatly reduce convenience for everyone but bitcoin miners.” []
  16. In one of its incarnations, Bitsplit was basically a euphemism for socializing CPU labor and privatizing some of the gains… now commonly called cryptojacking. []
  17. One reviewer said: “That earn.com pivot was done through the 21.co meetups that would host with Bitcoin engineers trying to buils apps on the 21 computer, which was eventually bricked. The idea for paying engineers for github pull requests led to earn.com’s business model.” []
  18. Note: in between the second and third pivot, during January 2017, Srinivasan deleted his tweets and interviewed for the top job at the FDA in Washington DC. []
  19. One reviewer commented that: “My personal view is that the current Earn.com concept is fundamentally legitimate and probably will see some usage (I can totally imagine consultants charging $50 for replying to emails, as that’s a very low-transaction-cost way to get one-time advice from people), but it deserves to exist as one of the 173 configurable settings in an email provider or social media service, not an independent multi-hundred-million dollar company. Perhaps the Coinbase acquisition actually will be utility-improving, in that gives the Earn.com team an ability to try to be useful by making gadgets for an existing company that has a userbase and services, rather than trying to build their own ecosystem which never made any sense (though it’s still a pretty disappointing end relative to Balaji’s original hype and aspirations).” []
  20. Is Coinbase a bank?  From the outside they seem to be a bit like a non-licensed deposit taking institution. []
  21. The line of reasoning is as follows: some startups attempted to randomly give away shares to strangers via various gimmicks but ultimately had to either take it back and/or were sued. If certain ICOs are deemed securities, you might not be able to just give them away to anonymous people. Reminder: I am not a lawyer, talk to a securities lawyer. []
  22. One competitor noted that: “21e6’s decision to go the Intel fabrication route was a non-starter. []
  23. Someone should remind me to talk about the dinner conversation that evening as well. []
  24. Coincidentally a few days prior to receiving those slides, I spoke with a NYC-based investor who was asking about the pros and cons of embedded ASICs for mining cryptocurrencies.  Specifically: should the fund invest in a startup designing embedded ASICs for bitcoin mining.  I provided my view point (the answer was no, still is a no).  During this same time frame there was a big meme being pushed by many Bitcoin boosters: that mining would somehow become re-decentralized via some unknown magic bullet.  Some of these promoters believed that 21.co would be the one to do it, without much evidence that the company could (or that anyone could). Note: there have been multiple other attempts at building and shipping embedded ASIC mining chips including from Midea and Bitfury.  None have been successful by any measure. []
  25. Remind me to mention the coincidence at Chipotle. []
  26. One reviewer asked: “Is this self-dealing?” []
  27. Another reviewer said: “This is acquisition theater, everyone is just trying to save face because this wasn’t a great idea, had wasteful execution, and the hype and hoopla reflects poorly on all involved.  The players fundamentally misunderstood the tech, the economics and use cases. I get that a VCs job is to make unsubstantiated bets on tech entrepreneurs they like. But here, an outright $116m investment in Bitcoin would have yielded X billions. And the “we returned all capital” probably because of BTC dividends and its price hike than cash returns.” []
  28. See Section 4 of a popular post last year. []
  29. What are the repercussions for publicly asking critical questions regarding bold claims such as those from a fireside chat with both Srinivasan and Andreessen?  Being blocked on ol’ Twitter. []
  30. Since we are going into the anecdote highway: in March 2015, at the Stanford Blockchain Workshop event, I approached Adam Ludwin after his panel discussion. On the panel he had mentioned that there could be a “redecentralization” of mining through an upcoming “Silicon Valley moment.” I assume he was talking about 21e6’s plan for mining chips being integrated into always-on devices because he was affiliated with one of its investors. When I told him I had seen a 21e6 deck and that it was making some very wild, likely incorrect assumptions, he basically said: we will see about that. Well, we have seen that once again: the difficulty rating rises with prices thereby diluting existing hash generating devices making them obsolete. []
  31. Some of the comments from the 21.co spokesperson are enjoyable. These hashing devices still wouldn’t be profitable at the current prices today because the difficulty rating has increased in proportion to the price yet all of the hashing units inside phone chargers and toasters had a fixed unit of labor. It’s a no-win situation for device owners as they would still have to pay for both the depreciating capital good (the device) as well as the electricity. []
  32. A couple hours after publishing this, a reader reached out and mentioned that: “I’m a proud owner of a Pitato. You forgot to mention that Balaji taught a course at Stanford about cryptocurrency and basically used it to promote 21co and Pitato to students. He gave it for free to students but all the labs were on this hardware. IMO it’s a conflict of interests for him as a professor <-> manager. The instructional material and repo is still online: (1) (2) (3) (4)”.  Note: I don’t think this is a conflict of interest, professors and lecturers sometimes have their students purchase a book they may have authored/co-authored as they are the subject-matter expert. []

What were some of the cash flows into the coin market last year?

A few independent reports have trickled in regarding the amount of real money that came into the cryptocurrency market last year.

One estimate is from Nikolaos Panigirtzoglou at JP Morgan entitled “Flows & Liquidity: The emergence of cryptocurrencies.”  According to his analysis:

The net flow into cryptocurrencies is very much a function of coin creation which is controlled by computer algorithms and in the case of bitcoin is diminishing over time. Figure 6 shows the net amount of money invested every year since 2009. The cumulative amount has totaled around $6bn since 2009, well below the current market cap of $300bn.

He illustrates this over time with the bar chart below:


A cumulative $6 billion figure is a little less than the next estimate below.

Note: that Panigirzoglou’s analysis above was published last month.  It is unclear how much his calculation(s) may adjust upward given the fervent energy through the holiday season.

Robin Wigglesworth, a reporter with the Financial Times, posted a new note from Citi research about a week ago entited: “Cryptocurrencies are the answer; what is the question?”  A couple bullet points from the note:

  • In 2017, cryptocurrencies grew from a market cap of less than $20bn to around $500bn. We estimate this surge was driven by net inflows of less than $10bn.
  • We think current prices require inflows of approximately $25bn/year to be sustainable. For 2018, this seems likely to be exceeded. We would expect bitcoin to continue to make gains but for larger alt-coins, particularly ripple and ethereum, to outperform.

They don’t give a range, but less than $10 billion could sync with the JP Morgan analysis depending on which spot exchanges and OTC service providers they spoke with (in addition to the market data they may have used).

I typically don’t write about price action, however, the price of bitcoin has been especially volatile the past few weeks.  It has declined about $5,000 (~25%) since its most recent all-time high last month.  And both ether and XRP have recently seen new highs.  Will this last throughout the rest of the year?

Note: I was quoted in The Wall Street Journal last month saying this is some kind of bubble:

The most recent moves brought bitcoin’s year-to-date gain to about 1,560%. For many skeptics, though, that is proof that bitcoin is a massive bubble.

“It’s clear that people are putting money in simply because they think other people are going to put in money,” said Tim Swanson, the founder and research director at Post Oak Labs, a San Francisco advisory firm. “We’re seeing the actual illustration of speculation. Somebody should take a snapshot of this and put it in the dictionary.”

Let’s check back in a few months to see if there are any more cash flow estimates.

Update: Chainalysis posted an explanation for the post-December price decline which looks at ‘net inflow’ at exchanges.  See also: J.P. Morgan Perspectives: “Decrypting Cryptocurrencies: Technology, Applications and Challenges” (pdf)

Predictions for 2018

As mentioned in my previous post, below are five thoughts for what could take place in 2018, categorized by degree of likelihood: most likely –> least likely.

(1) Continued mania

The euphoria around cryptocurrencies and ICOs continues due almost entirely because of retail sentiment, not just because of institutional action.  Every valuation model that has been proposed to gauge what the price of a certain coin will be, fails almost entirely because of the inability to model sentiment.  Contra Chris Burniske (note: he did not really disclose that he owned bitcoins while covering cryptocurrencies as an analyst), there are no ‘fundamentals’ to nearly any coin, in fact, many of the “top” coins don’t even do what they claim to do.

Want proof?  Look at the most talked about ICOs and altcoins and airdrops that were created in 2013-2014.  How many of them have actually delivered what they marketed?  Basically none.  Yet, if they are still listed on an exchange, odds are they are trading at near all-time highs because retail investors really don’t care about functionality or utility: they want narratives that paint pictures of Moonlambos in their near future.

This phenomenon is best described as “coin nihilism”:

Source: Twitter

So as long as there is free-entry to create and market a cryptocurrency to the masses, coin domination (who is the king of the castle) will be fluid.  The only entities capable of changing that is law enforcement via coordinated regulatory action (e.g., debanking of exchanges due to regulatory guidance).1

Or as one of my OTC trader friends recently remarked:

“This is why crypto is doomed for pump and dump because the market can’t react to increased demand with more supply. So if interest fades you just keep getting clobbered with new supply like 2014 redux.”

When you have free-entry and no gatekeepers when it comes to creating money supply, people will just create a new coin as it always has more financial upside.

Besides governments, what else could stop the pump train?  Hackers seem focused on low-hanging fruit – no one bothers to actually attack technical weaknesses in a blockchain.  “Early adopters,” old guard (OG) whales cashing out faster than demand can absorb the coin supply may be the only other large counterbalance to the mania.2

(2) Lawsuits

Both criminal and civil lawsuits will continue to be filed against issuers and developers of both cryptocurrencies and ICOs.  On the criminal side, the wrinkle will be that it will not just be securities and/or commodities regulators.  Law enforcement agencies involved with monitoring money transmission (such as FinCEN and FINTRAC) will announce more than one criminal suit against developers who either enabled money laundering to take place on their platforms and/or failed to comply with some other area of BSA (or other regional equivalent).3

Rather than go through the laundry list of all the areas for regulatory and law enforcement action, check out (attorney) Christine Duhaime’s explanation.

With that said, while a case could be made that entities like Bitcoin Core – and its vocal surrogates – behave a lot like administrators, there are few indications that the any development team will be sued right now.

(3) Pumpers and VCs are going to pump and won’t be held accountable

Pretty much the most popular twitter personalities nowadays are the shills and pumpers who benefits from one anothers antics.  It’s a non-stop contest to see who can say the most outrageous things about what cryptocurrencies will do to the world.  The winner gets to cash out on a secondary market and buy a Swiss resort. The loser who said Junkcoin would only jump 10x instead of 100x also gets to cash out and retire in the Hamptons.

Will bagholding be a line on a resume?4

Nope.  Few if any of these personalities will be debunked let alone dragged to court.  Consider this well-crafted title from Bloomberg last month: “The Hottest ICOs Are the Ones That Have Done the Least Amount of Work.”

How many of the most egregious examples of investors and advisors that promoted these will be held accountable?  Probably very few even though the SEC put out a press release specifically around the promotion of ICOs… we still regularly see ads for ICOs on social media (e.g., “general solicitation”).

For those hoping that techbros and their apologists will be held accountable, this is probably not that year.  This includes lobbying groups involved in disinformation campaigns for their own ideological purposes.

(4) Enterprise-related DLT efforts generate recurring enterprise license-based revenue

If we were to aggregate the amount of revenue generated by enterprise-focused DLT vendors, based on the known RFPs that were won last year and are currently being bid on, I’d guesstimate that about $100 – $200 million is at play this year.  This is based on the fact that most RFPs seem to be for less than $10 million.  It’ll take at least 6-12 months to build an MVP and then even longer to get approval for additional phases.

As mentioned in my previous post: unfortunately our sample size of big infrastructure builds on the enterprise side is still limited.  Examples include the the DA / ASX deal (which took 2 years for a final decision to be made).  Another large one is the DTC trade, the vendor of which is IBM.  If built and put into production, these will eventually recoup costs but the bigger revenue will likely come from actual enterprise-licenses: seats to use the network.

For an inside perspective, I reached out to one of my close friends working at a DLT vendor who provided the following view:

This year’s revenue is one thing. There is also recurring revenue (run vs build).  There is also the fact that last year some/many deals were “bought” for marketing and credential building purposes (so they are subsidized).  But I think this year suppliers are less willing to buy the business and bid low on price. We (the industry) could be in steady state production by year end for some implementations.  I think $100-200m is broadly right for revenue to play for this year.

His estimate included Q/A support and SLAs.

I also would predict that, just like last year, there will be very few new enterprise-focused vendors entering the market from the early stage startup world.  And that enterprise vendors struggle as a whole to attract and retain junior developers because they have to compete with cryptocurrency-related projects that may provide higher compensation during this bull market.

(5) Cryptocurrencies as financial market infrastructure

I think this is the least likely theme to occur this – and we should thank the gods – is using a cryptocurrency (anarchic) chain as FMI.  Despite the mud that coin lobbyists and evangelists throw at enterprise-focused DLT vendors, cryptocurrency networks are systemic risks to the financial world and should be avoided at this time.

It is one thing to have a coin bubble driven by unsophisticated retail investors.  It is another to have a coin bubble because of leverage and integration with some real financial instruments.  And it is another to have a coin bubble – and the mission critical systems of the world’s financial intermediaries – directly impacted by these coin fluctuations and not be able to hold any of the validating nodes accountable… because they are pseudonymous miners in a jurisdiction that doesn’t recognize the standing of a foreign lawsuit.

If you are reading this, you are probably not terribly sympathetic to anyone who loses their shirt at this time for buying some random coin.  On the other hand, you would be justified if you are worried that a national payment or securities depository is being run on top of Bitcoin via some kind of colored coin Rube Goldberg system.  Reducing systemic risks to the financial world has been a top priority of financial regulators since 2008.

At the time of this writing, none of the existing cryptocurrencies being built seems to have gone through or respects a PFMI check-off.  Or maybe that is a risk regulators and regulated financial institutions will be willing to take?

Final remarks

As a friend recently said, with cryptocurrencies you always have to expect the unexpected.  People are quick to forget the bear market of 2014-2015.  Will the irrational exuberance die down once most of these cryptocurrency and ICO projects fail to deliver on their promises?  Maybe not, but then again, check out the coin rankings over time on these four charts.

I am actually kind of optimistic for new ideas being tested out in certain ecosystems, like Ethereum (note: this is not an endorsement of Ethereum or ETH/ETC).  Now that proof-of-stake, via Casper, is being brought out of the lab and onto a testnet, we might be able to scratch off the environmental impact issue that is a blight on proof-of-work networks.  CryptoKitties, via ERC721, is a neat demonstration of how to potentially create non-fungible property (assuming courts recognize it as such).  I have been giving this some thought on other areas that this could be reused and commercialized.  Note: there is an entire, virtual zoo of copy cats that has now arrived, including puppies and other animals.

What do you think, will heads begin to roll as law enforcement learns what shenanigans are going on?  Will an ETF-based on bitcoin futures be approved?  It seems likely that the CME and CBOE will add futures trading for ether, what about other coins? Coinbase and several other former bitcoin-only exchanges have already announced that they will add more altcoins and everybody is guessing which one will be next.  Will 2018 be a repeat of 2014 with altcoin mania again dominating mindshare?

Endnotes

  1. One reviewer who works at an OTC desk commented: “Almost all of the OTC trading counterparties and exchange we have use just a couple banks.  It would be trivial to cut the spigot off overnight.  Also if I’m a regulator and want to go after the toxic sludge flowing through the fiat side of this world I hit one of these banks that provides the liquidity.” []
  2. One trader at an OTC desk commented that: “Real institutional liquidity, beyond what we have now, would help. I’d argue part of the reason why things get so out of hand so fast is because the market infrastructure isn’t there to handle it correctly.” []
  3. One reviewer at an exchange commented: “I think regulatory scrutiny is actually gonna land next year from CFTC and SEC in a real way.  The CFTC in particular has a duty now to police spot, wait till we get the first settlement of CME or CBOE where someone intentionally puts the auction in the tank or DoS’s the exchanges.” []
  4. Most traders only brag about their winning trades, not their losses. []

Six bedtime stories from 2017

[Note: I neither own nor have any trading position on any cryptocurrency.  I was not compensated by any party to write this.  The views expressed below are solely my own and do not necessarily represent the views of my employer or any organization I advise.  See Post Oak Labs for more information.]

2017 taught us many things, including the fact that no one reads (or writes) or pays for long-form content any more.  Even with lovable memes and animated gifs, keeping an audience’s attention is hard.

Already too distracted to read further?  How about a quick video from JP Sears on how to appropriately Bitcoin Shame your friends and family:

The other takeaway for 2017 is that, if in doubt, open up hundreds of social media accounts and shill your way to riches.  The worst thing that could happen is no one buys your coin.  The best thing that happens is that someone buys your coin and you can then convert the coin into real money, retire, and act like you are super-wise thought leader with oodles of entrepreneurial and investing experience.

Some other stories with revisiting from the past year:

(1) “Legitimization”

If we were being intellectually honest we would say that the only goal post anyone cared about this year was that the price of cryptocurrencies, as measured in real money, and how high they soared.1 And that the main reason this occurred is because Bob knew Alice and Carol were both going to buy a lot of say, bitcoin, thereby pushing up the price, so he did too.  The Economist called it “the greater fool theory.”  But The Economist are great fools for not buying in at $1, so let’s ignore them.

Basically none of the feel-good goals about lowering remittance fees or increasing financial inclusion promoted in previous years by enthusiasts have really materialized.  In fact, at-risk users and buyers in developing economies probably got screwed on the ICO bandwagon as insiders and sophisticated investors who were given privileged early access to pre-sales, dumped the coins on secondary markets and hoi polloi ended up holding the bag on dozens of quarter-baked ICOs.2

Oh, but transaction fees for Bitcoin are at all-time highs, that’s a real milestone right?

There are many reasons for this, including the fact that Bitcoin Core’s scaling roadmap has thus far failed to achieve its advertised deadlines (see section 5 below).3 Maybe that will change at some point.

Shouldn’t higher fees be a cause for celebration with “champaign” (sic)? 4

Some Bitcoin Core representatives and surrogates have created an ever expanding bingo card of scapegoats and bogeymen for why fees have gone up, ranging from:

  • blaming Roger Ver and Jihan Wu as demonic-fueled enemies of Bitcoin
  • to labeling large chunks of transactions as ‘spam attacks’ from nefarious Lizard-led governments5
  • to flat out bitcoinsplaining: higher fees is what to expect when mass adoption takes place!

I’m sure you’ll be on their bingo card at some point too.

Just like Visa and other widely used payment network operators charge higher and higher rates as more and more users join on… oh they don’t.6 But that’s because they censor your freedom loving transactions!  Right?

So what’s the interim solution during this era of higher fees?  Need to send a bitcoin payment to someone?

You know how supermarkets used to hold items on layaway?  They still do, but it’s not as common to use, hence why you googled the term.  Well, in light of high fees, some Bitcoin Core developers are publicly advising people to open up a “tab” with the merchant.  You know, just like you do with your favorite local bartender.

Fun fact: the original title of the Satoshi whitepaper was, Bitcoin: a peer-to-peer electronic layaway system.

This faux comparison didn’t age well.  In 2014 this was supposed to be a parody. (Source)

For example, the ad above was promoted far and wide by Bitcoin enthusiasts, including Andreas Antonopoulos who still tries to throw sand in Western Union’s eye.  Seriously, watch the linked video in which Antonopoulos claims that Bitcoin will somehow help the poor masses save money such that they can now invest in and acquire clean water.  It’s cringe worthy.  Did Bitcoin, or Bitcoin-related businesses, actually do any of the things he predicted?  Beyond a few one-time efforts, not really.7 Never mind tangible outcomes, full steam ahead on the “save the world” narrative!

Many enthusiasts fail to incorporate in their cartoonish models: that the remittance and cross border payment markets have a set of inflexible costs that have led the price structure to look the way it does today, and a portion of those costs, like compliance, have nothing to do with the costs of transacting.8  There may be a way of reducing those costs, but it is disingenuous (and arguably unethical) to pull on the heart strings of those living on subsistence in order to promote your wares.9

Rather than repeat myself, check out the break down I provided on the same Western Union example back in 2014.  Or better yet, look at the frequently updated post from Save on Send, who has the best analysis bar none on the topic.

Back to loathing about ‘adoption’ numbers: few people were interested in actual usage beyond arbitrage opportunities and we know this because no one writes or publishes usage numbers anymore.10 I’ll likely have a new post on this topic next quarter but for a quick teaser: BitPay, like usual, still puts out headline numbers of “328% growth” but doesn’t say what the original 2016 baseline volume was in order to get the new number today.

I don’t strive to pick on BitPay (to be fair they’re like the only guys to actually publish something) but unfortunately for them, the market still has not moved their way: Steam recently dropped support for Bitcoin payments and a Morgan Stanley research note (below) showed that acceptance from top 500 eCommerce merchants dropped from 5 in 2016 to 3 in 2017.11

“This is possibly the saddest bitcoin chart ever” – BI. Source: Morgan Stanley

Due to a lack of relevant animated gifs, a full break down on the topic wouldn’t fit in this article.  But just a quick note, there were a number of startups that moved decisively away from their original stated business case of remittances and instead in to B2B plays (BitPesa, Bitspark) or to wallets (Abra). 12  These would be worth revisiting in a future article.13

So what does this all have to do with “legitimization”?

If you haven’t seen the Godfather trilogy, it’s worth doing so during or after the holiday break.14

This year we have collectively witnessed the techbro re-enactment of Godfather: Part 3 with the seeming legitimization of online bucket shops and dodgy casinos, aka cryptocurrency intermediaries, you wouldn’t talk about in polite company.

All of the worst elements of society, like darknet market operators, hate groups, and malware developers, effectively got eff you money and a cleansing mainstream “exit” courtesy of financial institutions coming in and regulators overwhelmed by all of the noise.15  Just like in No Country for Old Men, the bad guy(s) sometimes win.  This isn’t the end of that story but the takeaway for entrepreneurs and retail investors: don’t work or build anything. Just shill for coins on social media morning, noon, and night.

(2) Red Scares

I am old enough to remember back in 2013 when Bitcoin “thought leaders” welcomed Chinese Bitcoin users.  In late 2013, during the second bull run of that year, there were frequent reddit threads about how mainland Chinese could use Bitcoin to route around censorship and all the other common civil libertarian tropes.

Guess what happened?  On December 5th, 2013, the People’s Bank of China and four other ministries issued guidance which restricted activities that domestic banks could do with cryptocurrencies, thereby putting spot exchanges in a bit of a bind, causing panic and subsequently a market crash.  Within days there were multiple “blame China” threads and memes that still persist to this day.  Case in point: this thread titled, “Dear China” which had Mr. Bean flipping off people in cars, was voted to the top of /r/bitcoin within a couple months of the government guidance.  Classy.

As I detailed in a previous post, earlier in the autumn, several state organs in China finally closed down the spot exchanges, which in retrospect, was probably a good decision because of the enormous amounts of scams and deception going on while no one in the community was policing itself.16 In fact, some of the culprits that led Chinese exchanges into the dishonesty abyss are still around, only now they’re working for other high-profile Bitcoin companies. 17  Big surprise!

For example, Reuters did an investigation into some of the mainland exchanges this past September, prior to the closure of the spot exchanges.  They singled out BTCC (formerly BTC China) as having a checkered past:

Internal customer records reviewed by Reuters from the BTCChina exchange, which has an office in Shanghai but is stopping trading at the end of this month, show that in the fall of 2015, 63 customers said they were from Iran and another nine said they were from North Korea – countries under U.S. sanctions.

It’s unclear how much volume BTCC processed on behalf of North Koreans, one former employee says the volumes were definitely not zero.18 These were primarily North Koreans working in China, some in Dandong (right across the border).

For perspective: North Korea has been accused of masterminding the WannaCry ransomware attack and also attacking several South Korea exchanges to the tune of around $7 million this year.  Sanctions are serious business, check out the US Department of Treasury resource center to learn more.19

Isn’t China the root of all problems in Bitcoinland?

Source: Twitter

The sensationalism (above) is factually untrue yet look how many people retweeted and liked the quickly debunked conspiracy theory.  It’s almost as if, in the current mania, no one cares about facts.

As Hitchens might say: that which can be asserted without evidence, can be dismissed without evidence.  So to are the conspiracies around Bitcoin in China:

  • Is the Chinese government nationalizing Bitcoin?  No.
  • Is the Chinese government responsible for Bitcoin Cash.  No.
  • Is the Chinese government behind the rise in CryptoKitties. No.

In this bull market it is unclear why Paul has to resort to PR stunts, like making fearmongering tweets or opening a strike/call option at LedgerX with the bet that bitcoin will be worth $50,000 next year.20 There are many other ways to better utilize this capital: rethink investing in funds run by managers who are not only factually wrong but who spread fake rumors around serious issues like nationalization.

For instance, I don’t normally publicly write about who I meet, but this past July, while visiting Beijing I sat down with about a dozen members of their ‘Digital Money‘ team (part of the People’s Bank of China group involved in exploring and researching blockchain-related topics). 21 They had already spoken with my then-current employer as well as many other teams and companies (apparently the Zcash team saw them the very next day). While I don’t want to be perceived as endorsing their views, based on my in-depth discussion that day, this Digital Money team had clearly done their homework and heard from all corners of the entire blockchain ecosystem, both cryptocurrency advocates and enterprise vendors. They were interested in the underlying tech: how could the big umbrella of blockchain-related technology improve their financial market infrastructure?

Look at it another way: the Chinese government (or any government for that matter) has no need to nationalize Bitcoin, what value would it bring to them?  It would just be a cost center for them as miners don’t run for free.22  In contrast, their e-RMB team, based out of Shenzhen, has been experimenting with forks/clones of Ethereum.  This is public information.

But what about Jihan and Bitmain?  Aren’t they out to kill Bitcoin?

I can’t speak on his intentions but consider this: as a miner who manufacturers and sells SHA256 hardware that can be used by both Bitcoin and Bitcoin Cash (as well as any SHA256 proof-of-work coin), Bitmain benefits from repeat business and satisfied customers.  It is now clear that the earlier Antbleed campaign effort to demonize Bitmain was a massive PR effort to create a loss of confidence in Bitmain as it was promoted by several well known Bitcoin Core supporters and surrogates to punish Bitmain for its support for an alternative Bitcoin scaling roadmap and client.  In fact, as of this day, no one has brought forth actual evidence beyond hearsay, that covert ASICBoost is/was taking place.  Maybe they did, but you’d need to prove this with evidence.

Speaking of PR campaigns and mining…

(3a) Energy usage / mining

Over the past two months there have probably been more than a dozen articles whitewashing proof-of-work mining energy consumption numbers.  Coin Center, a lobbying group straight out of Thank You for Smoking, has its meme team out on continuous social media patrols trying to conduct damage control: no one must learn that Bitcoin mining isn’t free or that it actually consumes resources!

Source: Twitter

The title of the article above is complete clickbait BS.  Empirically proof-of-work mining is driving miners to find regions of the world that have a good combination of factors including: low taxes, low wages, low energy costs, quick time-to-market access (e.g., being able to buy and install new hashing equipment), reliable energy, reliable internet access, and low political turmoil (aka stability).23  Environmental impact and “clean energy” are talking points that Van Valkenburgh allege, but don’t really prove beyond one token “we moved to renewables!” story.  The next time Coin Center pushes this agenda item, be sure to just ask for evidence from miners directly.24.

Another example is in a recent Bloomberg View column from Elaine Ou (note: the previous company that she co-founded was shut down by the SEC).  She wrote:

Digital currency is wasteful by design. Bitcoin “miners,” who process transactions in return for new currency, must race to solve extremely difficult cryptographic puzzles. This computational burden helps keep the transaction record secure — by raising the bar for anyone who would want to tamper with it –- but also requires miners to build giant farms of servers that consume vast amounts of energy. The more valuable bitcoin becomes, the more miners are willing to spend on equipment and electricity.

Mining a proof-of-work coin (such as Bitcoin) can only be as ‘cheap‘ or ‘efficient’ as the block reward is worth. As the market price of a coin increases so too does the capital expended by miners chasing seigniorage.  This, we both agree on.

In the long run, proof-of-work miners will invest and consume capital up to the threshold in which the marginal costs of mining (e.g., land, labor, electricity, taxes, etc.) roughly equals the marginal revenue they receive from converting the bitcoins into foreign currency (aka real money) to pay those same costs.  This, we also both agree on.

What Ou makes a mistake on is in her first sentence: digital currencies are not all wasteful, only the proof-of-work variety are.  Digital currency != cryptocurrency.25

I know, I know, all other digital currencies that are not proof-of-work are crap coins and those who make them are pearl-clutching morons.  Contra Ou and Coin Center, it is possible for central banks, and even commercial banks, to issue their own digital currency — and they could do so without using resource intensive proof-of-work.26  The Bank of International Settlements recently published a good paper on the various CBDC models out there, well worth a read.  And good news: no mountains of coal are probably used in the CBDC issuance and redemption process.27

Back to proof-of-work coins: a hypothetically stable $1 million bitcoin will result in a world in which miners as a whole expend up to $1 million in capital to mine.  If the network ever became cheaper to operate it would also mean it is cheaper to permanently fork the network.  You can’t have both a relatively high value proof-of-work coin and a simultaneously non-resource intensive network.

While it is debatable as to whether or not Bitcoin mining is wasteful or not, it empirically does consume real resources beyond the costs of energy and the externalization of pollution onto the environment.  The unseen costs of hash generation for a $20,000 bitcoin is at least $13 billion in capital over a year that miners will eventually consume in their rent-seeking race albeit from a combination of resources.

Data source: BitInfoCharts

I quickly made the chart (above) to illustrate this revenue (or costs depending on the point of view).28 These are the eight largest proof-of-work-based cryptocurrencies as measured by real money market prices.

There are a few caveats: (1) some of the block rewards adjust more frequently than others (like XMR); (2) some of the coins have relatively low transaction fees which equates to negligible revenue so they were not included; (3) the month of December has seen some very high transaction fees that may or may not continue into 2018; (4) because block generation for some of these is based on an inhomogeneous Poisson process, blocks may come quicker than what was supposed to be “average.”

How to interpret the table?

The all-time high price for Bitcoin was nearly $20,000 per coin this year.  If in the future, that price held stable and persisted over an entire year, miners would receive about $13 billion in block rewards alone (not including transaction fees).  Empirically we know that miners will deploy and consume capital up to the point where the marginal costs equals the marginal value of the coin.29  So while there are miners with large operating margins right now, those margins will be eaten up such that about $13 billion will eventually be deployed to chase and capture those rewards.  Consequently, if all 8 of these proof-of-work coins saw their ATH extended through 2018, ceteris paribus, miners would collectively earn about $32.6 billion in revenue (including some fees).

There are a variety of sites that attempt to gauge what the energy consumption is to support the network hashrate.  Perhaps the most frequently cited is Digiconomist.  But Bitcoin maximalists don’t like that site, so let’s put together an estimate they cannot deny (yes, there are climate change denialists in the cryptocurrency world).

For the month of December, the network hashrate for Bitcoin hovered around 13.5 exahash/second or 13.5 million terahash/second (TH/s).

To get a lowerbound on how many hash-generating machines are being used, let’s look at a product called the S9 from Bitmain.  It is considered to be the most “efficient” off-the-shelf product that public consumers can order in volume.30 This mining unit generates around 13.5 TH/s.

So, if we were to magically wave our hands and replace all of the current crop of Bitcoin mining machines into the most efficient off-the-shelf product, we’d need about 1 million of these to be manufactured, shipped, installed, and maintained in order to generate the equivalent hashrate that the Bitcoin network has today.  Multiply 1 million S9’s times the amount of energy individually used by a S9 and you’d get a realistic lowerbound energy usage for the network today.31

Note: this doesn’t factor in land prices, energy costs, wages for employees, building the electrical infrastructure (e.g., installing transformers), and many other line items that are unseen in the chart above.  It also doesn’t include the most important factor: as more mining hashrate is added and the difficulty rating adjust upward, it dilutes the existing labor force (e.g., your mining unit does not improve or become more productive over time).

(3b) Energy usage upperbound

So what are the upperbound costs?

Source: Twitter

The tweet above is not a rare occurrence.  If you are reading this, you probably know someone who tried to mine a cryptocurrency from an office computer or maybe their computer was the victim of ransomware.

You may not think of much of the externalization and socialization of equipment degradation that is taking place, but because mining is a resource intensive process, the machines used for that purpose depreciate far faster than those with normal office usage.32  To date, no one has done a thorough analysis of just how many work-related computers have been on the receiving end of the mining process but we know that employees sometimes get caught, like the computer systems manager for the New York City Department of Education or the two IT staffers in Crimea.33

Even if miners eventually fully utilize renewable energy resources, most hash-generating machines currently deployed do not and will not next year.  These figures also do not factor in the fully validating nodes that each network has that run out of charity (people run them without any compensation) yet consume resources.  According to Bitnodes, Bitcoin has around 11,745 nodes online. According to EtherNodes, Ethereum has around 26,429 nodes online.

So is there an actual upperbound number?

There is, by dividing hashpower by cost and comparing to costs of various known processor types.  For instance, see this footnote for the math on how two trillion low-end laptop CPUs could be used.3435

Just looking at the hash-generating machines, according to Chen Min (a chip designer at Avalon Mining), as of early November, 5% of all transistors in the entire semiconductor industry is now used for cryptocurrency mining and that Ethereum mining alone is driving up DRAM prices.

This is not to say you should march in the streets demanding that miners should forgo the use of coal power plants and only use solar panels (which of course, require consumption of resources including semiconductors), there are after all, many other activities that are relatively wasteful.

But some Bitcoin and cryptocurrency enthusiasts are actively whitewashing the environmental impact of their anarchic systems and cannot empirically claim that their proof-of-work-based networks are any less wasteful or resource intensive than the traditional foreign capital markets they loathe.

In point of fact, while the traditional financial markets will continue to exist and grow without having to rely on cryptocurrencies for rationally pricing domestic economic activity, in 2018, as in years prior, Bitcoinland is still fully dependent on the stability of foreign economies providing liquidity and pricing data to the endogenous labor force of Bitcoin.  Specifically, I argue in a new article, that miners cannot calculate without using a foreign unit of account; that economic calculations on whether or not to deploy and consume capital for expanding mining operations can only be done with stable foreign currency.36

Keep in mind that cryptocurrencies such as Bitcoin only clear (not settle) just one coin (or token) whereas traditional financial markets manage, transact, clear and settle hundreds of different financial instruments each day. 37  For comparison, the Federal Reserve estimates that on any given day about 600 million payment, clearing, and settlement transactions take place in the US representing over $11 trillion in value.38  But this brings up a topic that is beyond the scope of this article.  Next section please.

(4) MIT’s Digital Currency Initiative

On the face of it, MIT’s DCI effort makes a lot of sense: one of the world’s most recognized institutions collaborating with cryptocurrency developers and projects worldwide.

But beneath the slick facade is a potential conflict of interest that has not been looked at by any media outlet.  Specifically, around its formal foray into building tools for central bank digital currency (CBDC).  Rob Ali, a well-respected lawyer turned research scientist (formerly with the Bank of England), was hired earlier this year by DCI to build and lead a team at MIT for the purpose of continuing the research he had started at the BoE.  This is no secret.

Less known is how this research has now morphed into a two-fold business:

  1. DCI charges central banks about $1 million a year to be a partner.39  What this allows the central bank to do is send staff to MIT and tap into its research capabilities.  This includes MIT representatives co-authoring a couple of papers each year focused on topics that the central bank is keen to explore.  Multiple central banks have written checks and are working together with DCI at this time.
  2. Building and licensing tools and modules to central banks and commercial banks.  DCI has hired several Bitcoin developers whom in turn have cloned/forked Bitcoin Core and Lightning.  Using this code as a foundation, DCI is building IP it aims to license to central banks who want to build and issue central bank digital currency.

Where is the conflict of interest?

DCI is housed within MIT’s Media Lab, whose current director is Joi Ito.  Ito is also the co-founder and director of Digital Garage.  Digital Garage is an investor in Blockstream and vocal advocate of Lightning; coincidentally Blockstream is building its own Lightning implementation. Having made several public comments in favor of Bitcoin Core’s hegemony, Ito also appears to be a critic of alternative blockchain implementations.

In looking at his publicly recorded events on this topic Ito does not appear to disclose that the organizations he co-runs and invests in, directly benefit from the marketing efforts that Bitcoin Core and Lightning receive.  Perhaps this is just miscommunication.

I’m all for competition in the platform and infrastructure space and think central bank digital currencies are legit (again check out this BIS paper) but this specific DCI for-profit business should probably be spun off into an independent company.  Why?  Because it would help reduce the perception that Ito – and others developers involved in it – benefits from these overlapping relationships.  After all, Bitcoin Core arguably has a disproportional political clout that his investment (Blockstream) potentially benefits from if/when Lightning goes into production.40 And again, this is not to say there shouldn’t be any private-public partnerships or corporate sponsorships of academic research or that researchers should be prohibited in investing in companies, rather just a recommendation for disclosure and clarity.

(5) Lightning Network

If you haven’t seen The Money Pit (with Tom Hanks), it is well worth it for one specific reason: the contractors and their staff who are renovating Hanks’ home keep telling Hanks that it will be ready in two weeks.

And after those two weeks are over, Hanks is informed yet again that it will be ready in another two weeks.

The Lightning Network, as a concept, was first announced via a draft paper in February 2015. Its authors, Tadge Dryja and Joseph Poon, had initially sketched out some of the original ideas at their previous employer Vaurum (now called Mirror).

Lightning, as it is typically called, is commonly used in the same breath as “the scaling solution,” a silver bullet answer to the current transactional limitations on the Bitcoin network.41 Nearly three years later, after enormous hype and some progress, a decentralized routing version still has not gone into production.  Maybe it will eventually but not one of its multiple implementations is quite ready today unless you want to use a centralized hub.42  Strangely, some of the terminology that its advocates frequently use, “Layer 2 for settlement,” is borderline hokum and probably has not been actually vetted to see if it fulfills the requirements for real “settlement finality.”43

And like multiple other fintech infrastructure projects, some of its advocates repeatedly said it would be ready in less than 6 months, several times.  For instance:

  • On October 7, 2015, Pete Rizzo interviewed multiple developers including Tadge Dryja and Joseph Poon regarding Lightning.  Rizzo wrote that: “In interview, Dryja and Poon suggested that, despite assertions project development could take years, Lightning could take as little as six months to be ready for launch.”
  • On April 5, 2016, Kyle Torpey interviewed Joseph Poon regarding expected time lines, stating that: “Lightning Network co-creator Joseph Poon recently supplied some comments to CoinJournal in regards to the current status of the project and when it will be available for general use. Poon claimed a functional version of the Lightning Network should be ready this summer.”
  • A month later, on May 5, 2016, Kyle Torpey interviewed Adam Back regarding his roadmap.  Torpey wrote that: “While all of these improvements are being implemented on Bitcoin’s base layer, various layer-2 solutions, such as the Lightning Network, can also happen in parallel. The Lightning Network only needs CHECKSEQUENCYVERIFY (along with two other related BIPs) and Segregated Witness to be accepted by the network before it can become a reality on top of the main Bitcoin blockchain.”
  • On November 12, 2016, Alyssa Hertig interviewed several developers including Pierre-Marie Padiou, CEO of ACINQ, one of the startups trying to building a Ligthning implementation.  According to Padiou: “The only blocker for a live Lightning implementation is SegWit. It’s not sure how or when it will activate, but if SegWit does activate, there is no technical thing that would prevent Lightning from working.”

Segregated Witness (SegWit) was activated on August 24, 2017.  More than four months later, Lightning is still not in production without the use of hubs.

Source: Twitter

Not to belabor the point, just this past week, one of the executives at Lightning Labs (which is building one of the implementations) was interviewed on Bloomberg but wasn’t asked about their prior rosy predictions for release dates.  To be fair, there is only so much they could cover in a six minutes allocation.

“Building rock solid infrastructure is hard,” is a common retort.

Who could have guessed it would take longer than 6 months?  Yes, for regular readers of my blog, I have routinely pointed out for several years that architecting and deploying financial market infrastructure (FMI) is a time consuming, laborious undertaking which has now washed out more than a handful of startups attempting to build “enterprise” blockchains.

For example, Lightning as a concept predates nearly every single enterprise-focused DLT vendor’s existence.  While not an equal comparison (they are trying to achieve different goals), there are probably ~5 enterprise-focused, ‘permissioned’ platforms that are now being used in mature pilots with real institutional customers and a couple could flip the “production” button on in the next quarter or so.4445

For what it is worth, enterprise DLT vendors as a whole did a very poor job managing expectations the past couple of years (which I mentioned in a recent interview).  And they certainly had their own PR campaigns during the past couple of years too, there is no denying that.  Someone should measure and quantify the amount of mentions on social media and news stories covering enterprise vendors and proposals like Lightning.46

Better late than never, right?  So what about missed time frames?

In a recent (unscientific) poll I did via Twitter (the most scientific voting platform ever!) found that of the more than 1,600 voters, 81% of respondents thought that relatively inexpensive anonymous Lightning usage won’t really be good to go for at least 6+ months.

Just as Adam Back proposed a moratorium on nebulous “contention” for six months (beginning in August), I propose a moratorium on using the term “Lightning” as a trump card until it is actually live and works without relying on hubs.  But don’t expect to see the crescendo of noise (and some signal) to die down in the meantime, especially once exchanges and wallets begin to demonstrate centralized, MSB-licensed implementations.47

With that suggestion, I can see it now: all of the Lightning supporters flaming me in unison on Twitter for not being a vocal advocate.  Sure beats shipping code!  To be even handed, Lightning’s collective PR effort was just one of many others (hello sofachains!) that could be scrutinized.  A future post could look at all funded infrastructure-related efforts to improve cryptocurrency networks.  Which ones, if any, showed much progress in 2017. 48

Interested in reading more contrarian views on the Lightning Network?  See Gerard and Stolfi (and Stolfi2x) (and Stolfi3x).  Let’s revisit in 6 months to see what has been launched and is in production.

(6) Objective reporting and analysis

Without sugar coating it: with the exception of a few stories, coin media not only dropped the ball on critically, objectively covering ICO mania this past year, but was largely complicit in its mostly corrupt rise.  This includes The Information, which is usually stellar, but seems to have fallen in the tank with the ICO pumpers.  That is, unless you’re a fake advisor and then they’ve got your number.

It took some time, but eventually mainstream and a few not-so-mainstream coverage has brought a much needed spotlight on some of the shady actions that took place this year. There were also a number of good papers from lawyers and academics published throughout 2017.

Your holiday reading list in no particular order:

One of my favorite articles this year should be yours too:

Just a few short months after Stephen Palley published the article above, a lawsuit occurred in which, surprise surprise, the plaintiffs highlighted specific claims in the white paper:

Source: Twitter

Note: that the SEC’s order against the Munchee ICO also relied on highlighting specific claims in the white paper.

Concluding remarks

Unfortunately 2017 will probably go down as the year in which several generations of nerds turned into day-trading schmucks, with colorful technical charts and all.50 This included even adopting religious slogans like:  Buy the dip!  Weakhands!  HODL!  We are the new 1%!  The dollar is crashing!  It’s not a bubble, it’s an adoption curve!

A few parting bits of advice: unfollow anyone that says this time things are different or the laws of economics have changed or calls themselves a “cryptolawyer” or who previously got shutdown by the SEC or who doesn’t have a LinkedIn page.  Rethink donating or investing funds to anyone who makes up rumors about mining nationalization or who was fired for gambling problems or has a communications team solely dedicated to designing memes for Twitter.51

Cryptocurrencies aren’t inherently bad and ideas like ERC721 are even cool.52 But as neat as some of the tech ideas may be, magic internet coins sure as heck continue to attract a lot of Scumbag Steves who are enabled by participants that have turned a blind eye.  It’s all good though, because everyone will somehow get a Moonlambo after the final boss is beaten, right?

Coda

I will have a separate post discussing predictions for 2018 but since we are reflecting on 2017, below are a few other areas worth looking into now that you’re a paper zillionare:

  • We have real empirical observation of hyperdeflation occurring: in which it is more rational to hoard the coin instead of spend it.  As a result, Bitcoin-focused companies that have accumulated bitcoin are still raising capital from external financial markets denominated in foreign currency instead of deploying (consuming) their own bitcoin. And these same startups are receiving valuations measured, not in terms of bitcoin, but in terms of a foreign unit of account.  What would change this trend?
  • Bitcoinland, with its heavy concentration of wealth, looks a lot like a feudal agrarian economy completely dependent on other countries and external financial markets in order to rationally deploy capital and do any economic calculation. Is there a way to build a dynamically adjustable cryptocurrency that does not rely on foreign capital or foreign reference rates?
  • How much proof-of-work related pollution has been externalized and socialized on the public at large due to subsidies in various regions like Venezuela?  What are the effects, if any, on global energy markets?
  • As traditional financial markets add products and solutions with direct ties to cryptocurrencies (futures, options, payments, custody), by the end of 2018 how much of the transactional activity on Bitcoin’s edges will be based on non-traditional financial markets (e.g., LocalBitcoins)?
  • There were a lot of publicity stunts this year.  Working backwards chronologically, the Andreas Antonopoulos donation could have been a publicity stunt, it also could be real.  The argument goes: how is someone with a best selling book, who charges $20,000+ for speaking engagements, and who has been receiving bitcoins for years (here is the public address), still in debt.  Maybe he is, maybe his family fell on hard times.  But few asked any questions when an anonymous person sent what amounted to $1 million in bitcoin enabling him to reset his tax basis.  (Hate me for writing this?  As an experiment, earlier this month I put up a Bitcoin and Ethereum address on the sidebar of the home page, feel free to shower me with your magic coins and prove me wrong.  I promise to convert it all into dirty filthy statist bucks.)  A few months prior to that, Jamie Dimon was accused of everything but eating babies after he said “Bitcoin is a fraud.”  Dozens of “Dear Jamie” letters were written begging him to see Bitcoin with their pure rose-tinted eyes.  At what point will Bitcoin enthusiasts grow some thick skin and ignore the critics they claim don’t matter?  And while we can continue to add PR stunts forever, the “fundraiser” for Luke-Jr’s home after Hurricane Irma had zero proof that it was his house, just a picture that Luke-Jr. says it was and the rest of the Bitcoin Core fan club promoting it.  Trust but verify?

[Note: if you found this research note helpful, be sure to visit Post Oak Labs for more in the future.]

Acknowledgements

Many thanks to the following for their constructive feedback: VB, YK, RD, CM, WG, MW, PN, JH

End notes

  1. Bitcoin fans basically walked onto the field before the football game, toppled the goal posts, and carried it outside the stadium declaring themselves victorious without having actually played the match. []
  2. How many of these unsophisticated buyers have subsequently lost the corresponding private keys?  See “Nearly 4 Million Bitcoins Lost Forever, New Study Says” from Fortune []
  3. I am sure I will be accused of being a “Bitcoin Cash shill” (which obviously I must be, there is no other explanation!) for pointing this out, but last week, one vocal Bitcoin Core supporter even proposed a commit to change the wording on Bitcoin.org surrounding low fees: “These descriptions of transaction features are somewhat open to interpretation; it would probably be best not to oversell Bitcoin given the current state of the network.” []
  4. As an actor on a classic Saturday Night Live sketch said: “You may ask how we at the Change Bank, make money? It’s simple, volume.” []
  5. I take issue with anyone claiming to be able to label transactions specifically as spam without doing an actual graph analysis.  See Slicing Data for more. Proof-of-lizard is not to be conflated with lizardcoin. []
  6. Note: this is not an endorsement of Visa, I do not have any equity or financial stake in Visa. []
  7. One reviewer commented: “One problem that affects all cryptocurrencies whether proof of work or of stake: What reason do most people have for using them that won’t run afoul of social policy objectives? As long as people need to convert them to regular fiat currencies, they have a distinct disadvantage. The only exception would be in failed economies where stable fiat currencies are restricted, until those governments see a cryptocurrency as a potential substitute and ban it. It is not even clear why a government would need to issue a cryptocurrency (not a CBDC). If it wants to serve unbanked people it could open or subsidize a bank for them which is what is being attempted in a few developing countries.” []
  8. One reviewer commented: “Fully peer-to-peer without banks ultimately leads to creating a new currency. A new currency means that for international payments you have the additional costs of converting into the currency and converting out of the currency. A currency not linked to a real world economy is always going to have a more volatile price (assuming it has any price at all). Volatility in FX always, always leads to higher transaction costs for exchange because the bid offer spread has to be wider. This is before you even get into the mining proof or work model and all its inherent flaws, which again ultimately result from trying to build a financial system without banks.” []
  9. One reviewer noted that: “Transferwise, Currency Fair, Revolut, Mondo and other startups are already doing it. And they’re doing it without having to break the rules and laws banks and Western Union have to play by. They’re building actual real, potentially sustainable businesses that are useful to society. They’re just not grabbing the headlines like the greater fool / Nakamoto Scheme is. When you build a real business, your scope for false promise making behind incoherent computer science jargon is pretty small.” []
  10. I even stopped aggregating numbers 18 months ago because fewer companies were making usage numbers public: it’s hard to write about specific trends when that info disappears.  Note: if you think you have some interesting info, feel free to send it my way. []
  11. BitPay has diversified its portfolio of services now, expanding far beyond the original merchant acceptance and recently closed a $30 million funding round.  However, the problem with their growth claims is they are typically measured in $USD volume. So, as the value of bitcoin has grown 10-20x (as measured in USD) in the past year, it is unclear how much BitPay has really grown in terms of new customers and additional transactions.  Note: the same can be said for most Bitcoin-specific companies making big growth-related claims, BitPay is just one example. []
  12. Movements occurred in other areas too, on the enterprise side, Chain was perhaps the most well known company to pivot away from that vertical. []
  13. One reviewer commented: “2017 was a good year for B2B players with some prominent funding rounds (e.g., Bitspark, Veem, BitPesa) and some claimed growth on blockchain “rails” (but also on non-blockchain) namely Veem and BitPesa. A big surprise of 2017 was a much broader awareness of cryptocurrencies, i.e., free massive PR. The Coinbase app became more popular than Venmo (and far ahead of any bank). As a result, one of the most intriguing questions right now for 2018 is if/how Coinbase could capitalize on this opportunity to become a full-fledged bank leveraging the best of banking-like services from players like Xapo, Uphold, and Luno?” []
  14. I suppose it is safe to assume that if you’re reading this, you are coin millionaire so you don’t worry about fiat-mandated holiday breaks like the rest of us. []
  15. Not all medium-to-large coin holders are the adopters you now see wearing suits on television talk shows.  Most coin holders, including the abusive trolls and misogynists on social media, have seen a large pay raise, enabling the worst elements to continue their bullying attacks and illicit activities.  See Alt-right utilizes bitcoin after crackdown on hate speech from The Hill []
  16. Worth pointing out that Ryan Selkis is attempting to push forward with a the self-regulatory effort called Messari.  See also: The Brooklyn Project. []
  17. Earlier this year, right after the law enforcement raids in China, one of the senior executives left BTCC but still remains on the board of the parent company that operates BTCC.  He quickly found a new senior role at another high-profile Bitcoin-focused company and uses his social media accounts to vigorously promote Bitcoin Core and maximalism. []
  18. As explored in a previous post, fake volumes among the Chinese exchanges was not uncommon and several of the large exchanges attempted to gain funding from venture capitalists while simultaneously faking the usage numbers. As one former employee put it: “That was an extraordinary attempt at fraud — faking the numbers through wash trading and simply printing trades, while using that data to attract investment and establish their valuation.” []
  19. Coinbase got into some problems in early 2015 when one of its investor decks highlighted the fact that cryptocurrencies, such as Bitcoin, could be used to bypass sanctions. []
  20. Ari Paul runs a small “crypto” hedge fund called BlockTower Capital (estimated to have between around $50-$80 million AUM) that like many companies in this space, faces an ongoing lawsuit.  Unclear why LPs didn’t just buy and hold cryptocurrencies themselves and cut out the hysteria and management fees. []
  21. Yea, I know, “money” is already digital… I didn’t give them that name, they did. []
  22. One reviewer noted: “The fact remains that if you replace the mining process with a a centralized system for validation of transactions and up-to-date of balances you could run the whole thing on an ordinary sized server for a few thousand dollars per year. Centralisation and a more logical data model are vastly better technically speaking. And it would be far easier to add in compliance and links to banks for more robust and honest methods for exchanging between a centralized bitcoin and fiat. What would the Chinese government gain from mining?” []
  23. One of the often overlooked benefits of setting up a mining farm in China is that many of the parts and components of mining equipment are either manufactured in China and/or final assembly takes place in China.  So logistically it is much quicker to transport and install the hardware on-site within China versus transport and use overseas. []
  24. I know a bunch and could maybe introduce them though some of them make public appearances at conferences so they can usually be approached or emailed. []
  25. In fact, many regulators, such as the ECB, categorize cryptocurrency as a type of “virtual currency,” separate from a “digital currency.” []
  26. There is often confusion conflating “transaction processing” and “hash generation,” the two are independent activities.  Today mining pools handle the transaction processing and have sole discretion to select any transactions from the memory pool to process (historically there have been thousands of ’empty’ blocks) — yet mining pools are still paid the full block reward irrespective of how many transactions they do or not process.  Hash generation via mining farms has been a discrete service for more than 5 years — think of mining pools as the block makers who outsource or subcontract the hash generation out to a separate labor force (mining farms) and then a mining pool packages the transactions into a block once they receive the correct proof-of-work.  Note: “fees” to miners is a slightly different but related topic. []
  27. CBDCs have their own issues, like the risk of crowding out ordinary banks in market for deposits in a low interest rate environment but they have little in common with anarchic crytocurrencies. []
  28. Many thanks to Vitalik Buterin for his feedback and suggestions here. []
  29. See also: Some Crypto Quibbles with Threadneedle Street from Robert Sams []
  30. There are other mining manufacturers, including some who only build for themselves, such as Bitfury. []
  31. Interestingly enough, the market price for one of these machines is around $2,000.  And if you do the math, you’ll see exactly what all professional miners do: it’d only cost $2 billion to buy enough machines to generate 100% of the network hashrate and claim all the $13 billion in rewards to yourself!  In other words, the seigniorage is big, fat, and juicy… and will attract other miners to come and bid up the price of mining to the equilibrium point. []
  32. There are many walk-throughs of bitcoin mining facilities, including this video from Quartz. []
  33. In the process of writing this article, a new story explained how more than 105,000 users of a Chrome extension were unknowingly mining Monero.  Heroic theft of CPU cycles, right? []
  34. In theory, and practice, the upperbound is not infinite.  We know from the hashrate being generated that there are a finite amount of cycles being spent repeatedly multiplying SHA256 over and over.  Perhaps a possible, but improbable way to gauge the upperbound is to take the processing speed of a low-end laptop CPU (which is not as efficient at hashing as its ASIC cousins are).  At 6 MH/s, how many seventh generation i3 chips would it take to generate the equivalent of 13.5 million TH/s?  On paper, over 2 trillion CPUs.  Note: 1 terahash is 1 million megahashes.  So 1 million laptop CPUs each generating 6 MH/s on paper, would collectively generate around 6 TH/s.  The current network hashrate is 13.5 exahash/s.  So you’d need to flip on north of 2 trillion laptop CPUs to reach the current hashrate.  In reality, you’d probably need more because to replace malfunctioning machines: a low-end laptop isn’t usually designed to vent heat from its CPU throttled to the max all day long. []
  35. One China-based miner reviewed this scenario and mentioned another method to arrive at an upperbound: “Look at the previous generation of ASICs which run at 2-3x watt per hash higher.  The previous generation machines normally get priced out within 18 months.  But with differing electricity costs and a high enough price, these machines get turned on.  Or they go to cheap non-petrodollar countries like Russia or Venezuela. So your base load of 1 million machines will have an upperbound of 2x to 3x depending on prevailing circumstances.” []
  36. It may be also worth pointing out that the “evil Chinese miners blocking virtuous Core” narrative is hard to justify because Bitcoin’s current relatively high fees are a direct result of congestion and has consequently increased miner revenue by 33% (based on December’s fees).  So in theory, it’s actually in the miners interest to now promote the small block position.  Instead, in reality, most miners were and are the ones advocating for bigger block sizes, and certain Bitcoin Core representatives were blocking those proposals as described elsewhere but we’re not going down that rabbit hole today. []
  37. One reviewer commented: “Financial instruments that either directly perform a service to our economy and even indirectly via speculation, enable price discovery for things that are important to people’s lives. Who’s lives is Bitcoin really important to right now? To this day the only markets it can claim to have any significant market share in, let alone be leader in, is illicit trade and ransomware. The rest appears to be just people looking to pump and shill.” []
  38. It’s also probably not worth trying to start a discussion about what the benefits, if any, there is for society regarding cryptocurrency mining relative to the resources it collectively consumes, as the comments below or on social media would simply result in a continuous flame war.  Note: colored coins and metacoins create distortions in the security assumptions (and rewards) for the underlying networks.  Watermarked tokens are neither secure nor proper for financial market infrastructure. []
  39. It is not $1 million straight, there are multiple levels and tiers. []
  40. There is an ongoing controversy around key decision makers within Bitcoin Core (specifically those who approve of BIPs) and their affiliation with Blockstream.  One of Blockstream’s largest investors, Reid Hoffman, said Blockstream would “function similarly to the Mozilla Corporation” (the Mozilla Corporation is owned by a nonprofit entity, the Mozilla Foundation). He likened this investment into “Bitcoin Core” (a term he used six times) as a way of “prioritiz[ing] public good over returns to investors.” []
  41. Because it is its own separate network, it actually has cross-platform capabilities.  However, historically it has been promoted and funded for initial uses on the Bitcoin network moreso than others. []
  42. Yes, I am aware of the demo from Alex Bosworth, it is a big step forward that deserves a pat on the back.  Now to decentralize routing and provide anonymity to users and improve the UI/UX for normal users. []
  43. To start with, see the Principles for Financial Market Infrastructures. []
  44. This is not an endorsement of a specific platform or vendor or level of readiness, but examples would include: Fabric, Quorum, Corda, Axcore, Cuneiform, and Ripple Connect/RCL. []
  45. While Lightning implementations should not be seen as a rival to enterprise chains (it is an apples to oranges comparison), the requirements gathering and technical hurdles needed to be overcome, are arguably equally burdensome and maybe moreso for enterprise-focused companies.  Why?  Because enterprise-focused vendors each need approval from multiple different stakeholders and committees first before they deploy anything in production especially if it touches a legacy system; most Lightning implementations haven’t actually formally defined who their end-customer is yet, let alone their needs and requirements, so in theory they should be able to “launch” it faster without the check-off. []
  46. For instance, CoinDesk currently has 229 entries for “lightning,” 279 entries for “DLT,” and 257 entries for “permissioned.” []
  47. It bears mentioning that Teechain, can achieve similar KPIs that Lightning can, via the use of hardware, and does so today.  BitGo’s “Instant” and payment channels from Yours also attempt to achieve one similar outcome: securely transmitting value quickly between participants (albeit in different ways). []
  48. We’d need to separate that from the enterprise DLT world because again, enterprise vendors are trying to solve for different use cases and have different customers altogether.  Speaking of which, on the corporate side, there is a growing impatience with “pilots” and some large corporates and institutions are even pulling back.  By and large, “blockchain stuff” (people don’t even agree on a definition still or if it is an uncountable noun) remains a multi-year play and aside from the DA / ASX deal, there were not many 2017 events that signaled a shorter term horizon. []
  49. Note: both the Fedcoin and CAD-coin papers were actually completed and sent to consortium members in November 2016 then three months later, published online. []
  50. One reviewer commented: “There seems to be a whole new wave of both suckers and crooks to exploit the geeks. I have read some the Chartist analysis on forums for more traditional forms of day-trading such as FX day-trading and it is exactly the same rubbish of trying to inject the appearance of intelligence and analysis into markets that the day-traders (and those encouraging them) simply do not understand.” []
  51. A former Coinbase employee, now running a “crypto” hedge fund, was allegedly fired for gambling issues.  Maybe he wasn’t but there are a lot of addicts of many strains actively involved in trading and promoting cryptocurrencies; remember what one of the lessons of Scarface was? []
  52. ERC20 and ERC721 tokens may end up causing a top-heavy problem for Ethereum. See Watermarked tokens and also Integrating, Mining and Attacking: Analyzing the Colored Coin “Game” []

External facing appearances for the final months of the year

The past several months have been pretty productive especially in terms of education.

For instance, my “Eight Things” article had over 100,000 views in its first week alone thanks largely to landing on the front page Hacker News and reshares on social media. I may write-up an article breaking down its reception at a later date.

And interestingly, one of my older articles from 2014 recently ended up on the front of /r/DataIsBeautiful generating 15k+ views over a couple of days.

Below are some of my outward facing appearances.  If you’re interested in chatting about the topics below, feel free to reach me via Post Oak Labs.

Interviews

Cited and acknowledged

Panels and presentations

How the CME (un)intentionally weighed in on chain splits

For background, this post assumes you have read some (or ideally all) of the previous posts:

Last year, when the CME first announced that it was considering backing a Bitcoin-related futures product, it also announced the CME CF Bitcoin Reference Rate (BRR).  At the time, the reference pricing data came from the following cryptocurrency exchanges: Bitfinex, Bitstamp, GDAX, itBit, Kraken and OKCoin.com (HK).

As of today, the CME has formally whittled down those six into a smaller group of four exchanges: Bitstamp, GDAX, itBit and Kraken.

They did not publicly disclose why they removed Bitfinex and OKCoin, although we can speculate:

  • It is likely they removed OKCoin because of the laws and regulations around cryptocurrencies in China over the past year included various types of bans.  OKCoin’s mainland spot price exchange for yuan <-> cryptocurrency have been shut down.  OKEX, an international subsidiary of OKCoin, replaced the China-based exchanges on its own index (including OKCoin itself).
  • Bitfinex’s corporate and organizational structure has been described in previous articles.  Even though it has the largest trading volume and is the key player to price discovery, it has a lot of red flags around compliance and transparency (described in the links at the top) that likely made organizations such as the CME uneasy.

It bears mentioning that the proposed Winklevoss COIN ETF also went through a similar evolution in terms of how to price the instrument.  The principals initially created and used the Winkdex.  The Winkdex included many different cryptocurrency exchanges over time, including Mt. Gox and BTC-e.  Eventually, in future amended filings to the COIN ETF, the Winkdex was completely discarded in favor of a daily auction price conducted at an exchange (Gemini) that the principals and creators of the COIN ETF owned and managed.  This is chronicled in a paper I wrote last year.

So what does this have to do with the CME and how did the CME (un)intentionally weigh in on the Bitcoin block size debate?

During the recent Bitcoin Core versus SegWit2X (S2X) political battle, one of the four exchanges that constitute the CME reference rate announced which ticker symbol would be attributed to a specific chain.

GDAX (Coinbase), made the following public announcement on October 25:

In our prior blog post we indicated that at the time of the fork, the existing chain will be called Bitcoin (BTC) and the Segwit2x fork will be called Bitcoin2x (B2X).

Since then, some customers have asked us to clarify what will happen after the fork. We are going to call the chain with the most accumulated difficulty Bitcoin.

We will make a determination on this change once we believe the forks are in a stable state. We may also consider other factors such as market cap and community support to determine stability.

It’s important for us to maintain a neutral position in any fork. We believe that letting the market decide is the best way to ensure that Bitcoin remains a fair and open network.

Note: original emphasis is theirs.

There have been several articles that attempted to track and chronicle what all of the exchanges announced with respect to the ticker symbol and the fork.  At the time of this writing, itBit, Kraken, and Bitstamp have not publicly commented on this specific fork (although they have publicly signaled specific views on other proposed forks in the past).

And this creates a challenge for any financial institution attempting to create a financial instrument that is compromised of a basket of cryptocurrency-specific prices from different, independent cryptocurrency exchanges.

Ignoring the lack of adequate market surveillance for the moment, if there is a future fork and the constituent exchanges that comprise the reference data choose different forks to be represented by the same ticker symbol, this will likely create problems for the financial product.

For instance, in a hypothetical scenario in which a fork occurs, and two of the exchanges comprising the BRR index choose one side of the fork to list as “BTC” and the other two exchanges choose the other fork to also represent “BTC,” because these forks are linked to separate different ecosystems and even economic systems the combination could impact the volatility of the product.

Or in short: there is no universal agreement or consensus from cryptocurrency exchanges comprising the BRR about what the ticker symbol, let alone the chain should be defined as.

Concluding remarks

Over the past several years the primary debate has been around scaling, specifically around block sizes.  What if future forks are fought over changes to transaction fees, money supply, or KYC requirements?  This isn’t idle speculation as these have been proposed in the past with both Bitcoin and other cryptocurrencies (Ethereum Classic  held an event last year to focus on what the future money supply generation rate should be).

Obviously this is a situation the CME (and similar financial institutions) wants to avoid at all costs.

In order to do this, it’ll have to pick a side and either:

a) force an errant exchange on its index to fall in line or lose the free marketing; or

b) ditch it from the index

Either way, as by far the largest player in the market, in doing so it will be governing what Bitcoin is.  Unlike what most Bitcoin promoters often think: traders follow liquidity not the other way around so the CME is likely to become kingmaker in Bitcoin political disputes.  It is going to become a key arm in its governance.  That said, as we have seen before, rather than directly get involved with the tribes and religions of development they might simply defer to the incumbent Bitcoin Core rules — so that they can remain above the politics and out of any legal liabilities.

For more detailed commentary on this topic, be sure to read the articles linked to at the top.  This will be worth re-visiting once the CME and other regulated institutions fully launch their proposed products.

Acknowledgements: special thanks to Ciaran Murray for several insights articulated above.

Bitcoin Is Now Just A Ticker Symbol and Stopped Being Permissionless Years Ago

Financial market infrastructure in just one country (Source)

What is FMI?  More on that later.  But first, let’s talk about Bitcoin.

If you aren’t familiar with the Bitcoin block size war and its endless online shouting matches which have evolved into legal and even death threats, then you have probably been a very productive human being and should sell hugs and not wander into a non-stop social media dance off.

Why?  Because tens of thousands of man (and woman) hours have collectively been obliterated over a struggle that has illuminated that Bitcoin’s development process is anything but permissionless.

It also illuminates the poor fiduciary care that some VCs have towards their LPs.  In this case, more than a handful of VCs do not seem to really care about what a few of their funded companies actually produce, unless of course the quarterly KPIs include “have your new Bitcoin meme retweeted 1,000 times once a week.”

In some documented cases, several dozen executives from VC-backed Bitcoin companies have spent thousands of hours debating this size attribute instead of building and shipping commercializable products.  But hey, at least they sell cool hats and built up very large Twitter followings, right?

Fact #1: Satoshi Nakomoto did not ask anyone’s permission to launch, change, or modify the codebase she unilaterally released in 2009.

Fact #2: In 2009, when Satoshi Nakomoto issued and minted a new currency (or commodity or whatever these MLIC are) she did so without asking anyone else’s approval or for their “ack.”

In the approximately seven years since she stopped posting under her pseudonym, influential elements of Bitcoin’s anarchic community have intentionally created a permissioned developer system commonly referred to as the Bitcoin Improvement Proposal (BIP) process.  “Bitcoin Core” is the name for the group that self-selected itself to vet BIPs; involvement is empirically permissioned because you can get kicked off the island.1 There are a small handful of decision makers that control access to the code repository.

For example, if you’re a developer that wants to create and launch a new implementation of Bitcoin that includes different block sizes… and you didn’t get it approved through this BIP process, guess what?  You are doing permissionlessness wrong because you didn’t get permission from the BIP approval committee to do so.

Oh, but you realize that and still want to launch this new Bitcoin implementation with the help of other elements of the community, such as some miners and exchanges?

According to some vocal members of the current BIP approval committee (Bitcoin Core) and its surrogates, this is an attack on Bitcoin.  Obviously this is absurd because there is no de jure or legally defined process for changing or forking Bitcoin, either the chain itself or the code.

There is no terms of service or contract which explicitly states what Bitcoin is and who controls its development process.  Or more historically: if Satoshi didn’t need permission from a (non-existent) BIP approval committee to launch a cryptocurrency, then no other Bitcoin developer needs to either.

Tickers

Fast forward to this current moment in time: if the Bitcoin Cash or Segwit2X forks are an attack on network because either fork did not get ack’ed (approved) by the right people on the BIP approval committee or retweeted by the right “thought leaders” on social media, then transitively every 10 minutes (when a block is generated by a miner) arguably could be an attack on Bitcoin.

Why?  At any time a block maker (miner) could use a different software implementation with different consensus rules.  They, like Satoshi before them, do not need permission to modify the code.

Oh, but other miners may not build on top of that block and some exchanges may not recognize those blocks as “legitimate” Bitcoin blocks?

That is certainly a risk.  In fact, several exchanges are now effectively white listing and black listing — permissioning — Bitcoin-related blocks.

For instance, Bittrex, a large crypto-to-crypto exchange, has said:

The “BTC” ticker will remain the Bitcoin Core chain before the hard fork block. Bittrex will observe the Bitcoin network for a period of 24 to 48 hours to determine if a chain split has occurred and the outcome.

In the event of a chain split, “BTC” will remain the existing Bitcoin chain with 1 MB blocks until the industry and ecosystem demonstrates a clear chain preference for Bitcoin.

Bitfinex, the largest (and most nebulous) cryptocurrency exchange in the world, took this even further by stating:

The incumbent implementation (based on the existing Bitcoin consensus protocol) will continue to trade as BTC even if the B2X chain has more hashing power.

After heavy public (and private) lobbying by members and surrogates of Bitcoin Core, other exchanges have instituted similar policies favoring the incumbent.2  So what can alternative implementations to do?  Bend the knee?

Daenerys Targaryen, Breaker of Chains

Historically miners have built on the chain that is both the longest and also has the most accumulated difficulty… and one that has enough profitability to pay for the electricity bills.  It just happens that this collective block building activity is never called an “attack” because in general, most participants have been happy enough with the status quo.

Visions of what Bitcoin is and how it should be defined have clearly, empirically shifted over time.  But since this network was purposefully designed to be self-sovereign and anarchic — lacking contracts and hooks into any legal system — no one group can claim legitimacy over its evolution or its forks.

As a result, recent war cry’s that Segwit2X is a “51% attack” on Bitcoin are a red herring too because there is no consensus on the definition of what Bitcoin is or why the previous block – in which approximately 51% of the hashrate created a block – is not an attack on Bitcoin. 3

This has now morphed into what the “BTC” ticker on exchanges represents.  Is it the longest chain?  The chain with the most accumulated difficulty?  The chain maintained by Bitcoin Core or now defunct NYA developers?  If a group of block makers can build blocks and exchanges are willing to list these coins as “BTC” then that specific chain has just as much legitimacy as any other fork other miners build on top of and exchanges may list.

Furthermore, if the BIP approval committee gets to say what software miners or exchanges should or should not use (e.g., such as increasing or decreasing the block size), that could mean that existing network is a managed and even administered.  And this could have legal implications.  Recall that in the past, because block making and development were originally separate, FinCEN and other regulators issued guidance stating that decentralized cryptocurrencies were exempt from money transmission laws.

Despite what the trade associations and Bitcoin lobbying groups would like the narrative to be, I recently published an article that went into this very topic in depth and have publicly asked several prominent “crypto lawyers” to provide evidence to the contrary (they have yet to do so).  An argument could be made that these dev groups are not just a loose collective of volunteers.

Financial market infrastructure

I’m not defending S2X or XT or Bitcoin Unlimited.  In fact, I have no coins of any sort at this time.

But even if you don’t own any bitcoins or cryptocurrencies at all, the block size debate could impact you if you have invested in the formal financial marketplace.

For example, if and when the CME (and similar exchanges) get CFTC approval to list cryptocurrency-related futures products and/or the NYSE (and similar exchanges) get SEC approval to list cryptocurrency-related ETFs, these products will likely result in a flood of institutional money.

Once institutions, regulators, and sophisticated investors enter the picture, they will want to hold people accountable for actions.  This could include nebulous “general partnerships” that control GitHub repositories.  Recall, in its dressing down of The DAO, the SEC defined the loose collective building and maintaining The DAO as a ‘general partnership.’  Is Bitcoin Core or other identifiable development teams a “general partnership”?

Maybe.  In fact, the common refrain Bitcoin Core and its surrogates continually use amounts to arguments in favor of a purported natural monopoly.

For instance, Joi Ito, Director of MIT’s MediaLab, recently stated that:

“We haven’t won the battle yet. [But] I think the thing that is interesting is that Bitcoin Core has substantially more brain fire power than any of the other networks.”

This is problematic for a couple reasons.

First, Joi Ito is not a disinterested party in this debate.  Through Digital Garage (which he co-founded) it has invested in Blockstream, a company that employs several influential Bitcoin Core devs.4  Ignoring the potential conflict of interest, Ito’s remarks echo a similar sentiment he also made last year, that Core is basically “The Right Stuff” for NASA: they are the only team capable of sending humans into space.

But this is an empirically poor analogy because it ignores technology transfer and aerospace education… and the fact that multiple countries have independently, safely sent humans, animals, and satellites into space.

It also ignores how competitive verticals typically have more than just one dominant enterprise: aerospace, automobiles, semiconductor manufacturers, consumer electronic manufacturers (smart phones), etc.  Each of these has more than one company providing goods and services and even usually more than just one product development team developing those.  Intel, for example, has dozens of design teams working on many new chips at any given time of the year.  And they are just one of the major semiconductor companies.

Even in the highly regulated markets like financial services there is more than one bank.  In fact, most people are unaware of this but banks themselves utilize what is called “Core Banking Software” and there are more than a dozen vendors that build these (see image below).

It is a bit ironic that Bitcoin Core seeks to have a monopoly on the BIP process yet even banks have more than one vendor to choose from for mission critical software securely managing and processing trillions of dollars in assets each day.5

On the enterprise (non-anarchic) blockchain side of the ecosystem, there are well over a dozen funded teams shipping code, some of which is being used in pilots by regulated institutions that are liable if a system breaks.  Note: this is something I discussed in my keynote speech (slides) at the Korea Financial Telecommunications and Clearings Institute last year.

But as one vocal Core supporter in a WeChat room recently said, Bitcoin Core is equivalent to Fedwire or Swift, there is only one of each; so too does it make sense for only one Bitcoin dev team to exist.

Firstly, this conflates at least four different things: a specific codebase, with permissioned dev roles, with acceptance processes, with a formal organization.

It is also not a good analogy because there are many regulatory reasons why these two systems (Swift and Fedwire) exist the way they do, and part of it is because they were either setup by regulators and/or regulated organizations.  In effect, they have a bit of a legally ring-fenced marketplace to solve specific industry problems (though this is somewhat debatable because there are some alternatives now).6

If this supporter is equating Core, the codebase, with real financial market infrastructure (FMI), then they should be prepared to be potentially regulated.  Bitcoin Core and many other centralized development teams are comprised of self-appointed, vocal developers that are easy to identify (they have setup verified Twitter accounts and attend many public events), so subpoenas and RFI’s can be sent their way.

As I mentioned in my previous article: with great power comes great accountability.  Depending on the jurisdiction, Core and other teams could end up with regulatory oversight since they insist on having a monopoly on the main (only) implementation and process by which the implementation is managed.7

Remember that Venn diagram at the very top?  The companies and organizations that manage FMI today for central banks (RTGSs), central securities depositories (CSDs), and other intermediaries such as custodians and CCPs, have specific legal and contractual obligations and liabilities.

Following the most recent financial crisis, the G-20 and other counties and organizations established the Financial Stability Board (FSB) to better coordinate and get a handle on systemic risks (among other issues).  And while the genesis of the principles for financial market infrastructures (PFMI) had existed prior to the creation of the FSB, how many of the international PFMI standards and principles does Bitcoin Core comply with?

Spoiler alert: essentially none, because Satoshi intentionally wasn’t trying to solve problems for banks.  So it is unsurprising that Bitcoin isn’t up to snuff when it comes to meeting the functional and non-functional requirements of a global payments platform for regulated institutions.  Fact-check me by reading through the PFMI 101 guide.

When presented with these strong legal accountability and international standards that are part and parcel with running a payment system, there is lots of hand waving excuses and justifications from Core supporters (and surrogates) as to why they are exempt but if Core wants to enforce its monopoly it can’t have it both ways.  Depending on the jurisdiction they may or may not be scrutinized as FMI.

But in contrast, in looking at the evolution and development of the enterprise chain ecosystem – as I described in multiple previous articles – there are valuable lessons that can be learned from these vendors as to how they plan to operate a compliant network.  I recall one conversation with several managing directors at a large US investment bank over a year ago: maybe the enterprise side should just have CLS run a blockchain system since they have all the right business connections and fulfill the legal and regulatory check boxes.

Note: CLS is a very important FMI operator.  Maybe existing FMI operators will do just that.  Speaking of which, will Bitcoin Core (or other dev teams) apply to participate with organizations like the FSB that monitor systemically important financial institutions and infrastructure?

Angela Walch has argued (slides) that some coders, especially of anarchic chains, are a type of fiduciary.8  Even if this were not true, many countries have anti-monopoly and anti-trust laws, with some exceptions for specific market segments and verticals.  There are also laws against organized efforts involved in racketeering; in the US these are found within the RICO Act.

Watch the Godfather trilogy

I haven’t seen a formal argument as to why Core or other development teams could meet the litmus test for being prosecuted under RICO laws (though the networks they build and administer are frequently used for money laundering and other illicit activity).  But trying to use the “decentralization” trump card when in fact development is centralized and decisions are made by a few key individuals, might not work.

Look no further than the string-pulling Mafia which tried to decentralize its operations only for the top decision makers to ultimately be held liable for the activities of their minions.9  And using sock puppets and pseudonyms might not be full proof once forensic specialists are brought in during the discovery phase.10

Concluding remarks

Based on observations from how Bitcoin Core evolved and consolidated its power over time (e.g. removing participants who have proposed alternative scaling solutions), the focus on what Bitcoin is called and defined has landed in the hands of exchanges and really just highlights the distance that Bitcoin has walked away from a “peer-to-peer electronic cash” that initially pitched removing intermediaries.  To even care about what ticker symbol ‘Bitcoin’ is on an exchange is to acknowledge the need for a centralized entity that establishes what the “price” is and by doing so takes away the bitcoin holder’s “self-sovereignty.”11

While the power struggles between various factions within the Bitcoin development community will likely rage on for years, by permissioning off the development process, Bitcoin Core (and any other identifiable development groups), have likely only begun to face the potential regulatory mine field they have foisted on themselves.12

Historically blockchain-based systems have and still are highly dependent on the input and decision-making by people: somebody has to be in charge or nothing gets done and upgrades are a mess.  And the goal of appointing or choosing specific teams on anarchic chains seems to be based around resolving political divisions without disruptive network splits.13

The big questions now are: once these teams are in charge, what will governments expectations be?  What legal responsibilities and regulatory oversight will the developers have?  Can they be sued for anti-trust and/or RICO violations?  With billions of dollars on the line, will they need to submit upgrade and road map proposals for approval?

Endnotes

  1. Examples of developers who were removed: Alex Waters, Jeff Garzik, Gavin Andresen []
  2. Thanks to Ciaran Murray for identifying these exchanges. []
  3. Bitcoin mining is in fact based on an inhomogeneous Poisson process; a participant could theoretically find a block with relatively little hash rate.  Although due to the probabilities involved, most miners pool their resources together to reduce the variance in payouts. []
  4. According to one alleged leak, Digital Garage is testing Confidential Assets, a product of Blockstream. []
  5. According to a paper from the Federal Reserve: payment, clearing, and settlement systems in the United States “process approximately 600 million transactions per day, valued at over $12.6 trillion.” []
  6. On AngelList, there are about 3,400 companies categorized as “payments” — most of these live on top of existing FMI, only a handful are trying to build new independent infrastructure. []
  7. A key difference between Bitcoin and say Ethereum is that with Ethereum there are multiple different usable implementations managed by independent teams and organizations; not so with how Bitcoin has evolved with just one (Bitcoin Core) used by miners.  In addition, the Ethereum community early on formally laid out a reference specification of the EVM in its yellow paper; Bitcoin lacks a formal reference specification beyond the Core codebase itself. []
  8. See also The Bitcoin Blockchain as Financial Market Infrastructure: A Consideration of Operational Risk from Angela Walch []
  9. Thanks to Stephen Palley for providing this observation. []
  10. It is unclear why the current Bitcoin Core team is put onto a pedestal.  There are many other teams around the world building and shipping blockchain-related system code used by companies and organizations (it is not like there is only just one dev team that can build all databases or operating systems).  At the time of this writing Core has not publish any papers in peer-reviewed journals and many of them do not have public resumes or LinkedIn profiles because they have burned business and professional relationships in the past.  Irrespective of what their bonafides may or may not be, it is arguably a non sequitur that ‘permissionless’  coordination in open-source code development has to lead to a monopoly on said development. []
  11. Thanks to Colin Platt for this “appeal to authority” observation. []
  12. Bitcoin stopped being permissionless when developers, miners, and exchanges needed to obtain permission to make and use different code.  And likely there are and will be more other cryptocurrency development teams that follow that same path. []
  13. For an informed contrarian view on governance and distributed ledger technology, see The blockchain paradox: Why distributed ledger technologies may do little to transform the economy by Vili Lehdonvirta []

A note from Bob on the transparency of Tether

[Note: below is a note from a friend, Bob, who is a former attorney turned tech entrepreneur who closely follows the cryptocurrency world.  This was published with his permission.]

Hope all is well.  I am writing to share some alarming signs of Bitcoin price manipulation.

Bitcoin price is about 10 times of what it was a year ago. The exchange that decisively sets Bitcoin price is Bitfinex, a secretive institution with unknown beneficiary structure and place of organization.

Bitfinex had its wire services suspended by Wells Fargo in April.  To resume trading, Bitfinex enlisted the help of Tether, another company with unknown beneficiary structure and place of organization, but based on announcements is likely under common share holder control with Bitfinex.  Tether sells crypto-tokens known as USD Tethers, or USDTs, that are purportedly backed by an equal number of US dollars.  In other words, each USDT is a digital good priced at USD 1.00.

Despite the promise of “100% reserve” and the vague reference to “24×7 access to your funds” on Tether’s website, there is no contractual right, either tacit or express, for one USDT to be redeemed for one US dollar.  It is probably through this legal construct that Tether hopes to characterize its USDTs as digital goods and not “convertible” virtual currency covered by FinCEN regulations.

The invention of USDTs led to the proliferation of numerous crypto-currency exchanges.  Examples include Bitfinex, Binance, HitBTC, KKex, Poloniex, and YoBit.  Instead of providing crypto-to-fiat trading pairs, these “coin-to-coin” exchanges offer crypto-to-tether trading exclusively.  Therefore, USDTs not only help these exchanges remove the need for formal banking arrangement, but also enables these exchanges to organize in lesser known jurisdictions (e.g., the Republic of Seychelles) and operate outside of the regulation and supervision of major economies.  Most of these exchanges claim to screen-off visitors from the United States and other countries with laws on coin-to-coin trading, but the screen-off is often perfunctory. In almost all cases, the screen can be defeated with a simple mouse click.1

It is doubtful that these exchanges perform meaningful due diligence beyond identity verification to combat money laundering, financing of terrorism, and corruption of politically exposed persons. Bitfinex, for example, requires no identity verification at all for most trading activities and imposes no trading amount limits on unverified accounts.  The enablement of these exchanges where rampant money laundering is possible is outside of the scope of this note. Instead, I would like to bring to your attention the distinct possibility that Bitfinex, as the likely controller of Tether, is a bad actor.

Strong circumstantial evidence suggests that Bitfinex is creating USDTs out of thin air to prop up Bitcoin prices.  Namely, Bitfinex is likely acting as a central bank that issues a fiat money called USDTs. The sole mandate of this central bank is to enrich itself through market manipulation.

The first image (above) attached to this email illustrates how mysterious amounts of USDTs were minted and injected into Bitfinex at precise moments when a crash seemed imminent.

The second image (above) illustrates a strong correlation (but admittedly not causation) between the total amount of USDTs in circulation and Bitcoin price.

Bitfinex released an internal memo in September to allay concerns that USDTs might have been created at will.  The memo purportedly shows that Tether maintained sufficient US dollars to match all USDTs in circulation as of a day in September.  The memo, however, is of no probative value.  Among other strange things, the author of the memo didn’t verify with banks (names redacted) that account balances from Tethers were in fact correct, couldn’t promise that the balances weren’t overnight borrowings for purposes of producing the memo, and couldn’t promise that Tether indeed had access to those funds.

I therefore urge you to consider the possibility that the current price of Bitcoin is the result of Bitfinex’s manipulation and may collapse when regulators take action.

For example, Tether is almost certainly an administrator of virtual currency — it centrally puts into and withdraws from circulation USDTs, a virtual currency squarely intended as a substitute for real currency as admitted by Tether in the internal memo.

Tether has nominally registered as a money transmitter with FinCEN, but it is unclear if they fulfill any of the BSA filing requirements (e.g., filing SARs).2 As a company, Tether’s USDTs enables large crypto-currency exchanges (including US-based exchanges like Poloniex) to exist and powers trades thereon in the amount of millions every day.  So it wouldn’t be surprising if FinCEN eventually decides to enforce its rules against Tether as it did against Liberty Reserve.

Further, CFTC approved recently various swap execution facilities, designated contract markets and derivative clearing organizations with Bitcoin flavor.  And the Chicago Mercantile Exchange is expected to launch cash-settled futures on Bitcoin soon.  Manipulation of Bitcoin prices referenced by these entities is prosecutable by the CFTC, an agency with broad statutory authority to prosecute manipulation of commodity prices under the Commodity Exchange Act (including Section 753 as amended by the Dodd-Frank Act.).

Although none of these CFTC-registered entities are currently including Bitfinex in the calculation of their Bitcoin reference rates (CME used to), it is well understood and could be easily established (partially because of the transparency of Bitcoin blockchain) that Bitfinex-initiated price movements ripple through all exchanges via manual and automated trading.3  CFTC could then have grounds to investigate Bitfinex’s possible manipulation of Bitcoin price via Tether.

If you are considering investing into Bitcoin at this time, please look closer at the exchanges involved in price discovery and give it a second thought.

References

  1. For an example, see FinCEN ruling from August 15, 2015. []
  2. Tether Limited did do a basic registration which takes around 5 minutes and about 45 dollars. But they probably didn’t do what come after the registration, which includes many other filings to FinCEN such as submitting suspicious activity reports. []
  3. The initial reference rate announced by the CME included Bitfinex.  Similarly, the Winklevoss Bitcoin ETF used a reference rate (called the “Winkdex”) whose comprising exchanges fluctuated over time.  See Comments on the COIN ETF (SR-BatsBZX-2016-30). []

Who are the administrators of blockchains?

[Note: I neither own nor have any trading position on any cryptocurrency.  I was not compensated by any party to write this.  The views expressed below are solely my own and do not necessarily represent the views of any organization I advise.  See Post Oak Labs for more information.]

On All Hallows’ Eve in 2008, an anonymous person (or group of persons) posted a short technical whitepaper on an obscure mailing list about a new virtual coin-based online-only payment system they had been designing for the last eighteen months.1 Several months later, in January 2009, this same person posted the code that created the functionality described in the whitepaper and began minting this new virtual currency.  Less than two years later, the creator walked away from the project and without ever revealing their real identity.

The creator likely stayed anonymous for a variety of reasons, including the fact that by creating and administering a new payment system they may have been violating money transmission laws in multiple countries.2 Despite multiple hoaxes, we still don’t know who this anonymous person was.  But their system – like the Ship of Theseus – continues to exist in a form referred to as Bitcoin.

But before getting to that part of the saga, let’s look at May 2013.  At the end of that month, US federal agents raided a Costa Rica-based company called Liberty Reserve due to money laundering violations (along with a list of other crimes).  Liberty Reserve was a centralized payment platform that marketed to its users the ability to anonymously send funds to one another.

According to the BBC:

The US Justice Department said the scheme had been used to process 78 million transactions with a combined value of $8bn (£5.5bn) – many of which were related to hiding the proceeds of credit card theft, identity fraud, hack attacks and Ponzi scam investment schemes.

Last year the founder of Liberty Reserve, Arthur Budovsky, was convicted and sentenced to twenty years in prison.  Several other insiders also received sentences.  Liberty Reserve had more than 5 million users including more than 200,000 in the US — it is unclear at this time if any of the users are being prosecuted.

According to some cryptocurrency fans, Liberty Reserve’s big blunder was that they attached their legal names to the payment processing enterprise.

But this misses the point.  If you play with a highly regulated industry such as financial services, be prepared for the existing stakeholders such as regulators and law enforcement to increasingly scrutinize your operations as they detect familiar activities, such as the marketing and sale of securities or operating a payment platform.

Cypherpunk cosplay uniform (mostly worn online)

If you spend your weekends cosplaying online as a cypherpunk and yet voluntarily sit on-stage wearing a name tag with your real name at public events and promote financial products and financial market infrastructure to the world at large, consider that there may be people who later watch these videos stored on Youtube. In its report on The DAO, the SEC cited two specific Youtube videos including one from Slock.it, the creators of The DAO.  Recall that Slack stores everything, including your private pump and dump strategies.  If you used cloud-based email, there is a non-zero chance that your successful solicitations and payola to coin media could be discovered after the cloud provider receives a subpoena.

What does this have to do with blockchains?  Below we discuss a few ideas that tie in with money transmission and payment processing.

“Core” development teams

Let me state from the onset that I am unaware of any current or potential criminal or civil cases specifically against developers of cryptocurrency networks.  Furthermore, regulators and law enforcement may not view development teams as administrators at all.  I am not a lawyer and this is not legal advice.

What are administrators?  At a very high level, in the United States, according to guidance published in March, 2013 by FinCEN:

An administrator is a person engaged as a business in issuing (putting into circulation) a virtual currency, and who has the authority to redeem (to withdraw from circulation) such virtual currency.

The rest of the March guidance goes into a little more detail of what administrators are with respect to money exchange itself.

For the purposes of this article, and without diving too much into the technical weeds, let’s consider this hypothetical:

Bob forks/clones Bitcoin in a new GitHub repo that he alone has commit access to.  While other people can submit suggested changes, he alone has commit access to make any changes to the code.  He likes his privacy so he doesn’t actively advertise or market the repo or coin or tell anyone who he is.  And then sets up one mining node, initiates the genesis block, and begins Day 1 of Bobcoin.

Is Bob an administrator?  If so, at what point does he stop being an administrator?  When there are more than one mining nodes in operation?  When more than one developer has commit access?

That’s a decision that regulators and law enforcement will need to make but from this cursory bit of detail, Bob clearly issued his own virtual currency.  Can he redeem it?

Perhaps.3  Either way, he could unilaterally change the code and annul previous or future coins/transactions.  He could change the money supply schedule, doubling or halving it if he so pleased.   He could make a new rule that says block sizes should be arbitrarily larger or smaller.  He could make a new version that separates the digital signatures from other data in the block.  He could change the required transaction fee.  He could add functionality such as P2SH.  He could change how the difficulty setting adjusts.  And so forth.

Even if other participants added computers and joined the Bobcoin network and diluted Bob’s mining hashrate, if the new participants solely rely on the code in his GitHub repo (e.g., are unaware of and/or do not use alternative implementations of Bobcoin code), then Bob remains very influential and could still directly make changes to the network.

Does being very influential — controlling the code repo to a financial network — constitute “administration”?  Arguably yes, but there should be some objective measuring sticks as to what these attributes are (e.g., how many different people have commit access to a repo for financial market infrastructure).

In the proof-of-work-based cryptocurrency world today, we have observed a stark 180 logistical change from Bitcoin in 2009.  Whereas originally all nodes were miners and vice versa, today you have a permanent bifurcation between: fully validating nodes and the mining process itself (hash generation process).  Similarly, many participants in the market, including dozens of developers and miners, use their real legal identities through the use of verified social media accounts and the speaking circuit at fintech events.  They are no longer pseudonymous.

In order for participants to coordinate and administer these types of networks, they did not necessarily need to reveal themselves.  In fact, we still don’t know who many of the original creators of various cryptocurrency networks are that are still in operation (who is BCNext?).  But because many have publicly identified themselves, they could be served with legal process and held responsible if legally liable: hiding behind pseudonymity or anonymity is no longer an option for them.

To borrow a phrase that has been recently used by several regulators, will it come down to the “facts and circumstances” to determine whether or not an entity such as a mining pool operator or core development team is a money service business or fiduciary? 4

Either way, popular euphemisms commonly used by cryptocurrency promoters and lobbyists include supposedly supporting “open” or “public” blockchains – several feelgood words – but as we empirically observe, in many cases these networks are not open to the general public: either as an actual validator or as a developer.  Access can become gated by a clique who determines who can be involved.5

In December 2015, the individuals in the photo above allegedly represented about 90% of the Bitcoin network hashrate: Source

Command and control

According to some, the Bitcoin network is viewed as a “third party payment processor” and because no one single entity administers the network it meets FinCEN’s exemptions.6  Thus, the argument goes, cryptocurrency network creators do not need to obtain a money transmitter license in the US because each activity is separate and run by a different group of participants who meet some kind of legal or regulatory exemption.7

This may have been the case in 2009 and 2010 prior to mining pools and dedicated development teams but it may not stand up to closer scrutiny in 2017.

For instance, over the past couple of years there has been this phenomenon called the “block size” debate.  Rather than go into the different camps and what they want or demand, let’s look at how various participants actually behave and act.

To begin with, let’s look at mining.

As mentioned above, mining in 2017 is different than it was in 2009.  Whereas mining initially meant (1) validation back to the genesis block and (2) generating proofs-of-work (hashes), these two processes are fully separated today.8

Today mining pool operators pick and choose which transactions to include into blocks and validate the chain they are building their blocks, is the chain they intended to do so on.  They can (and do) censor transactions.  For a pre-arranged fee, some will include your transaction before including others, including transactions from the mining pool operator itself.  Mining pools in turn pay miners (those with hash generating equipment) a share of the block reward for the work they do.  Note: miners (hash generators) themselves do not validate blocks and in fact, the machines they use are comprised of ASIC chips, are incapable of doing anything other than some simple multiplication — they can’t even run the software needed to validate the chain, let alone software like Excel.

There is a third stake holder in the mining process; infrastructure managers, who own and operate (or lease) the physical infrastructure that houses the equipment for miners.  Very little has been published on these participants (in English) because most of this infrastructure is managed in countries where English is not the mother tongue.9 These participants negotiate electrical rates and sometimes help install and operate the electrical equipment (transformers and wiring) at the various mining facilities (or outsource and manage that to someone else).

Now let’s look at the software implementation commonly used by many Bitcoin mining pools, called Bitcoin Core.  Until very recently, most mining pools ran a reference implementation of what is called the Bitcoin Core implementation of Bitcoin.  That is to say, the software running their node which builds and validates blocks, comes from a repository managed by a collective describing itself as Bitcoin Core.  This software was originally called the “Satoshi client” (Bitcoin-Qt) and has been renamed a few times along the way to its current name of Bitcoin Core.

In October, 2017 one common refrain from the camp that collectively identifies itself as Bitcoin Core, is that miners do not ultimately operate Bitcoin.  They argue that hashrate follows price and price follows the chain that is best maintained by the best developer team.  This is empty rhetoric.  We know that there are three entities involved in mining: mining pools, hash generators, infrastructure managers.  We know their key importance because they have been lobbied non-stop by many different stakeholders (such as Bitcoin Core and Bitcoin Classic) over the past several years including both open and closed door events on multiple continents.  They have been asked to sign agreements.  And then have seen those same agreements broken.  If miners are not important, they would not be lobbied or demonized at all: they would be ignored entirely.1011

Bitcoin Core is especially interesting because Bitcoin Core proponents claim it does and does not exist.  It is a bit like Schrodinger’s cat: Core exists when it is convenient for its proponents (like rallying supporters to denounce an alternative implementation) but does not exist when it encounters accountability or responsibility for its collective decisions or the decisions made by its surrogates.

Bitcoin Core maintains a website, a verified Twitter profile, Slack and other media channels.12 It even has a public team page of some of the contributors.  It is unclear how they precisely coordinate, but they work closely together with the owners and maintainers of Bitcoin.org and Bitcoin Core GitHub repo.  Note: Bitcoin.org, Bitcoin Talk and /r/Bitcoin are all controlled by the same individual, “theymos.”13 The other channels are owned and controlled by a set of unknown participants.  This collective does not have any known trademarks or copyrights at this time.  While no one has yet identified the actual decision makers, Bitcoin Core has multiple surrogates who are publicly known and actively engaged in media.

When there are disputes over decisions, some individuals who have identified themselves on the Bitcoin Core contributor list, will come out defending Bitcoin Core.  This includes asking for Bitcoin Core alleged lookalikes and doppelgangers to stop existing.  Schrodinger’s cat strikes again: Bitcoin Core wants to own the term Bitcoin Core on social media so that others can’t use it, but do not want the accountability when the collective or someone from the collective makes a decision.  Whose identification documents were used to create a verified Twitter (KYC’ed) account?  What about the web domains?  Those people are arguably actual representatives of the collective.

Bitcoin Core does not have a trademark on the Bitcoin logo, the Bitcoin ticker symbol, etc.  The original code base was released under an MIT License and “Satoshi Nakomoto” is still the copyright owner.14 Tibanne KK (the parent company of Mt. Gox) actually has a trademark on “Bitcoin” in the UK; although since the logo was originally placed in the public domain it is unclear if Tibanne can enforce these claims.  While the representatives and surrogates of Bitcoin Core argue over alternative implementations, if the entity called Bitcoin Core sued, this could open them up for a few things:

  1. they might need to incorporate in order to have legal standing;15
  2. they’d likely have to reveal their legal names (who is the verified Twitter entity?);
  3. they could be liable for complying with state, federal and international laws around operating financial market infrastructure.

Some developers want the power to control a code repo but not the accountability that comes with it.   Source: Spider-Man

Note: if you have a few moments, Angela Walch has a great paper on this topic worth reading.  Recall one of the common refrains from multiple full-time cryptocurrency developers is that they must be conservative in how they upgrade the chain they are working on, “as billions of dollars are at risk.”  These statements are arguably self-incrimination for being a fiduciary.16

It is unclear if Bitcoin Core itself will remain pseudonymous to avoid lawsuits and countersuits.  But recall, no one currently owns “Bitcoin” — the network itself is a public good, a commons.  However, Bitcoin Core does control the GitHub repo and tightly controls the commit access, occasionally removing those that do not align with their political views.17

What is the big deal?  Isn’t this software similar to a browser?

No.  The several thousand ISPs that are connected to each other forming “the Internet” are not dependent on the existence of Firefox or Internet Explorer or any browser.  These ISPs use protocols which are developed and managed by various non-profit and for-profit entities, some with clearer governance than others (like ICANN and IETF).  Network traffic will continue to flow irrespective of what browser is being used.

Bitcoin Core (the software) is not like a browser.18  If it was, the miners could simply switch out and use a different implementation and then start building blocks based on this new implementation.  But as noted above, miners have been lobbied not to use anything but Bitcoin Core or face the consequences if they did.  For instance, this past spring a group of Bitcoin Core affiliated developers threatened to change the proof-of-work mechanism.  These same developers even created a Twitter account (hence deleted) and still maintain a website dedicated to promoting this change.

With threats like this, arguably miners aren’t really free to choose what implementation to run.  To use Walch’s description, Bitcoin Core (and other identifiable developer teams) could arguably be a fiduciary if not an administrator.

bitfury

Source: Twitter

George Kikvadze is an executive and vice chairman of BitFury, a large Bitcoin mining company based in the Republic of Georgia.  Seven months ago he tweeted the statements above in reaction to a Bitcoin Core developer that threatened to change the proof-of-work algorithm used in Bitcoin in order to punish miners for using non-Bitcoin Core code.

Neither threat was carried out but this scenario raises interesting questions: if representatives of Bitcoin Core (or other development teams) who had commit access did change the proof-of-work mechanism to something the ASIC miners that BitFury designed was no longer capable of monetizing, is Bitcoin Core (or other developer teams) itself liable for the loss in revenue suffered by BitFury and other miners?  Is it just the person who submitted the documents to get a verified Twitter account?

No terms of service

One of the fundamental challenges for any anarchic chain is coming to agreement on defining the chain in the first place.19 What is Bitcoin?  Is it the chain with the most proof-of-work?  The longest chain?  The one that gets the most retweets?  The one with the most starred repo on GitHub?

As I mentioned in a paper a couple years ago (Appendix A), because there is no de jure process to handle governance issues, the various communities and tribes rallying and fighting around their disparate visions must rely on ad hoc de facto processes, much of which spills over onto social media

Fundamentally there does not appear to be any contract rights involved in using or operating Bitcoin (the network).  Who do users have contractual relationships with?  If someone does, then you could theoretically sue them.  But there is not even a click-through agreement or EULA when downloading Bitcoin Core (or any other alternative implementation).

This is relevant because earlier this month there were several Bitcoin Core contributors and surrogates, some of whom used their real names, claimed that alternative implementations such as Bitcoin Segwit2X (and its developers) could be violating the Computer Fraud and Abuse Act in the event that Segwit2X successfully creates a new fork next month.

If the CFA Act or money transmission laws are being broken post-Segwit2X then they are probably being broken now because of how various forks and updates are currently rolled out by developers and miners.  While it is unclear if any regulators or law enforcement would see the interpretation of the CFA Act the same way as Bitcoin Core representatives do, this hypothetical legal threat raises a few interesting points:

  1. What legal standing does anyone have in the event of a fork on an anarchic chain?  Code is not law.
  2. What country has jurisdiction and who has contractual relationships with one another?
  3. Would such a lawsuit create precedence or chilling effect on anyone wanting to fork/clone code in the future?  Who is liable for orphaned blocks?
  4. What happens in the event of an accidental fork like the one in March 2013?

By pushing any interpretation of the CFA Act onto anarchic cryptocurrency networks, it could create interesting legal precedents for Bitcoin Core because once the government gets involved in deliberating which fork is and is not legitimate or which miners can or cannot participate, then you no longer have a pseudonymous anarchic network.  Recall there was no EULA or Terms of Service on purpose when Bitcoin was launched years ago.

Another recent example, a Bitcoin Core surrogate who used his real name, publicly asked the New York State Department of Financial Services (DFS) to look into Coinbase’s support of Segwit2x.  Does Coinbase violate the BitLicense for supporting one chain versus another?  Last month a Bitcoin Core contributor who also used his real name, penned a letter to the SEC about why it should not approve an ETF because the company applying for it supported Segwit2X, an alternative Bitcoin implementation.20

A couple weeks later the same author of the SEC letter publicly said:

But, yea, lets be clear, I dont know a singla significant contributor to Core who will ever work on btc1/Segwit2XCoin. If all the miners switch over, most likely some folks will buy hashrate and there will be a Bitcoin chain again to work on. If, somehow inexplicably, the entire community gives up on Bitcoin and uses 2xCoin, then most likely the vast majority of Core contributors will just move on to something other than Bitcoin, though given how 2x has been going, I find that highly, highly unlikey.

The term “2XCoin” is intended to be an inside baseball pejorative towards the developers and supporters of Segwit2X.  Other Core developers have publicly stated that other Core developers will walk away from (quit) the project if an alternative implementation successfully creates a fork.

Another common war cry during the summer was that Bitcoin Cash, a fork and airdrop of Bitcoin up to a certain block height, “was an attack on Bitcoin.”  This statement raises a number of questions:

(1) there are multiple existing forks of Bitcoin that continue to exist (such as Bitcoin Dark), were these also attacks on Bitcoin?  Where is the passionate uproar against the dozens of Bitcoin clones and forks including the ones that used line-for-line the same code but simply rebranded?

(2) Bitcoin needs to first be defined, since there is no 100% consensus or agreement on what it is (longest chain?) or even agreement on how to measure consensus, to prove that there is an attack you would need to at least agree on what Bitcoin is and what exactly was attacked.  Since Bitcoin was designed from the outset to be forked and for those with the most hashrate to decide what is and is included in a block — and the rules therein — how is Bitcoin Cash any different in terms of legitimacy than Bitcoin?

If there is a regulatory arbitrator stating which fork is the legitimate legal one, you have a permissioned network.  And I truly could talk all day about those because I popularized that term with this (now dated) paper more than two years ago and currently advise a couple companies involved in building those.  Inquire within!

The tactics used by different cryptocurrency tribes versus others is not new.  In fact, if you look as recent as the 1960s, during the Cultural Revolution in China there were struggle sessions in which the accused (class enemies) were captured and dragged out in front of the public and denounced for crimes that they didn’t commit.21

We see this type of behavior in the cryptocurrency world on a monthly basis, just look at the “Antbleed” hatchet job.  This was a manufactured controversy and coordinated attempt to discredit a company (Bitmain) that had publicly spoken out against one specific Bitcoin implementation in favor of another.2223 Nearly six months later, the original accusations (of covert usage) are still unproven yet some of the promoters of this theory, several of which who are affiliated with Bitcoin Core, continue to attack anyone who stands in the way of their own vision.  Many elements in the community thrive on both real and fake controversy in order to stay relevant: it is in a state of permanent lynching mode.

Other cryptocurrency chains

Lest I be accused of picking favorites, I should point out that future researchers could create an infographic depicting how all chains evolved over time.24

Below is a non-exhaustive list of other chains that have highly coordinated behavior between influential persons that look administrator-like:

  • Dash Core: run by a company (with a CEO no less); can identify the major participants involved and how they coordinate to make changes; they sponsor events and attempt to speak on behalf of the community while making any upgrades; they run various social media accounts
  • Ethereum Classic: this small community has held public events to discuss how they plan to change the money supply; they video taped this coordination and their real legal names are used; only one large company (DCG) is active in its leadership; they sponsor events; they run various social media accounts
  • Bitcoin Cash: an airdrop based on Bitcoin prior to a certain block height; can identify the major participants involved and how they coordinate to make changes; they run various social media accounts and events
  • Bitcoin Segwit2X: can identify the major participants involved and how they coordinate to make changes; they have met to formalize this process in multiple meetings including the New York Agreement (NYA); they run various social media accounts and claim to be the equivalent of Bitcoin Core
  • Bitcoin XT: defunct, in its terms they explicitly said one set of named individuals would be administrators
  • Litecoin: leaders are self-doxxed; have a formal Foundation as well; they run various social media accounts and events
  • Dogecoin: leaders are self-doxxed and publicly coordinated merged mining with Litecoin three years ago; there have a formal Foundation; they run various social media accounts
  • Ethereum: can identify and name specific people in the Ethereum Foundation and mining community who publicly coordinated several hard forks; these stakeholders sponsor public events and code changes; they run various social media accounts; the Ethereum Foundation has a registered trademark
  • Bitcoin Gold: an upcoming airdrop based on Bitcoin prior to a certain block height; can identify the major participants involved and how they coordinate to make changes; they run various social media accounts
  • Zcash: this was created by a company (Zerocoin Electric Coin Company); can identify and name specific people in the Zcash Foundation and mining community who publicly coordinate updates; these stakeholders sponsor public events, grants, and code changes; they run various social media accounts
  • Bitcoin: before Bitcoin Core consolidating itself, there was The Bitcoin Foundation which attempted to speak as the voice of Bitcoin… then it pretty much went morally and financially bankrupt
  • Dozens if not hundreds of others

Whereas the Bitcoin creator “walked away” (or is he lurking in the CoinDesk comment section?) most ICO issuers could have the same legal problems described above.  Even ignoring the issuance of unregistered securities through ERC20 and ERC20-like standards, many of these these ICO coins and tokens were centrally issued and administered.

One reviewer singled out Factom, Tierion, Ripple, and Stellar as well, but these communities have slightly different nuances worth looking into independent of this article.  It bears mentioning that Ripple was penalized and settled with FinCEN in May 2015, but this was due to non-compliance with BSA requirements with respect to not filing suspicious activity reports (SAR) from a side fund it operated. 25 It was not about operating the nodes on the network.26 Furthermore, centralized issuance and operation of a network through watermarked tokens (e.g., Counterparty, Omni (Mastercoin), all colored coins) is still taking place today (see Tether).

This is not to say that you shouldn’t create a cryptocurrency nor a foundation.  There are likely ways to create a new cryptocurrency and structure its governance in a legally compliant (or exempt) manner.

But some of those who issued a cryptocurrency which they centrally operate and mint could be on thin ice depending on how strict regulators and law enforcement are.27 Maybe they aren’t strict at all.

If it is centrally administered for 2 minutes versus 2 hours versus 2 years (like Satoshi did), at what point is that line crossed?  What about a network like Stellar that was originally decentralized and then in an emergency, centralized (running off of one node) due to a break in its consensus mechanism?  The Stellar organization itself operated the single validation node for months before re-decentralizing.  That is clearly administering a network especially since they issued lumens to begin with (lumens are the native currency of the Stellar network).

Forks as securities

A friend of mine that is the CEO of a Bitcoin-focused company recently hired an attorney to look at the upcoming Bitcoin Segwit2X (S2X) fork proposal and thinks there could be an argument that the fork is a security based on the Howey test.

His rationale is the following, reused with his permission:28

  • S2X is a common enterprise based on the efforts of the signers of the NYA
  • Many of the signers of the NYA have long touted the benefits and profit expectations of increasing the block size
  • S2X was assembled by a promoter/ third party: the organizers of the NYA and its signers
  • Anyone who purchased bitcoin between May 2017 and the fork date is an investor, in particular if that person bought bitcoin in anticipation / expectation of the fork

If this is true, then you could likely insert and replace S2X and NYA with various cryptocurrency developer groups (including Litecoin, Ethereum, Ethereum Classic, Bitcoin Core, Bitcoin XT and others listed in the section above) and just modify the date to argue that each of these coordinated efforts is effectively a common enterprise seeking to profit from the expectations of X, Y, or Z features.  It could be smaller or bigger blocks, sidechains, slower or faster block generation times, etc.  In other words, if Segwit2X is a security, then arguably many coordinated “soft” and “hard” forks are.29

At this time, in the US, neither the SEC nor CFTC have publicly issued their position on how a fork falls within their scope and mandate.30

However, if any regulator or court does formally publish guidance or a ruling siding with a specific fork, the cryptocurrency community will have institutionalized permissioned-on-permissionless chains.  An expensive contradiction.

Relevancy towards enterprise chains

Since you do not need proof-of-work to maintain all blockchains, enterprise focused blockchain and DLT-related companies (commonly referred to as private or permissioned chains) typically started off with the realization a couple years ago that:

  1.  In order for changes and upgrades to take place on a decentralized network, some clear governance needs to be created to manage that process;
  2.  Network validators, the nodes involved in validating transactions, would be run via known, identifiable (KYC’ed) operators who had specific contractual obligations that ultimately would rely on courts as arbiters (e.g., if there is a fork, only one chain would be deemed the legitimate de jure chain);
  3.  If an entity formally governs one of these networks it is likely that it would also be regulated under existing laws and regulations;
  4.  If an entity or group of entities has the power to coordinate and unilaterally make these changes at will without legal recourse, then this could be a single point of failure that could be abused.  How to design a network that prevents this security hole from forming yet comply with existing laws and regulations all while providing recourse to the users in the event of disputes arising?

Note: all of the vendor platforms have their own differences and nuances; from an architectural standpoint they cannot all be lumped together as a monolithic entity.

But in this case, many of these companies took roughly the same tact: one which attempts to hold validating parties accountable ultimately through the existing legal system (via contracts and if need be courts).  As a result, so far the vendors have generally gotten to bypass most of the drama around factional in-fighting described above.  But each vendor still has their own challenges ahead.  Once an enterprise chain’s mainnet is turned on in production and real value is being moved across their network, whoever administers and operates the network(s) could be legally liable for complying with a whole slew of regulations from multiple different jurisdictions.

That is why some operating models involve banks or other existing financial institution running the validating nodes — because they already have the necessary licenses and compliance structures put in place. That is also why some of the vendors created a consortium from the get-go because they foresaw the need to bring on different types of stakeholders early on.  But ignoring the consortium approach for the moment, once real legal names are touching and managing real financial instruments, regulators and law enforcement begin to pay much closer attention.

Final remarks

In the US there is no private right of action under the FinCEN guidelines.  Only FinCEN can initiate an enforcement proceeding, and based on conversations with legal experts who reviewed this article, these experts do not expect such actions right now given that FinCEN hasn’t thus far.

Can private parties initiate litigation?  Based on one conversation with an interested party, it seems that there is arguably a private right of action under the CEA, under certain state money transmission business (MTB) laws and under securities laws.  Will they?  My guess is that as more real value (e.g., real money like USD) is associated with any of these anarchic blockchains, the odds of lawsuits due to any type of fork (intentional or not), trends closer to probably.

With that said, networks such as blockchains, do not maintain themselves.  They do not upgrade themselves or automatically fix bugs that arise.  They are not anti-fragile.  They need people to do all of these pesky maintenance things.  And with people comes politics and social engineering.31

Empirically if there isn’t disharmony in a blockchain community it is because most participants agrees who the administrator or administrators are.32

If there is a disagreement, as we have seen multiple times, a political struggle often takes place and a fork or two may happen: either a fork in the chain or a fork in the community.  With hundreds of dead or zombie blockchains, it is clear that blockchains do not work without some kind of administrator and decision maker.  Whether or not FinCEN or other money transmitter regulators come to the same conclusion is a different matter.

The takeaway from this piece isn’t that no one should be formally or informally engaged with anarchic chains such as cryptocurrencies.  Or that passion and enthusiasm should be discouraged.  Rather, it is about consistency and the rule of law.  If you do not like the development or evolution in a community-without-formal-rules — such as the fractured tribes of Bitcoin — using the government as a club of convenience to get what you want and not expect consequences for their intervention on your behalf is shortsighted.

While a few dozen cryptocurrency startups have already begun using trade associations to lobby regulators on their behalf for a “hands-off” regulatory approach, at some stage the appearance of formalized governance of financial market infrastructure — even if it is marketed as self-sovereign, decentralized, open, and anarchic — could lead to increased regulatory oversight due to how the crypocurrency governance activity actually behaves in reality.  This is definitely a topic worth revisiting in a year to see if any regulator publicly opines on the topic. 33

[Note: if you found this research note helpful, be sure to visit Post Oak Labs for more in the future.]

Acknowledgements

To protect the privacy of those who provided feedback, I have only included initials: RD, CP, SP, CM, VB, DG, CK, AW.

Endnotes

  1. Both Ray Dillinger and Hal Finney have stated they analyzed and gave feedback to Satoshi on Bitcoin prior to its public announcement; perhaps there were others too. []
  2. See these two articles written by Daniel Friedberg: “FinCEN Guidance Validates Bitcoin Industry but Targets Satoshi” and “Bitcoin hard fork conspiracy treacherous” []
  3. It is possible to create a redeemable asset on Counterparty and several other platforms connected to Bitcoin. []
  4. One reviewer opined that: “I think it will be a technical legal definition that comes down to whether you can exert reasonable control before enforcing MSB rules.  Whether you are an administrator or not will be a boring court decision: they could look at whether you were mining or developing with a high enough impact. []
  5. On the mining side, the capital costs of running a mining farm and pool that actually validates blocks on many of the larger cryptocurrency networks is relatively expensive and out of reach for most users; mining pools have been documented at attacking one another on the network itself (e.g., DDOS attacks).  On the developer side, as discussed throughout this article, while it varies depending on the cryptocurrency, the control over the repo (specifically who has commit access) is often restricted to a few insiders who can permit and restrict who can be involved in the development process (e.g., they can remove a developer from mailing lists, forums, events, code repositories, etc.). []
  6. Cryptocurrency miners typically only have the ability to instruct payments of keys they control (although they can censor and/or fork as well).  Thus, it is argued, the miners typically just perform IT services. []
  7. In the UK, there is some relevant guidance from HM Revenue and Customs with respect to money laundering and money service businesses []
  8. See SPV wallets for a user-specific example. []
  9. This past summer Quartz published a series of articles detailing some of this physical infrastructure in China.  See: The lives of bitcoin miners digging for digital gold in Inner MongoliaPhotos: Inside one of the world’s largest bitcoin mines; and Take a 360 walk around one of the world’s biggest bitcoin mines []
  10. A year ago the narrative that miners were a key component of Bitcoin dramatically shifted in the minds of a group that lobbied for a change known as UASF: User Activated Soft Fork.  The proposal – which thus far has not been activated – attempts to remove miners and replace their role with nodes controlled by UASF advocates, pretty much removing Sybil protection.  Instead of buying hardware and pushing hashrate one way or the other, UASF advocates used social media to promote their views.  Incidentally some of the same people promoting “no2x” (opposed to Segwit2x) were actively part of the “UASF” campaign. []
  11. One reviewer mentioned that: “It’s worth noting that in Ethereum, miners actually don’t have a large role in decision-making. Ironically enough, I think the reason for this is that Bitcoin prefers soft forks for governance, whereas Ethereum prefers hard forks, and soft forks naturally depend more heavily on miner support in order to succeed.” []
  12. Its Twitter account actively retweets and highlights specific content from a common group of promoters, advocating and endorsing their viewpoints. []
  13. “theymos” is his/her username; his real name is allegedly Michael Marquardt but little is publicly known about who he is beyond his control of the most highly trafficked Bitcoin-specific developer sites.  Other pseudonyms that co-own some of these domains include “cobra.” []
  14. In the US, copyrights are unregistered.  The copyright owner of the original source code still belongs to “Satoshi Nakomoto” however as of this writing, no one has stepped forward to claim this copyright ownership. []
  15. Alternatively they could be a “general partnership;” this was discussed in the SEC paper on The DAO (pgs 14-15). []
  16. One reviewer provided a counterpoint: “There’s a difference between voluntarily taking on responsibility and being legally assigned it. For example, if I suddenly decide that I feel morally obligated to make sure all children in some village in Africa are properly fed, I do not become their legal guardian.” []
  17. Alex Waters, Jeff Garzik, and Gavin Andresen (among others) have been removed in this fashion. []
  18. If we replaced “browser” with “TCP/IP” that would likely create massive economic disruption and finger pointing for blame. []
  19. See also: Emochain and Statistchain []
  20. I touched on this same issue last year in a paper, see Comments on the COIN ETF (SR-BatsBZX-2016-30) []
  21. One reviewer pointed out that: “If you’re looking for parallels with authoritarian regimes, there are many. Bitcoin Core’s arguments that there must be only one reference implementation to “preserve stability”; them playing linguistic games to deny the opposition legitimacy, high levels of censorship, etc. There are also parallels on the other side of this, where the “opposition parties,” despite having many legitimate grievances, are all good at protesting but focus on negativity and are not nearly technically competent enough to effectively form their own “government”. This happens in Russia, to some extent Singapore, China (think Hong Kong independence movement), etc. You can probably expand this out into an entire blog post.” []
  22. Bitmain is the largest manufacture of mining equipment, Antminer is the brand of one of its product lines. []
  23. See also Just How Profitable is Bitmain? by Jimmy Song and Former Bitmain Chip Designer Seeks to Revoke Mining Giant’s Patent from CoinDesk []
  24. One reviewer suggested that future researchers and analysts could also look at several other attributes: (1) Basing oneself in a country as an incorporated entity; (2) Having developers heavily concentrated in a country; (3) Heavily marketing in a country, especially if it’s the same country as above; (4) The operation of a chain being controlled by one implementation and one company (as opposed to Ethereum’s geth/Parity/now harmony split []
  25. One reviewer opined that: “Though it is worth noting that their ability to operate the network in a way that gives users permissionlessness was compromised as a result of these side activities. A useful cautionary tale.” []
  26. XRP Ledger Decentralizes Further With Expansion to 55 Validator Nodes from Ripple Insights []
  27. One reviewer commented that: “I think it’s worth making a distinction here between convertibility and central administration of tech. Bitcoin, Bitcoin Cash, Ethereum, Ethereum Classic, Dash, etc are all not immediately convertible; the portion of tokens that actually are convertible is relatively low and I think everyone already agrees that those are regulated.” []
  28. Private correspondence on October 16, 2017. []
  29. For a related discussion see, Are Public Blockchain Systems Unlicensed Money Services Businesses in Disguise? from Ciaran Murray []
  30. One reviewer mentioned that in the event a fork occurs, there could be legal repercussions pursuant to Commodities Exchange Act (namely, section 6(c), rule 180). []
  31. Even some of the proposed “self-governing” blockchains ultimately start out fairly centralized, arguably as administrators and MTBs.  And due to the amount of coins that insiders and creators of these chains have, they could heavily influence the direction of votes (e.g., in a staking model, large coin holders are politically powerful entities who could coordinate and collude to fork in their own interest).  Will they always remain as administrators? []
  32. Many thanks to Ciaran Murray for providing this observation. []
  33. One of the reviewers asked how several current and proposed proof-of-stake coin-based projects would fit in here as potential solutions.  Since most of these are young and/or not even launched, see footnote 31 above.  Some have governance challenges already, see Backroom battle imperils $230 million cryptocurrency venture from Reuters.  Another reviewer opined that: “Systems like Bitshares, EOS, Tezos, et al will in practice be secure primarily precisely because there are large premines held by the foundations and developers themselves. It’s like a kind of ‘centralized administration without looking like centralized administration.'” []

Eight Things Cryptocurrency Enthusiasts Probably Won’t Tell You

[Note: I neither own nor have any trading position on any cryptocurrency.  I was not compensated by any party to write this.  The views expressed below are solely my own and do not necessarily represent the views of my employer or any organization I advise.  See Post Oak Labs for more information.]

Alternative title: who will be the Harry Markopolos of cryptocurrencies?

If you don’t know who Harry Markopolos is, quickly google his name and come back to this article.  If you do, and you aren’t completely familiar with the relevance he has to the cryptocurrency world, let’s start with a little history.

Background

Don’t drink the Koolaid

With its passion and perma-excitement, the cryptocurrency community sometimes deludes itself into thinking that it is a self-regulating market that doesn’t need (or isn’t subject to) government intervention to weed out bad actors.1 “Self-regulation,” usually refers to an abstract notion that bad actors will eventually be removed by the action of market forces, invisible hand, etc.

Yet by most measures, many bad actors have not left because there are no real consequences or repercussions for being a bad dude (or dudette).

Simultaneously, despite the hundreds of millions of dollars raised by VCs and over a couple billion dollars raised through ICOs in the past year or so, not one entity has been created by the community with the power or moral authority to rid the space of bad apples and criminals.  Where is the regulatory equivalent of FINRA for cryptocurrencies?2

Part of this is because some elements in the community tacitly enable bad actors. This is done, in some cases, by providing the getaway cars (coin mixers) but also, in other cases, with a wink and a nod as much of the original Bitcoin infrastructure was set-up and co-opted by Bitcoiners themselves, some of whom were bad actors from day one.3

There are many examples, including The DAO.4 But the SEC already did a good dressing down of The DAO, so let’s look at BTC-e.

BTC-e is a major Europe-based exchange that has allegedly laundered billions of USD over the span of the past 6 years.  Its alleged operator, Alexander Vinnik, stands accused of receiving and laundering some of the ill-gotten gains from one of the Mt. Gox hacks (it was hacked many many times) through BTC-e and even Mt. Gox itself.5 BTC-e would later go on to be a favorite place for ransomware authors to liquidate the ransoms of data kidnapping victims.

Who shut down BTC-e?

It wasn’t the enterprising efforts of the cryptocurrency community or its verbose opinion-makers on social media or the “new 1%.”  It was several government law enforcement agencies that coordinated across multiple jurisdictions on limited budgets.6 Yet, like Silk Road, some people in the cryptocurrency community likely knew the operators of the BTC-e and willingly turned a blind eye to serious misconduct which, for so long as it continues, represents a black mark to the entire industry.

In other cases, some entrepreneurs and investors in this space make extraordinary claims without providing extraordinary evidence.  Such as, using cryptocurrency networks are cheaper to send money overseas than Western Union.  No, it probably is not, for reasons outlined by SaveOnSend.7

But those who make these unfounded, feel-good claims are not held accountable or fact-checked by the market because many market participants are solely interested in the value of coins appreciating.  Anything is fair game so as long as prices go up-and-to-the-right, even if it means hiring a troll army or two to influence market sentiment.

And yet in other cases, the focus of several industry trade associations and lobbying groups is to squarely push back against additional regulations and/or enforcement of existing regulations or PR that contradicts their narrative.8

Below are eight suggested areas for further investigation within this active space (there could be more, but let’s start with this small handful):

(1) Bitfinex

Bitfinex is a Hong Kong-based cryptocurrency exchange that has been hacked multiple times.9  Most recently, about 400 days ago, $65 million dollars’ worth of bitcoins were stolen.

Bitfinex eventually painted over these large losses by stealing from its own users, by socializing the deficits that took place in some accounts across nearly all user accounts.10  Bitfinex has – despite promising public audits and explanations of what happened – provided no details about how it was hacked, who hacked it, or to where those funds were drained to.11 It has also self-issued at least two tokens (BFX and RRT) representing their debt and equity to users, listed these tokens on their own exchange and allowed their users to trade them.12

There have been suggestions of impropriety, with its CFO (or CSO?) Phil Potter publicly explaining how they handle being de-banked and re-banked:

“We’ve had banking hiccups in the past, we’ve just always been able to route around it or deal with it, open up new accounts, or what have you… shift to a new corporate entity, lots of cat and mouse tricks that everyone in Bitcoin industry has to avail themselves of.”

Yet there is little action by the cryptocurrency community to seek answers to the open questions surrounding Bitfinex.  I wrote a detailed post several months ago on it and the only reporters who contacted me for follow-ups were from mainstream press.

There are a lot of reasons why, but one major reason could be that some customers have financially benefited from this lack of market surveillance because relatively little KYC (Know Your Customer) is collected or AML (Anti-Money Laundering) enforced, so some trades and/or taxes are probably unreported.13 This wouldn’t be an isolated incident as the IRS has said less than 1,000 United States persons have been filing taxes related to “virtual currencies” each year between 2013 – 2015.

But that’s not all.

The latest series of drama began earlier this spring: Bitfinex sued Wells Fargo who had been providing correspondent banking access to Bitfinex’s Taiwanese banking partners.  Wells Fargo ended this relationship which consequently tied up tens of millions of USD that was being wired internationally on behalf of Bitfinex’s users.  About a week later Bitfinex dropped the suit and at least one person involved on the compliance side of a large Taiwanese bank was terminated due to the misrepresentation of the Bitfinex account relationship.

This also impacted the price of Tether.

Tether, as its name suggests, is a proprietary cryptocurrency (USDT) that is “always backed by traditional currency held in our reserves.”  It initially used a cryptocurrency platform called Mastercoin (rebranded to Omni) and recently announced an ERC20 token on top of Ethereum.1415

As a corporate entity, Tether’s governance, management, and business are fairly opaque.  No faces or names of employees or personnel can be found on its site.16  Bitfinex was not only one of its first partners but is also a shareholder.  Bitfinex has also created a new ICO trading platform called Ethfinex and just announced that Tether will be partnering with it in some manner.17

Tether as an organization creates coins.  These coins are known as Tethers that trade under the ticker $USDT each of which, as is claimed on their webpage, is directly linked, 1-for-1, with USD and yen equivalents deposited in commercial banks.  But after the Wells Fargo suit was announced, USDT “broke the buck” and traded at $0.92 on the dollar.18   It has fluctuated a great deal during the summer currently trades at $1.00 flat.

Which leads to the question: are the seven banks listed by the recent CPA disclosure aware of what Tether publicly advertises its USDT product as?19

Source: Tether LTD

Who is responsible for issuance, and how if at all can they be redeemed?  Are they truly backed 1:1 or is there some accounting sleight-of-hand taking place behind the scenes?20  Where are those reserves going to be exactly?  Who will have access to them?  Will either Tether (the company) or Bitfinex going to use them to trade?21 These are the types of questions that should be asked and publicly answered.

The only reason anyone is learning anything about the project is because of an anonymous Tweeter, going by the handle @Bitfinexed, who seemingly has nothing better to do than listen to hundreds of hours of audio archives of Bitcoiners openly bragging about their day trading schemes and financial markets acumen (in that order).

Despite myself and others having urged coin media to do so, to my knowledge there have been no serious investigations or transparency as to who owns or runs this organization.  Privately, some reporters have blamed a lack of resources for why they don’t pursue these leads; this is odd given the deluge of articles posted every month on the perpetual block size debate that will likely resolve itself in the passage of time.

The only (superficial) things we know about Tether (formerly Realcoin) is from the few bits of press releases over time.22  Perhaps this is all just a misunderstanding due to miscommunication.23  Who wants to fly to Hong Kong and/or Taiwan to find out more?

(2) Ransomware, Ponzi’s, Zero-fee and AML-less exchanges

Last month a report from Xinhua found that:

China’s two biggest bitcoin exchanges, Huobi and OKCoin, collectively invested around 1 billion yuan ($150 million) of idle client funds into “wealth-management products.”

In other words, the reason these exchanges were able to operate and survive while charging zero-fees is partially offset by these exchanges using customer deposits to invest in other financial products, without disclosing this to customers.24

Based on conversations with investigative reporters and former insiders, it appears that many, if not most, mid-to-large exchanges in China used customer deposits (without disclosing this fact) to purchase other financial products.  It was not just OKCoin and Huobi but also BTCC (formerly BTC China) and others.  This is not a new story (Arthur Hayes first wrote about it in November 2015), but the absence of transparency in how these exchanges and intermediaries are run ties in with what we have seen at BTC-e.  While there were likely a number of legitimate, non-illicit users of BTC-e (like this one Australian guy), the old running joke within the community is that hackers do not attack BTC-e because it was the best place to launder their proceeds.

Many exchanges, especially those in developing countries lacking KYC and AML processes, directly benefited from thefts and scams.  Yet we’ve seen very little condemnation from the main cheerleaders in the community.25

For example, two years ago in South Africa, MMM’s local chapter routed around the regulated exchange, patronizing a new exchange that wouldn’t block their transactions.26  MMM is a Ponzi scheme that has operated off-and-on for more than twenty years in dozens of countries.  In its most current incarnation it has raised and liquidated its earnings via bitcoin.  As a result, the volume on the new exchange in South Africa outpaced the others that remained compliant with AML procedures.  Through coordination with law enforcement it was driven out for some time, but in January of this year, MMM rebooted and it is now reportedly back in South Africa and Nigeria.  The same phenomenon has occurred in multiple other countries including China, wherein, according to inside sources, at least one of the Big 3 exchanges gave MMM representatives the VIP treatment because it boosted their volume.

It was a lack of this market surveillance and customer protections and outright fraud that eventually led to many of the Chinese exchanges being investigated and others raided by local and national regulators in a coordinated effort during early January and February 2017.27

Initially several executives at the non-compliant exchanges told coin media that nothing was happening, that all the rumors of investigation was “FUD” (fear, uncertainty, doubt).  But they were lying.28

Regulators had really sent on-site staff to “spot check” and clean up the domestic KYC issues at exchanges.  They combed through the accounting books, bank accounts, and trading databases, logging the areas of non-compliance and fraud.  This included problems such as allowing wash-trading to occur and unclear margin trading terms and practices.29 Law enforcement showed these problems (in writing) to exchange operators who had to sign and acknowledge guilt: that these issues were their responsibility and that there could be future penalties.

Following the recent government ban on ICO fundraising (described in the next section), all exchanges in China involved in fiat-to-cryptocurrency trades have announced they will close in the coming weeks, including Yunbi, an exchange that was popular with ICO issuers.30  On September 14th, the largest exchange in Shanghai, BTCC (formerly BTC China), announced it would be closing its domestic exchange by the end of the month.31 It is widely believed it was required to do so for a number of compliance violations and for having issued and listed an ICO called ICOCoin.32

Source: Tweet from Linke Yang, co-founder of BTCC

The two other large exchanges, OKCoin and Huobi, both announced on September 15th that they will be winding down their domestic exchange by October 31st.33  Although according to sources, some exchange operators hope this enforcement decision (to close down) made by regulators will quietly be forgotten after the Party Congress ends next month.34

One Plan B is a type of Shanzhai (山寨) hawala which has already sprung up on Alibaba whereby users purchase discrete units of funds as a voucher from foreign exchanges (e.g., $1,000 worth of BTC at a US-based exchange).35  Many exchanges are trying to setup offices and bank accounts nearby in Hong Kong, South Korea, and Japan, however this will not solve their ability to fund RMB-denominated trades.36

It is still unclear at this time what the exact breakdown in areas of non-compliance were largest (or smallest).37  For instance, how common was it to use a Chinese exchange for liquidating ransomware payments?

As mentioned in an earlier post, cryptocurrencies are the preferred payment method for ransomware today because of their inherent characteristics and difficulty to reclaim or extract recourse.  One recent estimate from Cybersecurity Ventures is that “[r]ansomware damage costs will exceed $5 billion in 2017, up more than 15X from 2015.”  The victims span all walks of life, including the most at-risk and those providing essential services to the public (like hospitals).

But if you bring up this direct risk to the community, be prepared to be shunned or given the “whataboutism” excuse: sure bitcoin-denominated payments are popular with ransomware, but whatabout dirty filthy statist fiat and the nuclear wars it funds!

Through the use of data matching and analytics, there are potential solutions to these chain of custody problems outlined later in section 8.

(3) Initial coin offerings (ICOs)

Obligatory South Park reference (Credit: Jake Smith)

Irrespective of where your company is based, the fundraising system in developed – let alone developing countries – is often is a time consuming pain in the rear.  The opportunity costs foregone by the executive team that has to road show is often called a necessary evil.

There has to be a more accessible way, right?  Wouldn’t it just be easier to crowdfund from (retail) investors around the world by selling or exchanging cryptocurrencies directly to them and use this pool of capital to fund future development?

Enter the ICO.

In order to participate in a typical ICO, a user (and/or investor) typically needs to acquire some bitcoin (BTC) or ether (ETH) from a cryptocurrency exchange.  These coins are then sent to a wallet address controlled by the ICO organizer who sometimes converts them into fiat currencies (often without any AML controls in place), and sends the user/investor the ICO coin.38

Often times, ICO organizers will have a private sale prior to the public ICO, this is called a pre-sale or pre-ICO sale.  And investors in these pre-sales often get to acquire tokens at substantial discounts (10 – 60%) than the rate public investors are offered.39.  ICO organizers typically do not disclose what these discounts are and often have no vesting cliffs attached to them either.

The surge in popularity of ICOs as a way to quickly exploit and raise funds (coins) and liquidate them on secondary markets has transitively led to a rise in demand of bitcoin, ether, and several other cryptocurrencies.  Because the supply of most of the cryptocurrencies is perfectly inelastic, any significant increase (or decrease) in demand can only be reflected via volatility in prices.

Hence, ICOs are one of the major contributing factors as to why we have seen record high prices of many different cryptocurrencies that are used as gateway coins into ICOs themselves.

According to one estimate from Coin Schedule, about $2.1 billion has been raised around the world for 140 different ICOs this year.40  My personal view is that based on the research I have done, most ICO projects have intentionally or unintentionally created a security and are trying to sell it to the public without complying with securities laws.41 Depending on the jurisdiction, there may be a small handful of others that possibly-kinda-sorta have created a new coin that complies with existing regs.42  Maybe.

Ignoring the legal implications and where each fits on that spectrum for the moment, many ICOs to-date have pandered to and exploited terms like “financial inclusion” when it best suits them.43  Others pursue the well-worn path of virtue signaling: Bitcoiners condemning the Ethereum community (which itself was crowdfunded as an ICO), because of the popularity in using the Ethereum network for many ICOs… yet not equally condemning illicit fundraising that involves bitcoin or the Bitcoin network or setting up bucket shops such as Sand Hill Exchange (strangely one of its founders who was sued by the SEC now writes at Bloomberg).

The cryptocurrency community as a whole condemned the “Chinese government” for its recent blanket ban on fundraising and secondary market listing of ICOs.44 The People’s Bank of China (PBOC) is one of seven regulators to enforce these regulations yet most of the public antagonism has been channeled at just the PBOC.45

Irrespective of whether you think it was the right or wrong thing to do because you heart blockchains, the PBOC and other regulators had quite valid reasons to do so: some ICO creators and trading platforms were taking funds they received from their ICO and then re-investing those into other ICOs, who in turn invested in other ICOs, and so forth; creating a fund of fund of funds all without disclosing it to the public or original investors.46 ICO Inception (don’t tell Christopher Nolan).

In China and in South Korea, and several other countries including the US, there is a new cottage industry made of up entities called “community managers” (CM) wherein an ICO project hires an external company (a CM) who provides a number of services:

  1. for X amount of BTC the CM will actively solicit and get your coin listed on various exchanges;
  2. the CM takes a sales commission while marketing the coin to the public such that after the ICO occurred, they would take a juicy cut of the proceeds; and several other promotional services.47

The ICO issuers and fundraising/marketing teams usually organize a bunch of ICOs weekly and typically employ a market maker (known as an “MM” in the groups) whose role is to literally pump and dump the coin.  They engage in ‘test pumps’ and ‘shakeouts’ to get rid of the larger ICO investors so they can push the price up on a thin order book by 10x, 20x, or 30x before distributing and pulling support. You can hire the services of one of these traders in many of the cryptocurrency trading chat groups.48

There were even ICO boot camps (训练营) in China (and elsewhere) usually setup with shady figures with prior experience in pyramid schemes.49  Here they coached the average person to launch an ICO on the fly based on the ideas of this leader to people of all demographics including the vulnerable and at-risk.50  Based on investigations which are still ongoing, the fraud and deceit involved was not just one or two isolated incidents, it was rampant.51 Obtaining the training literature that was given to them (e.g., the script with the promises made) would make for a good documentary and/or movie.

Scene from Boiler Room

In other words, the ICO rackets have recreated many aspects of the financial services industry (underwriters, broker/dealers) but without any public disclosures, organizational transparency, investor protections, or financial controls.  Much like boiler rooms of days past.  It is no wonder that with all of this tomfoolery, according to Chainalysis, that at least $225 million worth of ETH has been stolen from ICO-related fundraising activity this past year.52

At its dizzying heights, in China, there were about sixty ICO crowdfunding platforms each launching (or trying to launch) new ICOs on a monthly basis.53  And many of these platforms also ran and operated their own exchanges where insiders were pumping (and dumping) and seeing returns of up to 100x on coins that represented “social experiments to test human stupidity” such as the performance art pictured below.

One recent estimate from Reuters was that in China, “[m]ore than 100,000 investors acquired new cryptocurrencies through 65 ICOs in January-June [2017].”54  It’s still unclear what the final straw was, but the universal rule of don’t-pitch-high-risk-investment-schemes-to-grandmothers-on-fixed-incomes was definitely breached.

As a result, the PBOC and other government entities in China are now disgorging any funds (about $400 million) that ICOs had raised in China.55  This number could be higher or lower depending on how much rehypothecation has taken place (e.g., ICOs investing in ICOs).  All crowdfunding platforms such as ICOAGE and ICO.info have suspended operations and many have shut down their websites.  In addition, several executives from these exchanges have been given a travel ban.56

Cryptocurrency exchanges (the ones that predated the ICO platforms) have to delist ICOs and freeze plans from adding any more at this time.  Multiple ICO promotional events, including those by the Fintech Blockchain Group (a domestic fund that organized, promoted, and invested in ICOs) have been canceled due to the new ban.57  Several well-known promoters have “gone fishing” overseas.  This past week, Li Xiaolai, an early Bitcoin investor and active ICO promoter, has publicly admitted to having taken the ICO mania too far (using a car acceleration example), an admission many link to the timing of this crackdown and ban.58

A real ICO in China: “Performance Art Based on Block Chain Technology” (Source)

For journalists, keep in mind this is (mostly) just one country described above.  It would be a mistake to pin all of the blame on just the ICO operators based in China as similar craziness is happening throughout the rest of the world (observe the self-serving celebrity endorsements).  Be sure to look at not just the executives involved in an ICO but also the advisors, investors, figureheads, and anyone who is considered “serious” lending credibility to dodgy outfits and dragging the average Joe (and Zhou) and his fixed income or meager savings into the game.

There may be a legitimate, legal way of structuring an ICO without running afoul of helpful regulations, but so far those are few and far between.  Similarly, not everyone involved in an ICO is a scammer but it’s more than a few bad apples, more like a bad orchard.  And as shown above with the initial enforcement actions of just one country, short sighted hustling by unsavory get-rich-quick partisans unfortunately might deep-six the opportunities for non-scammy organizations and entrepreneurs to utilize a compliant ICO model in the future.59

(4) VC-backed entities

Theranos, Juicero, and Hampton Creek, meet Coinbase, 21.co, Blockstream, and several others.

Okay, so that may be a little exaggerated.  But still the same, few high-profile Bitcoin companies are publishing daily active or monthly active user numbers for a variety of reasons.

Founded in May 2012, the only known unicorn to-date is Coinbase.  Historically it has kept traction stats close to the chest but we got a small glimpse at what Coinbase’s user base was from an on-going lawsuit with the IRS.  According to one filing, between 2013-2015 (the most recent publicly available data) Coinbase had around 500,000 users, of which approximately 14,355 accounts conducted at least $20,000 in business.60 This is a far cry from the millions of wallets we saw as a vanity statistic prominently displayed on its homepage during that same time period.61

What did most users typically do?  They created an account, bought a little bitcoin, and then hoarded it – very few spent it as if it were actual money which is one of the reasons why they removed a publicly viewable transaction chart over a year ago.62

To be fair, the recent surge in market prices for cryptocurrencies has likely resulted in huge user growth.  In fact, Coinbase’s CEO noted that 40,000 new users signed up on one day this past May.  But some of this is probably attributed to new users using Coinbase as an on-and-off ramp: United States residents acquiring bitcoin and ether on Coinbase and then participating in ICOs elsewhere.63

After more than $120 million in funding, 21.co (formerly 21e6) has not only seen an entire executive team churn, but a huge pivot from building hardware (Bitcoin mining equipment) into software and now into a pay-as-you-go-LinkedIn-but-with-Bitcoin messaging service.  Launched with much fanfare in November 2015, the $400 Amazon-exclusive 21.co Bitcoin Computer was supposed to “return economic power to the individual.”

In reality it was just a USB mining device (a Raspberry Pi cobbled together with an obsolete mining chip) and was about as costly and useful as the Juicero juicing machine.  It was nicknamed the “PiTato” and unit sales were never publicly disclosed.  Its story is not over: in the process of writing this article, 21.co announced it will be launching a “social token” (SOC) by the end of the year.64

Blockstream is the youngest of the trio.  Yet, after three years of existence and having raised at least $76 million, as far as the public can tell, the company has yet to ship a commercial product beyond an off-the-shelf hardware product (Liquid) that generates a little over $1 million in revenue a year.65  It also recently launched a satellite Bitcoin node initiative it borrowed from Jeff Garzik, who conceived it on a budget of almost nothing about three years ago.66

To be fair though, perhaps it does not have KPIs like other tech companies.  For instance, about two and half years ago, one of their largest investors, Reid Hoffman, said Blockstream would “function similarly to the Mozilla Corporation” (the Mozilla Corporation is owned by a nonprofit entity, the Mozilla Foundation).  He likened this investment into “Bitcoin Core” (a term he used six times) as a way of “prioritiz[ing] public good over returns to investors.”  So perhaps expectations of product roadmaps is not applicable.

On the flipside, some entrepreneurs have explained that their preference for total secrecy is not necessary because they are afraid of competition (that is a typical rationale of regular startups), but because they are afraid of regulators via banks.67  For example, a regulator sees a large revenue number, finds out which bank provides a correspondent service and if the startup is fully compliant with AML, CFT, and KYC processes, starts auditing that bank, and banks re-evaluates NPV of working with a startup and potentially drops it.  Until that changes, we will not know volumes for Abra, Rebit, Luno, and others and that is why a year-old claim about 20% market share in the South Korea -> Philippines remittance corridor remains evidence-free.6869

While we would all love to see more data, this is a somewhat believable argument.  A more insightful question might be if/when we get to a point where supporting Bitcoin players becomes enough of real revenue that banks would agree to higher investments and support.  In the meantime, business journalists should drill down into the specifics about how raised money has been spent, is compliance being skirted, customer acquisition costs, customer retention rate, etc.70

(5) The decline of Maximalism

If you were to draw a Venn diagram, where one circle represented neo Luddism and another circle represented Goldbugism, the areas they overlap would be cryptocurrency Maximalism (geocentrism and all).71  This increasingly smaller sect, within the broader cryptocurrency community, believes in a couple of common tenets but most importantly: that only one chain or ledger or coin will rule them all.  This includes the Ethereum Classic (ETC) and Bitcoin Core sects, among others.

They’re a bit like the fundamentalists in that classic Monty Python “splitters” sketch but not nearly as funny.

If you’re looking to dig into defining modern irony, these are definitely the groups to interview.  For instance, on the one hand they want and believe their Chosen One (typically BTC or ETC) should and will consume the purchasing power of all fiat currencies, yet they dislike any competing cryptocurrency: it is us versus them, co-existence is not an option!  The rules of free entry do not apply to their coin as somehow a government-free monopoly will form around their coin and only their coin.  Also, you should buy a lot of their coin, like liquidate your life savings asap and buy it now.

Artist rendering of proto-Bitcoin Maximalism, circa 14th century

This rigidity has diminished over time.

Whereas, three years ago, most active venture capitalists and entrepreneurs involved in this space were antagonistic towards anything but bitcoin, more and more have become less hostile with respect to new and different platforms.

Source: Twitter

For instance, Brian Armstrong (above), the CEO of Coinbase, two and a half years ago, was publicly opposed to supporting development activities towards anything unrelated to Bitcoin.

But as the adoption winds shifted and Ethereum and other platforms began to see growth in their development communities (and coin values), Coinbase and other early bastions of maximalism began to support them as well.

Source: Twitter (1 2)

There will likely be permanent ideological holdouts, but as of this writing I would guesstimate that less than 20% of the bitcoin holders I have interacted with over the past 6-9 months would label themselves maximalists (the remaining would likely self-identify with the “UASF” and “no2x” tags on Twitter).

So interview them and get their oral history before they go extinct!

(6) Market caps

There is very little publicly available analysis of what is happening with Bitcoin transactions (or nearly all cryptocurrencies for that matter): dormant vs. active, customers vs. accounts, transaction types (self-transfers vs. remittances vs. B2B, etc.).

On-chain transaction growth seems to be slowing down on the Bitcoin network and we don’t have good public insights on what is going on: are there are pockets of growth in real adoption or just more wallet shuffling?

In other words, someone should be independently updating “Slicing data” but instead all we pretty much see is memes of Jamie Dimon or animated gifs involving roller coaster prices.72

In the real world, “market cap” is based on a claim on a company’s assets and future cash flows.  Bitcoin (and other cryptocurrencies) has neither — it doesn’t have a “market cap” any more than does the pile of old discarded toys in your garage.

“Market Cap” is a really dumb phrase when applied to the cryptocurrency world; it seems like one of those seemingly straightforward concepts ported to the cryptocurrency world directly from mainstream finance, yet in our context it turns into something misleading and overly simplistic, but many day traders in this space who religiously tweet about price action love to quote.

The cryptocurrency “market cap” metric is naively simplistic: take the total coin supply, and multiply it by the current market price, and voila!  Suddenly Bitcoin is now approaching the market cap of Goldman Sachs!73

Yeah, no.

To begin with, probably around 25% or more of all private keys corresponding to bitcoins (and other cryptocurrencies too) have been permanently lost or destroyed.74  Most of these were from early on, when there was no market price and people deleted their hard drives with batches of 50 coins from early block rewards without backing them up or a second thought.

Extending this analogy, 25% of the shares in Goldman Sachs cannot suddenly become permanently ownerless.  These shares are registered assets, not bearer assets.  Someone identifiable owns them today and even if there is a system crash at the DTCC or some other CSD, shareholders have a system of recourse (i.e., the courts) to have these returned or reissued to them with our without a blockchain.  Thus, anytime you hear about “the market price of Bitcoin has approached $XXX billion!” you should automatically discount it by at least 25%.

Also, while liquidity providers and market makers in Bitcoin have grown and matured (Circle’s OTC desk apparently trades $2 billion per month), this is still a relatively thinly traded market in aggregate.  It is, therefore, unlikely that large trading positions could simultaneously move into and out of billion USD positions each day without significantly moving the market.  A better metric to look at is one that involves real legwork to find: the average daily volume on fee-based, regulated spot exchanges combined with regulated OTC desks.  That number probably exists, but no one quotes it.  Barring this, an interim calculation could be based on “coins that are not lost or destroyed.”

(7) Buy-side analysts and coin media

We finally have some big-name media beginning to dig into the shenanigans in the space.  But organizations like CoinDesk, Coin Telegraph, and others regularly practice a brand of biased reporting which primarily focus on the upside potential of coins and do not provide equal focus on the potential risks.75  In some cases, it could be argued that these organizations act as slightly more respectable conduits for misinformation churned out by interested companies.76

Common misconceptions include continually pushing out stories like the example above, on “market caps” or covering vanity metrics such as growth in wallet numbers (as opposed to daily active users).  It is often the case that writers for these publications are heavily invested in and/or own cryptocurrencies or projects mentioned in their stories without public disclosure.

This is not to say that writers, journalists, and staff at these organizations should not own a cryptocurrency, but they should publicly disclose any trading positions (including ‘hodling’ long) as the sentiment and information within their articles can have a material influence on the market prices of these coins.

For instance, CoinDesk is owned by Digital Currency Group (DCG) who in turn has funded 80-odd companies over the last few years, including about 10 mentioned in this article (such as Coinbase and BTC China).  DCG also is an owner of a broker/dealer called Genesis Trading, an OTC desk which trades multiple cryptocurrencies that DCG and its staff, have publicly acknowledged at having positions in such as ETC, BTC and LTC.77

What are the normal rules around a media company (and its staff) retweeting and promoting cryptocurrencies or ICOs the parent company or its principals has a stake in?

If coin media wants to be taken seriously it will have to take on the best practices and not appear to be a portfolio newsletter: divorce itself of conflicts of interest by removing cross ownership ties and prominently disclose all of the remaining potential conflicts of interest with respect to ownership stakes and coin holdings.  Markets that transmit timely, accurate, and transparent information are better markets and are more likely to grow, see, and support longer-term capital inflows.78

Source: Twitter

Source: Twitter

For example, if Filecoin is a security in the US (which its creators have said it is), and DCG is an equity holder in Filecoin/Protocol Labs (which it is)… and DCG is an owner in CoinDesk, what are the rules for retweeting this ICO above?  There are currently 16 stories in the CoinDesk archive which mention Filecoin, including three that specifically discuss its ICO.  Is this soliciting to the public?79

Similarly, many of the buy-side analysts that were actively publishing analysis this past year didn’t disclose that they had active positions on the cryptocurrencies they covered.  We recently found out that one lost $150,000 in bitcoins because someone hacked his phone.

At cryptocurrency events (and fintech events in general), we frequently hear buzz word bingo including: smart assets, tokens, resilience, pilots, immutability, even in-production developments, but there is often no clear articulation of what are the specific opportunities to save or make money for institutions if they acquire a cryptocurrency or uses its network to handle a large portion of their business.80

This was the core point of a popular SaveOnSend article on remittances from several years ago.  I recommend revisiting that piece as a model for similar in-depth assessments done by people who understand B2B payments, correspondent banking and other part of global transfers.  Obviously this trickles into the other half of this space, the enterprise world which is being designed around specific functional and non-functional requirements, the SLAs, compliance with data privacy laws, etc., but that is a topic for another day.

What about Coin Telegraph?  It is only good for its cartoon images.81

Source: LinkedIn

There are some notable outliers that serve as good role models and exceptions to the existing pattern and who often write good copy.  Examples of which can be found in long end note.82

Obviously the end note below is non-exhaustive nor an endorsement, but someone should try to invite some or all these people above to an event, emceed by Taariq Lewis.  That could be a good one.

(8) Analytics

What about solutions to the problems and opaqueness described throughout this article?

There are just a handful of startups that have been funded to create and use analytics to identify usage and user activity on cryptocurrency networks including: Chainalysis, Blockseer, Elliptic, WizSec, ScoreChain, Skry (acquired by Bloq) – but they are few and far between.83  Part of the reason is because the total addressable market is relatively small; the budgets from compliance departments and law enforcement is now growing but revenue opportunities were initially limited (same struggle that coin media has).  Another is that the analytic entrepreneurs are routinely demonized by the same community that directly benefits from the optics they provide to exchanges in order to maintain their banking partnerships and account access.

Such startups are shunned today, unpopular and viewed as counter to the roots of (pseudo) anonymous cryptocurrencies, however, as regulation seeps into the industry an area that will gain greater attention is identification of usage and user activities.

For instance, four years ago, one article effectively killed a startup called Coin Validation because the community rallied (and still rallies) behind the white flag of anarchy, surrendering to a Luddite ideology instead of supporting commercial businesses that could help Bitcoin and related ideas and technologies comply with legal requirements and earn adoption by mainstream commercial businesses.  For this reason, cryptocurrency fans should be very thankful these analytics companies exist.

Source: Twitter. Explanation: Wanna Cry ransomware money laundering with Bitcoins in action. Graph shows Bitcoin being converted to Monero (XMR) via ShapeShift.io

More of these analytics providers could provide even better optics into the flow of funds giving regulated institutions better handling of the risks such as the money laundering taking place throughout the entire chain of custody.

Without them, several large cryptocurrency exchanges would likely lose their banking partners entirely; this would reduce liquidity of many trading pairs around the world, leading to prices dropping substantially, and the community relying once again on fewer sources of liquidity run out of the brown bags on shady street corners.84

One key slide from Kim Nilsson’s eye-opening presentation: Cracking MtGox

And perhaps there is no better illustration of how these analytic tools can help us understand the fusion of improper (or non-existent) financial controls plus cryptocurrencies: Mt. Gox.  Grab some warm buttery popcorn and be sure to watch Kim Nilsson’s new presentation covering all of the hacks that this infamous Tokyo-based exchange had over its existence.

Journalists, it can be hard to find but the full order book information for many exchanges can be found with enough leg work.   If anyone had the inclination to really want to understand what was going on at the exchange, there are 3rd parties which have a complete record of the order book and trades executed.

Remember, as Kim Nilsson and others have independently discovered, WillyBot turned out to be true.

Final Remarks

The empirical data and stories above do not mean that investors should stop trading all cryptocurrencies or pass on investing in blockchain-related products and services.

To the contrary, the goal of this article is to elevate awareness that this industry lacks even the most basic safeguards and independent voices that would typically act as a counterbalance against bad actors.  In this FOMO atmosphere investors need to be on full alert of the inherent risks of a less than transparent market with less than accurate information from companies and even news specialists.

Cryptocurrencies aren’t inherently good or bad.  In a single block, they can be used as a means to reward an entity for securing transactions and also a payment for holding data hostage.

One former insider at an exchange who reviewed this article summarized it as the following:

The cryptocurrency world is basically rediscovering a vast framework of securities and consumer protection laws that already exist; and now they know why they exist. The cryptocurrency community has created an environment where there are a lot of small users suffering diffuse negative outcomes (e.g., thefts, market losses, the eventual loss on ICO projects). And the enormous gains are extremely concentrated in the hands of a small group of often unaccountable insiders and “founders.” That type of environment, of fraudulent and deceptive outcomes, is exactly what consumer and investor protection laws were created for.

Generally speaking, most participants such as traders with an active heartbeat are making money as the cryptocurrency market goes through its current bull run, so no one has much motive to complain or dig deeper into usage and adoption statistics.  Even those people who were hacked for over $100,000, or even $1 million USD aren’t too upset because they’re making even more than that on quick ICO returns.

We are still at the eff-you-money stage, in which everyone thinks they are Warren Buffett.85  The Madoffs will only be revealed during the next protracted downturn.  So if you’re currently getting your cryptocurrency investment advice from permabull personalities on Youtube, LinkedIn, and Twitter with undisclosed positions and abnormally high like-to-comment ratios, you might eventually be a bag holder.86

Like any industry, there are good and bad people at all of these companies.  I’ve met tons of them at the roughly 100+ events and meetups I have attended over the past 3-4 years and I’d say that many of the people at the organizations above are genuinely good people who tolerate way too much drivel.  I’m not the first person to highlight these issues or potential solutions.  But I’m not a reporter, so I leave you with these leads.

While everyone waits for Harry Markopolos to come in and uncover more details of the messes in the sections above, other ripe areas worth digging into are the dime-a-dozen cryptocurrency-focused funds.

Future posts may look at the uncritical hype in other segments, including the enterprise blockchain world.  What happened after the Great Pivot?

[Note: if you found this research note helpful, be sure to visit Post Oak Labs for more in the future.]

Acknowledgements

To protect the privacy of those who provided feedback, I have only included initials: JL, DH, AL, LL, GW, CP, PD, JR, RB, ES, MW, JK, RS, ZK, DM, SP, YK, RD, CM, BC, DY, JF, CK, VK, CH, HZ, and PB.

End notes

  1. One reviewer commented: “Another meta-topic is the notion of “community,” which is a myth if you ask me.  Why hasn’t the “community” done “X”? Because the word is mostly a marketing fiction.” See also the discussion of the idea that “Code is not law” []
  2. One former regulator mentioned: “The cryptocurrency community needs to police itself better or it risks being policed more severely by unfriendly and unsympathetic regulators.  Self-regulation is what certain hands-off banking supervisors attempted with US banks and other financial institutions 15 years ago and that ended poorly for many parties including those who were not directly responsible for making the poor decisions in the first place.  Even in sports it is understood, with the exception of golf, it doesn’t work. In this Wild West atmosphere where are the sheriffs?” []
  3. Not unique to cryptocurrencies, but by enabling such bad actors, certain platform operators may even increase their short term profit. []
  4. Report of Investigation Pursuant to Section 21(a) of the Securities Exchange Act of 1934: The DAO []
  5. For an in-depth look at how the various moving pieces of the ecosystem interact, see: The flow of funds on the Bitcoin network in 2015, Cryptocurrency KYSF: Know Your Source of Funds, and Cryptocurrency KYSF: Know Your Source of Funds part 2 []
  6. Bitcoin Exchange Was a Nexus of Crime, Indictment Says from The New York Times []
  7. For an in-depth look at these different costs, it is highly recommended to read this post from Save on Send.  Some are convinced that this is the case because, on a small scale, the illiquidity of the end points serves to finance the operation, i.e. buying BTC with USD then selling BTC for MXN, may allow an apparent savings when compared with traditional remittance service providers.  Also oft-forgotten is the cost of cash-out and distribution of cash at the end point; also KYC / AML / CFT functions are frequently left-off the calculation. []
  8. One reviewer stated that, “Any working groups advising the government on policy are certainly worthy of investigation. Who are these people and what are their potential conflicts of interest?  For starters, in the US look at The Bitcoin Foundation and the Blockchain Alliance.” []
  9. It has a complex corporate structure and is nominally based in Hong Kong, operations and incorporation of subsidiaries are in other jurisdictions including BVI. []
  10. There were exceptions. Some users reported smaller haircuts as they were customers of SynapsePay.  Another user claims to have retained a lawyer and he did not have any haircut.  I independently verified this with an executive at SynapsePay. []
  11. Phil Potter, an executive at Bitfinex, has spoken about the hack on multiple different podcasts including once in detail, but this has since been deleted. []
  12. Bitfinex also recently announced that they will be doing an ICO (called NEC) to capitalize on the current token mania. []
  13. Bitfinex does do KYC and AML when a user withdraws USD and when they receive subpoenas. []
  14. ERC20 tokens are arguably not the same thing as a cryptocurrency, they are more like colored coins. See “Watermarked tokens and pseudonymity on public blockchains” by Tim Swanson. []
  15. Tether brings tokenised USD to Ethereum network from Finextra []
  16. We only know who is involved through various reddit threads wherein users dox and identify themselves as employees and founders. []
  17. Tether brings tokenised USD to Ethereum network from Finextra []
  18. This wouldn’t be the first time that a peg “broke the buck;” money market funds have been propped up by a parent organization in the past. []
  19. Tether Update []
  20. One reviewer noted that: “Theoretically they could maintain a fractional reserve to service redemptions although this isn’t a problem per se, provided that it is disclosed.  By saying you have “cash” backing, you could have some really bizarre stuff, like USD loans to unsavory entities.  But maybe they do not do this either.”  []
  21. Source for some of these questions. []
  22. One reviewer commented: “Tether offers users a way to move USD from one country to another, much like Western Union. So Tether should be obligated to run KYC/AML checks on not only those who are depositing US$ funds to get new Tethers (as it currently does), but also everyone who uses second-hand Tethers (it doesn’t). Now if Tether was like bitcoin, and had no physical address, it would be complicated for the authorities to enforce this requirement. But Tether is anchored to the brick & mortar banking system, so law enforcement should be easier, will it?” []
  23. One reviewer commented: “Let’s assume the worst for Tether, what does that mean?  If it were to collapse would it harm the small investors or the whales? A few exchanges that allow Tether also allow you to hold your deposits in USD, aside from the ability to send USDT between exchanges, which arguably could actually be a net positive because it allows clients to net positions between exchanges potentially reducing the overall credit in the system. But this goes back to one of their continual issues: lack of communicating and transparency for how the whole money issuance and transmission process works.” []
  24. Note: they did have withdrawal fees which likely generated revenue from arbitrageurs.  Several of the larger exchanges also raised venture capital and setup (and still run) order books outside of China with other business lines which may help offset some costs. []
  25. Described in further detail, “Comments on the COIN ETF (SR-BatsBZX-2016-30)” by Tim Swanson []
  26. See the section “Stopping Predators” within A Kimberley Process for Cryptocurrencies []
  27. China Central Bank Said to Call Bitcoin Exchanges for Talks from Bloomberg []
  28. In addition to lying about being investigated, they were lying about the true volume on their exchanges.  When the zero-fee domestic exchanges were required to add a minimum fee (to discourage wash trading), volume plummeted. []
  29. Central bank warns Bitcoin exchanges over margin trading, money laundering from Xinhua and Chinese bitcoin exchanges resume withdrawals after freeze from Reuters []
  30. Li Xiaolai: Yunbi Is Winding Down In 3 Months from 8BTC []
  31. BTCC to Cease China Trading as Media Warns Closures Could Continue from CoinDesk []
  32. Sources: CNLedger and ICOcoinOfficial []
  33. Huobi, OKCoin to Stop Yuan-to-Bitcoin Trading By October’s End from CoinDesk []
  34. The 19th National Congress of the Communist Party of China starts on October 18th.  All exchanges involving fiat-to-cryptocurrency trades will be closed. Both OKCoin and Huobi have overseas platforms (with independent order books and bank accounts independent of the domestic Chinese exchanges).  These have cryptocurrency-to-cryptocurrency trading and will remain operating.  Currently, users of the domestic fiat-to-currency platform can move their coins to the overseas platforms. []
  35. Something similar was done with voucher codes sold on Taobao in 2014 as well.  See After Crackdown, A New Bitcoin King Emerges in China from Wired []
  36. At one time or another, the spot price for each of the three large Chinese exchanges was a constituent part of several different pricing indices including the Winkdex, TradeBlock XBX index, and others such as OKEX (OKEX is an international subsidiary of OKCoin who replaced these exchanges on its own index).  This is potentially problematic because, as I detailed in my COIN ETF report, these exchanges were prone to mismanagement, crashes, and ultimately quick closure.  Going forward, what other sources of reliable pricing data can ETFs use that also accurately reflect market prices? []
  37. One insider in China noted that: “These exchanges had multiple chances to clean up their act and even self-regulate but because of the competitive pressures in China towards zero-fees, no one wanted to be left behind.  It was a type of collective action failure, so the government finally had to come in and clean up the mess because no one else would.” []
  38. These are mostly ERC20 tokens, not coins. []
  39. One reviewer mentioned: “Depending on the jurisdiction, these pre-arranged discounts might be deemed as structured products.” []
  40. Is There a Cryptocurrency Bubble? Just Ask Doge. from The New York Times []
  41. “How the ICO, OCO, and ECO ecosystem works at a high level” by Tim Swanson and “Comments on the COIN ETF (SR-BatsBZX-2016-30)” by Tim Swanson []
  42. Note: volumes can and will be written on this section alone.  If not on the legalities but on the ‘pump and dumps’ that have taken place. []
  43. One former regulator suggested: “Ignoring for the moment the overarching legal implications of what they did, because these activities took place on blockchains, future researchers should be able to eventually provide very accurate estimates the costs and losses to investors who put their trust and money into deceptive ICO organizers who were unscrupulous.” []
  44. Some argue this ban may just be temporary and cite a CCTV 13 interview with Hu Bing with the Institute of Finance and Banking who says the government will issue licenses in the future. []
  45. As of this writing there are many rumors circulating regarding how these new guidelines could impact cryptocurrency mining operators based in China.  One recent story from the Wall Street Journal articulates a rumor that miners will need to also shut down operations because they are trading cryptocurrencies without a license.  More existentially, if all fiat-to-cryptocurrency exchanges shut down domestically, miners would need a new method to liquidate their coins because they need to pay utilities in RMB (e.g., it doesn’t help to have a JPY or KRW-denominated bank account because Chinese utilities require being paid in RMB). []
  46. This same phenomenon occurred several years ago with “wealth management products” doing the same re-investment into other WMPs; revisiting the P2P Lending scams that came to light in the past two years as well is helpful.  See China’s ICO ban makes more sense in light of its history with fintech by Nik Milanovic []
  47. One insider noted that: “A New Zealand based person (and company) is one of the main men in all of this. I’ve encountered him on a number of occasions. He’s a complete fraudster. For example he told a group I am in that MGO would be listed on Poloniex within weeks of launch. Months later he hasn’t even got it on Bittrex. He’s now buying up lots of it wholesale from disenchanted investors who’ve taken a massive hit recently and will inevitably be sitting on a pile when the intentionally delayed launch and pump happens.” []
  48. Whalepool and The Coin Farm on Telegram are both examples of this type of coordination. []
  49. ICO被定性为涉嫌非法集资,想一夜暴富的“韭菜”们醒醒吧 from Huxiu []
  50. Based on translated stories from after the investigations as well as conversations with observers of these training sessions. []
  51. According to a source close to the investigations, law enforcement are using WeChat correspondence to chronicle the intentional cases of fraud and deceit.  In some cases, ICO organizers would run a public WeChat group, providing investors with false information and then use a private WeChat group with a smaller circle of insiders to “laugh at the stupidity” of these investors and coordinate dumps.  As a result, ICO organizers are leaving WeChat to use platforms like Telegram.  See China’s WeChat crackdown drives bitcoin enthusiasts to Telegram from South China Morning Post []
  52. That is the best case scenario because it assumes that there were not additional losses to fraud and mismanagement, which we know there has been. []
  53. China bans companies from raising money through ICOs, asks local regulators to inspect 60 major platforms from CNBC []
  54. Cryptocurrency chaos as China cracks down on ICOs from Reuters []
  55. Ibid []
  56. China shuts down Bitcoin industry; bans executives from leaving the country from Australian Financial Review []
  57. Another ICO Conference Cancels in Wake of China Ban from CoinDesk []
  58. He had to refund the ICOs he promote (plus with an added premium). []
  59. One reviewer commented: “The inevitability of regulations coming down the pipeline is a certainty (not just “blanket bans”).  Whether it’s 1 month or 1 year, regulations or enforcement of existing regulations will be coming in. A lot of these participants in the market seem to want to get in before regulations come into effect but in many jurisdictions they can still be liable for past actions (depending on the statute of limitations). That’s part of what I think is driving this tremendous amount of ICOs right now.” []
  60. 14,000 Coinbase Customers Could Be Affected by IRS Tax Summons from CoinDesk and Legitimate? IRS Defends Coinbase Customer Investigation in Court Filing from CoinDesk []
  61. At the time of this writing Coinbase has raised more than $225 million.  By January 2015, Coinbase had in aggregate raised just north of $106 million.  The ongoing lawsuit with the IRS states that there were 500,000 users by the end of the 2013 – 2015 period, of which 14,355 had done $20,000 or more of trading.   Future research can look into Coinbase’s customer acquisition costs over time (e.g., switching costs) versus the same costs traditional banks have.  Note: this also does not include the user numbers at GDAX, their platform marketed to professional traders. []
  62. According to an alleged insider (which may be untrue), some Coinbase users allegedly didn’t even know they may have been entitled to things like CLAM coins.  Maybe they weren’t. Tangentially, the continual high percentage of hoarding done by cryptocurrency enthusiasts suggests that this still remains a virtual commodity and continues to fail the medium of exchange test needed to be defined as a transactional currency. []
  63. At this time, it is unclear what the breakdown of these new (or old) users are acquiring cryptocurrencies on Coinbase and then participating in ICOs.  As a company, Coinbase has been publicly supportive of the ICO zeitgeist and hosted multiple meetups where ICO creators presented.  Earlier this year it co-sponsored a publication discussing the securities law framework of tokens.  Based on several interviews for this article, users of both the Coinbase wallet and its subsidiary, GDAX, currently can send bitcoins and ether from their user accounts to participate in ICOs.  It is unclear how often this is screened and/or prevented.  For perspective, a former employee was allegedly fired for sending bitcoins from his Coinbase account to gamble on Chinese web casinos.  Assuming this is true (and it may not be) then Coinbase could have the knowledge and/or ability to prevent users from participating in ICOs or other off-platform activity that violates its terms of service. []
  64. Another tech company that supposedly struggled raising funding and later issued its own coin (through an ICO) is Kik, through its Kin Foundation. []
  65. If this post is true (and it may not be), a dozen or so exchanges paying between $7,000 – $10,000 a month is roughly $1.4 million a year.  The SaaS monthly estimate has been independently validated from conversations with a couple participating exchanges. []
  66. One reviewer recommended: “If I were a journalist, I would more closely scrutinize the social media habits of the executives (and their surrogates) on these teams so the ecosystem can ascertain the relationship between the amount of time senior employees spend opining on Twitter, Reddit, mailing lists, IRC, WhatsApp, Slack, WeChat, Telegram, BitcoinTalk, GitHub, Discord, etc., and the number of hours in a working day, or number of products shipped.  Other social media analytics ideas for journalists: look at the Twitter tribes of Bitcoin (and other cryptocurrencies). Who is aligned with whom and pushing what agendas? Who are the trolls associated with those different tribes?  How many suspect accounts are associated with each group? For example, how many accounts that were just created, or never tweeted before, or only have followers from within their own tribes?” []
  67. One reviewer argued that, “It could also because they want to protect their valuations and because they are privately held companies that may be legally forbidden to divulge this information.” []
  68. This article in Quartz did not provide actual data or evidence that these remittance numbers were real, no one fact-checked it and instead, reproduced similar headlines for several months. []
  69. According to a recent interview with Forbes, after nearly two years of operations Abra only has 73 users per day. They are currently raising another round at this time; it is believed that this will help fund their compliance team and for licenses which they currently lack. []
  70. One reviewer said, “A counterpoint could be: VC returns are even sharper than standard Pareto; 1:9 or even 1:99 as opposed to 2:8. Startups are hard – most fail – why should cryptocurrency world be any different?” []
  71. One reviewer suggested that: “In the future, you should explain why Maximalism is a type of Authoritarianism and is not to be conflated with cypherpunks.” []
  72.  In mid-September, vocal promoters and owners of cryptocurrencies such as Bitcoin collectively spent thousands of hours yelling on social media and conducting letter writing campaigns all to channel their anger towards comments made by Jamie Dimon.  A couple worthwhile followups include: JPMorgan handles bitcoin-related trades for clients despite CEO warning from Reuters and  MUFG CEO on Dimon Remarks: Bank Cryptocurrencies Have ‘Nothing to Do With Bitcoin’ from CoinDesk []
  73. Bitcoin was only used as an example, nearly all cryptocurrencies listed on CoinMarketCap have the same issue in terms of calculating a real “market cap.” []
  74. Learning from Bitcoin’s past to improve its future from Tim Swanson []
  75. The theatrics around “BearWhale”-like events still persists.  For example, one current conspiracy theory is that: “the Chinese government is shutting down Bitcoin miners to mine bitcoins themselves.”  This is most likely false and the proposed solution is to “use satellites.”  But in talking with professional miners in China, many of them have contracts directly with State Grid, so they could lose access to energy in a worst-case scenario and satellites would not be of any use (assuming any of those rumors are true). []
  76. To be fair, this is not unique to the cryptocurrency space. []
  77. Genesis Trading is also the marketing and distribution agent for Bitcoin Investment Trust and Ethereum Classic Investment Trust, two regulated financial products.  DCG also is an owner in Grayscale Investments which is the legal sponsor both of these Trusts []
  78. Research: How Investors’ Reading Habits Influence Stock Prices by Anastassia Fedyk and Effects of Misinformation on the Stock Return: A Case Study by Ahsan et al. []
  79. Some employees in coin media have used social media channels to discuss various cryptocurrencies including ICOs over the past year.  How many of these were sponsored or received a cut of the coins to do so? []
  80. A great paper on this topic is The Path of the Blockchain Lexicon (and the Law) by Angela Walch []
  81. Nearly all of the coin media site allow ICO advertisements as well.  What are the terms and benefits that these media sites receive in exchange for displaying these advertisements and advertorials? []
  82. Note: this is not an exhaustive list and I’ll likely be flamed for not including X but including Y.  Journalists who write good original stories include: Nathaniel Popper, Matt Levine, and Matt Leising.  There have been several good op-eds written by lawyers which have appeared on CoinDesk, including Joshua Stark, Jared Marx, Brian Klein, Benjamin Sauter and David McGill.  Some other original, constructive views that should be highlighted include Stephen Palley, Ryan Straus, George Fogg, Miles Cowan, Patrick Murck, Amor Sexton, Houman Shadab, Angela Walch, Scott Farrell, Claire Warren, Simon Gilchrist, and two perpetual curmudgeons: Izabella Kaminska and Preston Byrne (very prickly at times!).  Non-lawyer thought-leaders, technical, and subject matter experts with bonafides worth interviewing include: Adam Krellenstein, Alex Batlin, Alex Waters, Andrew Miller, Andy Geyl, Antony Lewis, Ari Juels, Arvind Narayanan, Christian Decker, Christopher Allen, Ciaran Murray, Colin Platt, Danny Yang, Dave Hudson, David Andolfatto, David Schwartz, Dominic Williams, Duncan Wong, Elaine Shi, Emily Rutland, Emin Gun Sirer, Ernie Teo, Fabio Federici, Flavien Charlon, Gideon Greenspan, Ian Grigg, Ittay Eyal, Jackson Palmer, Jae Kwon, James Hazard, James Smith, Jana Moser, Jeff Garzik, JP Koning, John Whelan, Jonathan Levin, Jonathan Rouach, Jorge Stolfi, Juan Benet, Juan Llanos, Kieren James-Lubin, Lee Braine, Leemon Baird, Makoto Takemiya, Mark Williams, Matthew Green, Martin Walker, Massimo Morini, Michael Gronager, Mike Hearn, Muneeb Ali, Piotr Piasecki, Richard Brown, Robert Sams, Ron Hose, Sarah Meiklejohn, Stefan Thomas, Stephen Lane-Smith, Vitalik Buterin, Vlad Zamfir, Yakov Kofner, Zaki Manian, Zennon Kapron, and Zooko Wilcox-O’Hearn, as well as dozens of others from several different financial institutions and enterprises too long to list.  I also think that Michael del Castillo, Ian Allison, Simon Taylor, Jon Southurst, and Arthur Falls try to do an honest job reporting too.  Epicenter TV is arguably the best podcast in this space. []
  83. For an example, see Cracking Mt. Gox by WizSec []
  84. Chainalysis has a partnership with Circle which in turn enabled Circle to open up an account with Barclays.  Two years ago, an alleged business plan for Chainalysis was leaked online and unsurprisingly, some in the community were up in arms that this small company provided these forensic services. []
  85. Partially inspired by this tweet. []
  86. Click farms are being used by various ICO and Bitcoin-related online personalities to boost their perceived importance. []

Which regulators have publicly commented on Initial Coin Offerings?

Below are some of the stated positions of several different regulators around the world regarding ICOs.  In chronological order:

    • Brazil’s equivalent of the SEC, the Comissão de Valores Mobiliários (CVM), published (July 13th) initial legislation instruction (Instrução CVM No. 588) regulating crowdfunding via ICOs: (Portuguese announcement)
    • The United States SEC published on July 25th on ICOs: (Report on investigation) (Investor bulletin) (Investor alert)
    • Monetary Authority of Singapore published its views on August 1st on ICOs: (Clarification statement) (Consumer advisory)
    • Canadian Securities Administrators (CSA), including the Ontario Securities Commission, published its views on August 24th on ICOs: (Staff Notice) (Announcement)
    • Israel Securities Authority announced on August 30th that it is forming a committee to look at ICOs: (Hebrew announcement) (English)
    • The Financial Supervisory Commission (FSC) in South Korea announced on September 3rd that it held a joint task force meeting to strengthen regulations around digital currency trading, including fundraising with ICOs: (BusinessKorea)
    • Central Bank of Russia issued a public statement on September 4th that included its views on ICOs: (Russian announcement) (English)
    • The People’s Bank of China, along with 6 other Chinese government bodies including the national securities regulator (CSRC), publicly banned ICO fundraising in China on September 4th: (CN announcement) (English) (Bloomberg) (Reuters)
    • SFC in Hong Kong announced its views on ICOs on September 5th: (Announcement)
    • The UK Financial Conduct Authority (FCA) announced that it was keeping a close eye on ICOs on September 6th: (FT)
    • The Securities Commission (SC) of Malaysia issued a press release cautioning investors in ICOs on September 7th: (DNA)
    • The Dubai Financial Services Authority (DFSA) warned investors that ICOs were risky on September 13th: (Statement)
    • The Securities and Exchange Commission in Thailand issued some statements regarding ICOs on September 14th: (Comments)
    • Gibraltar Financial Services Commission (GFSC) issued an official statement regarding ICOs on September 22nd: (Statement)
    • North American Securities Administrators Association (NASAA) issued its annual paper and warned of risks around cryptocurrencies and ICOs on September 26th: (Press release)
    • Macau Monetary Authority (MMA) announced that banks cannot engage with ICOs and cryptocurrencies either “directly or indirectly” on September 27th: (Statement)
    • The Australian Securities and Investments Commission (ASIC) released formal guidance and comments about ICOs on September 28th: (Information Sheet)
    • The Financial Services Commission in South Korea said all kinds of initial coin offerings (ICO) will be banned as trading of virtual currencies needs to be tightly controlled and monitored on September 29th: (Reuters) (Yonhap)
    • The Financial Market Supervisory Authority (FINMA) in Switzerland announced it is investigating ICO procedures and issued formal guidance on September 29th: (Press Release)
    • SEC Exposes Two Initial Coin Offerings Purportedly Backed by Real Estate and Diamonds on September 29th: (Press release)
    • Abu Dhabi’s Global Market’s Financial Services Regulatory Authority (FSRA) released guidelines on ICOs on October 9th: (Guidelines)
    • The Central Bank of Lithuania announced its position and guidelines regarding ICOs on October 11th: (Press release)
    • The US Commodity Futures Trading Commission (CFTC), through its internal division, LabCFTC, released a primer on cryptocurrencies including ICOs on October 17th: (Press release)
    • The Financial Markets Authority (FMA) released commentaries on cryptocurrencies and ICOs on October 25th: (Press release) (Commentary)
    • Japan’s Financial Services Agency (FSA) issued a short statement warning users and business operators about the risks of ICOs on October 27th: (Statement)
    • The European Securities and Markets Authority (ESMA) issued two public statements on ICOs: one on risks and the other on rules applicable to firms involved in ICOs on November 13, 2017: (Press Release)

What do they all say?  A friend who is an attorney said it concisely: when you sell securities, you have to comply with securities laws.

If you plan to do an ICO or some kind of token sale, be sure to speak with more than one lawyer or law firm to get a legal opinion about what it is you are actually selling (or not).

And if you’re interested, below is an interview of Nick Morgan.  He is an attorney who previously was part of the SEC’s enforcement team.  He discusses The DAO, securities regulations, and the current ICO frenzy.

Bonus:

  • ECB’s Draghi rejects Estonia’s virtual currency idea – Reuters
  • Initial Coin Offerings: Know Before You Invest – FINRA