Writing
Paradigm Files Amicus Brief in NY AG's Case Against KuCoin Pushing Back Against Allegation that ETH is a Security
Paradigm filed an amicus brief in the lawsuit that the NY AG brought against KuCoin, in which the OAG alleged that certain tokens traded by KuCoin, including ETH, are securities. Our brief highlights the unfairness of the OAG’s tactics, which deprive the most affected parties an opportunity to defend themselves in court.
May 18, 2023
Paradigm Files Amicus Brief Supporting Coinbase’s Writ of Mandamus
Today Paradigm filed an amicus brief in support of Coinbase’s lawsuit that seeks to compel the SEC to respond to the company’s pending rulemaking petition.
May 10, 2023
Paradigm Files Comment Letter in Response to Proposed Amendments to the Custody Rule
TLDR: Today Paradigm submitted a comment letter to the SEC regarding the Commission’s proposed amendments and redesignation of rule 206(4)-2 (better known as the Custody Rule).
May 8, 2023
Moneyness In The Digital Age
The recent events surrounding Silicon Valley Bank (SVB) provide a lens for reexamining age-old questions about the relationship between money and credit — and crypto’s important role in the future.
April 26, 2023
Paradigm Files Amicus Brief in SEC vs Terra
Paradigm was not an investor in the Terra ecosystem and our brief was filed in support of neither party’s motion—our only interest was to push back against the SEC’s continued attempts to expand their jurisdiction over crypto.
April 24, 2023
SEC’s Path to Registration - Part III
The Current SEC Disclosure Framework Is Unfit for Crypto
The grand bargain of the US securities laws is that any issuer selling securities to the general public must provide the public with a set of disclosures approved by the SEC. These laws are intended to address information asymmetry and ensure that the investing public has the material information necessary to make informed investment decisions. The securities laws are not intended to turn the SEC into a gatekeeper or “merit regulator” that itself decides which projects are investable and which are not. Congress meant for discretion to remain solidly in the hands of individual investors.
April 20, 2023
Paradigm Files Van Loon Amicus Brief
Paradigm filed an amicus brief in the lawsuit that six Tornado Cash users brought to challenge the government’s unprecedented sanctioning of the Tornado Cash open-source code.
April 17, 2023
March 2023 Public Opinion Poll
While Washington sits on the sidelines, Americans want regulatory clarity on crypto. That's the bottom line on a poll we recently conducted to better understand how Americans view crypto.
March 24, 2023
SEC’s Path to Registration - Part II
Lessons from Crypto Projects’ Failed Attempts to Register with the SEC
The grand bargain of the US securities laws is that any issuer selling securities to the general public must provide the public with a set of disclosures approved by the SEC. These laws are intended to address information asymmetry and ensure that the investing public has the material information necessary to make informed investment decisions. The securities laws are not intended to turn the SEC into a gatekeeper or “merit regulator” that itself decides which projects are investable and which are not. Congress meant for discretion to remain solidly in the hands of individual investors.
March 23, 2023
SEC’s Path to Registration - Part I
Due to SEC Inaction, Registration is Not a Viable Path for Crypto Projects
SEC Chair Gary Gensler would like the American public to believe that it is just as simple and easy for crypto founders to register tokens or crypto products with the SEC. It’s not.
March 23, 2023
Paradigm Files Amicus Brief in SEC vs Wahi
Today, Paradigm filed an amicus brief in SEC vs. Wahi that rejects the SEC’s expansive and unsupported application of securities laws to crypto secondary markets.
March 10, 2023
You Can't Regulate What You Can't Understand: The Case for Modernizing Government Ethics Rules
The tl;dr is that ethics rules effectively bar most government employees from owning crypto.
February 21, 2023
Using On-Chain Data for Policy Research, Part 3: Mint/Burn Dashboard
Today, fiat-backed stablecoins are an important part of the crypto ecosystem and looking closely at on-chain data can surface issues that lead to better-designed stablecoins. Rather than write an academic-style report, our approach here is to make available a clean data set and deliver an interactive data dashboard to encourage more individual use and exploration of on-chain activity.
February 16, 2023
Using On-Chain Data for Policy Research, Part 2: Stablecoin Risk Rundown
The first post in this series provided an overview of one of the many ways to access on-chain data for use in policy research. This piece builds on that work by introducing a set of policy issues relevant to stablecoins, including what can and can't be probed using on-chain data. It also covers a few practical steps related to data cleaning. It is intended for policy professionals operating at the academic-practitioner frontier.
January 19, 2023
Paradigm Files Amicus Brief in SEC’s Lawsuit Against Ripple
Last week, Paradigm filed an amicus brief in the SEC’s lawsuit against Ripple Labs, Inc. Our goal is to help the Court avoid the unintended consequences of casually endorsing the SEC’s position in this case, which conflates an investment scheme with the crypto asset sold in that scheme.
November 17, 2022
Introducing Paradigm’s Policy Council
We are excited to announce the first iteration of the Paradigm Policy Council, an impressive group of bipartisan talent with a diverse set of experiences. This team will advise Paradigm’s leadership team and help us tell the story of Web3 in Washington and around the world.
November 7, 2022
Paradigm Files Amicus Brief in CFTC Action Against "Ooki DAO"
Paradigm is filing an amicus brief in the case recently brought by the CFTC against “the Ooki DAO.” While we are not a party to the case, we thought it was necessary to speak up against the CFTC’s attempt to expand liability to unsuspecting technology users and impair the ability of DAOs to operate in the US.
October 17, 2022
Using On-Chain Data for Policy Research: Part 1
Crypto policy work rarely involves real, granular data. This is a missed opportunity, given how many tools used by the modern economics and finance community should directly translate to crypto data analysis. Crypto offers granular data, available to anyone, by design.
October 13, 2022
Ethereum's New ‘Staking’ Model Does Not Make ETH A Security.
Ethereum’s adoption of a proof-of-stake consensus mechanism does not make ETH (or even staked ETH) an investment contract, and such a finding would result in a nonsensical application of securities laws.
October 5, 2022
What is the Merge?
The Ethereum network will soon undergo an update known as the Merge. The primary goal of the Merge is to transition Ethereum's consensus mechanism from a model known as proof-of-work (PoW) to one called proof-of-stake (PoS).
September 15, 2022
Base Layer Neutrality
With this analysis, we hope to ease uncertainty plaguing industry actors and provide clarity around the scope of sanctions compliance obligations.
September 8, 2022
DAO Strategy and Legal Wrappers
One of the important features of Web3 is the way in which blockchain-based technology enables individuals to organize themselves in novel arrangements to make problem solving potentially more creative, efficient and communitarian.
June 8, 2022
Joining Paradigm · Katie Biber
June 6, 2022
Joining Paradigm · Justin Slaughter
February 14, 2022