[davidgerard]

What I mean by "SAFT is dead" is that the purpose they were overwhelmingly used for - which really was to try to sell token futures as a security, but have the resulting tokens not be a security - is a non-starter.

Sure you can try to construct exceptions to this - but dodging the Howey test was what SAFTs were invented for, and I feel reasonably confident in stating that this complaint against Telegram makes it very clear that this just isn't going to fly.