https://www.jdsupra.com/legalnews/cryptocurrencies-and-the-s...
a contract, transaction or scheme whereby a person invests his money in a common enterprise and is led to expect profits solely from the efforts of the promoter or a third party
And I find it odd that your referenced article mentions three tests, when it seems to be normally listed as four prongs: https://duckduckgo.com/?q=howey+test+prongs
And I find it odd that your referenced article mentions three tests, when it seems to be normally listed as four prongs: https://duckduckgo.com/?q=howey+test+prongs