[cowl]

Although technically you are right that the "intrinsic value" is not explicitly stated by SEC, the whole purpose of the Howey Test it to establish whether something has intrinsic Value. At least that's my interpretation of it. The main points of it are is it an investment and does this investment value depend only on the enterprise you investing on and promotion or does it have any other value that is independent of those factors (thus intrinsic value). Put it another way, if you investment is completely lost when the actor who put it in the market disappears, then it is a security.