[SpicyLemonZest]

"Ponzi scheme" isn't a legal term, the specific SEC claims are all about fraud. But the point of calling it that is to emphasize that there was very little underlying business value to be honest about. I don't think there's any point in picking apart the story for the few parts that might have been legal if they were properly disclosed - if the SEC's allegations are correct, many of those parts would have only existed in the first place as tools to help disguise the fraud.