Overview

• The SEC’s Division of Corporation Finance said it will not recommend enforcement against DoubleZero’s programmatic 2Z distributions as described in a Sept. 25 filing.
• DoubleZero’s design compensates Network Providers for high-performance connectivity and Resource Providers for calculating payment amounts, positioning 2Z as operational compensation.
• Commissioner Hester Peirce characterized DePIN tokens as functional incentives rather than investment contracts under the Howey Test and cautioned that securities treatment would hinder network growth.
• The staff relief is non-binding and fact-specific, with the SEC noting that different circumstances could lead to a different outcome and that the letter is not a legal determination.
• Reporting indicates DoubleZero plans a Friday mainnet and token debut on Solana, while industry voices including co-founder Austin Federa and the DeFi Education Fund view the letter as a practical signal for U.S. DePIN projects.