Overview

• The SEC’s Division of Corporation Finance said it will not recommend enforcement if DoubleZero adheres to the programmatic transfers described in its Sept. 25 submission.
• Based on those facts, the agency indicated 2Z does not meet securities criteria under current law and will not be treated as a class of equity securities under the Exchange Act.
• The distribution model compensates network and resource providers for connectivity and payment-calculation work, and it is not structured as a capital-raising sale.
• DoubleZero’s Solana mainnet beta and 2Z rollout are expected Friday, with participant rewards tied to performance and reliability.
• The SEC emphasized the letter is fact-specific and not a legal determination, and observers see it as a narrow template for other DePIN projects.