The new hotness is “governance tokens” where no money is raised and tokens are dumped into a yield farm. The tokens have no utility or rights, just the ability to vote on governance. These tokens are worth billions of dollars in total. Example token launched this way <a href="https://www.coingecko.com/en/coins/yearn-finance" rel="nofollow">https://www.coingecko.com/en/coins/yearn-finance</a><p>These launches side step many aspects of the Howie Test such as “an investment of money”. I’m unsure that the SEC would win in court against these.