Why SAB-121 is Massive for Crypto | Round Up

Primary Topic

This episode delves into the significant impact of SAB-121 on the cryptocurrency industry, exploring its implications for crypto custodians and the broader financial landscape.

Episode Summary

In this episode of Blockworks' podcast, hosts Santiago Roel Santos and Jason Yanowitz tackle the pivotal role of SAB-121, a policy from the SEC that has stirred the crypto community due to its demanding requirements for crypto custodians. They discuss the bipartisan efforts in Congress to address the challenges posed by this policy, emphasizing its unexpected passage through both the House and Senate, highlighting the substantial bipartisan support it received. The episode also covers a variety of crypto-related topics, including security, online crime, and the involvement of political figures in cryptocurrency advocacy, providing a comprehensive overview of the current state and future prospects of cryptocurrency regulation and adoption.

Main Takeaways

  1. SAB-121 requires crypto custodians to hold corresponding assets on their balance sheets, complicating accounting practices.
  2. The resolution to challenge SAB-121 passed with surprising bipartisan support, reflecting a growing political interest in cryptocurrency.
  3. Significant concerns persist about the SEC’s approach to issuing such guidelines without a formal rulemaking process.
  4. The potential presidential veto of the resolution could have broad implications for the political landscape concerning crypto policies.
  5. The episode discusses broader themes such as the role of crypto in politics, the impact of regulatory decisions on market dynamics, and the ongoing debates within the crypto community regarding regulation and innovation.

Episode Chapters

1: Introduction to SAB-121

Exploring the origins and implications of SAB-121, highlighting its potential impacts on the crypto custody landscape. Santiago Roel Santos: "SAB-121 requires a burdensome balance sheet adjustment for custodians, which could stifle innovation."

2: Political Dynamics

Discussion on the political response to SAB-121, including the bipartisan efforts to overturn it. Jason Yanowitz: "The strong bipartisan support for overturning SAB-121 signals a significant shift in how politicians view crypto regulation."

3: Broader Crypto Regulatory Environment

Analyzing the SEC's regulatory approach and its reception in the crypto community. Casey Wagner: "The way SAB-121 was passed reflects poorly on the SEC’s transparency with the crypto industry."

Actionable Advice

  1. Stay informed about changes in crypto regulation that could affect your investments or business.
  2. Engage with community discussions on regulatory impacts to better understand the broader implications.
  3. Consider the political landscape when making investment decisions in the crypto space.
  4. Monitor the actions of regulatory bodies like the SEC to anticipate future regulatory challenges.
  5. Participate in advocacy efforts to support or oppose regulations impacting the crypto industry.

About This Episode

In this episode, Santi and Jason discuss the SAB-121 vote with Blockworks' Senior Reporter Casey Wagner, unpacking its bipartisan political support and huge implications for crypto. They cover the DOJ's charges in the $25M MEV boost exploit, the resurgence of meme stock mania with GameStop, and the ongoing Pump.Fun exploit drama. Santi shares his framework for valuing L1 and L2 blockchains based on total economic value. They close our by highlighting insights from DBA's research day and share their favorite youtube comments. Enjoy!

People

Santiago Roel Santos, Jason Yanowitz, Casey Wagner

Companies

Blockworks

Books

Leave blank if none.

Guest Name(s):

Casey Wagner

Content Warnings:

None

Transcript

Santiago Roel Santos

Let me ask you the question. You're american, like you work in the industry. Is it not refreshing and a breath of fresh air to hear someone actually be supportive of the industry? Can you not empathize with people that have been feeling very stressed under the current administration? Say, you know what?

Yeah, I'm a single issue voter. Does that make you a fool? I don't think so. This episode is brought to you by say SE's v two upgrade introduces the first high performance parallelized EVM already live on public Devnet Mainnet comes later in Q two. You can follow along with the say journey on X.

Jason Yanowitz

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When you visit auraaura.com forward slash blockworks terms and conditions apply cipher details. You'll hear more about aura later in the show. This episode is brought to you by Kinto, the safety first layer two that features user owned KYC and native account abstraction to solve the two biggest roadblocks to mainstream adoption. One, security and two, user experience. Their founder Ramon sent me the onboarding flow it's engine Kinto XYZ.

I would highly recommend becoming a founding member of their launch program. You'll hear more about Kinto later in the show. Are you tired of high gas fees? I'm excited to let you know about Skale, a zero gas fee modular blockchain that's become a perfect fit for gaming and AI apps because of their instant finality and lack of mev. Explore the Skale ecosystem today at Skale space forward slash ecosystem and stay up to date with the gasless blockchain on X at Scalenetwork.

That's scale network big. Thanks to scale for sponsoring Empire.

Bada bing, bada boom. All right, roundup time. What's up, man? Well, not much, you know, it's just coming back from New York feeling very refreshed. Nice.

Santiago Roel Santos

Wishing I'd be there again. Give me the highlights and the lowlights of the trip. There's too much going on to go into that, but we hosted a great meetup. Bunch of people showed up. That was really cool.

And yeah, I met with a bunch of people in the Solana team, a bunch of teams. They have an office there in Soho and so I was there. Really got to see a lot of the teams building. It's just really energizing to be there and meet with a lot of these guys and teams. And so, yeah, really cool.

Jason Yanowitz

Nice. Nice. Little pleaserdo dinner Friday night. That, too. That was also really nice.

Santiago Roel Santos

Can't believe I've never listened to the Wu Tang album. Leshner actually was the one who first called out the op ed that kind of went viral over the weekend. He's like, look. He's like, what is this op ed? And had, like, three likes.

Jason Yanowitz

And I was like, oh, I'm. I don't. He was the first. I was like, oh, I don't know. Probably nothing, whatever.

And then woke up Saturday morning with about 70 DM. So we'll talk about this op ed. I want to talk about also research day York that dBA put on. I want to talk about this mev. Like, DOJ took down a couple of mev guys.

What else we talking about? Gamestop came back. I'm curious if you think that's, like, sign of retail coming back. We can talk about that. There's, like, an ongoing thing as we are recording this about margin, fi and pump.

Fun. It's very unclear of, like, what really happened because it just came out five minutes ago. But first, let's talk Sabbath. Sab 121. Yeah.

Santiago Roel Santos

Yeah, let's definitely do that. Cool. Let me pull. So we've got Casey Wagner from blockworks joining. Casey's been on the show a bunch.

Jason Yanowitz

So, Case, welcome to. Welcome back to Empire. Hi. Thanks for having me. Thanks for coming on.

I did ask Casey to come on about four minutes ago, so we've got ample prep time. But, Case, maybe if you could lay out you've had some really good coverage of. I guess. It's not a bill you were explaining to me. It's a bullet bulletin board or something or another.

Can you. Can you explain to us what Saab 121 is? Okay. Yeah. So Saab 121 is kind of the background policy from the SEC, which inspired joint resolution 109.

Casey Wagner

It's not a bail, it's a resolution, but the process to pass is very similar. And that is what passed in the House last week, and it passed in the Senate just a few minutes ago with actually a lot more bipartisan support than I think anyone was expecting. So what was Saab 121? Why was it so important? What is the related custody in banks?

Jason Yanowitz

And can you just give us an outline of it? People in the crypto industry were interested in Saab 121 because it basically says that anyone who custodies crypto assets has to hold a corresponding group of assets on their balance sheet, and they have to list it as a liability. So it makes accounting a lot more difficult for custodians. That was really the main point that got the crypto industry's attention. The other kind of component of this is, like I said, because it was an accounting bulletin and not a formal rule, there was a lot of concern about over how the SEC decided to publish this guidance.

Casey Wagner

It seemed a little sneaky to a lot of people, the fact that they didn't do it through a formal rulemaking process. Hmm. So this was Gensler's kind of rule, or bill or bulletin or guideline. I'm not even sure the right word to describe this. That said, basically, unlike all other forms of custody, if you custody crypto assets, you have to hold them on your balance sheet as though you own them, and therefore, you have to hold capital against them as well.

Jason Yanowitz

And so that is a completely insane thing to do. So it makes it so that the likes of maybe a BNY Mellon, who's ready to turn on crypto custody and has been ready for years, hasn't actually done it, which is therefore limiting to other folks who maybe want to enter the space and don't want Coinbase to custody to their assets. They want maybe a qualified custodian to do it. There's a political element to this case. Republicans wanted to repeal it.

Tell me if I get this right. Republicans wanted to repeal it. And the big surprise was that 21 Democrats came out and joined the republican effort, breaking from the mold. Can you just explain this a little bit to us? Yeah.

Casey Wagner

So, like I said, the SEC staff passed this bulletin in 2022, which is when the conversation kind of started in Washington. There was actually, the Government Accountability Office did a review and basically said that the SEC kind of overstepped and that this guidance was inappropriate to be issued in an accounting bulletin versus a rule. The office basically said the SEC didn't do things really correctly, and it kind of was not necessarily by the book. So that's really when interest in Washington started to pick up. The joint resolution started in the House.

It was a bipartisan effort. One Democrat, Senator, Kristen Gillibrand, from New York, she signed on to that. At the time, she was the only democratic senator to support it. But eventually, the resolution worked its way through the House. It was voted on last week, and like you said, 21 Democrats actually supported it, which is more bipartisan support than they initially had as co sponsors.

And then, you know, if we remember the song of how bills become laws, once the House passed it. It went to the Senate, which is the vote that they had today. And I believe there were twelve Democrats that voted in favor. So in the Senate, we all know they only need a simple majority. We were expecting like maybe three to five democratic Democrats to support it.

So twelve is definitely a lot higher than anyone that I spoke to was expecting. They only needed two. So it definitely shows that there's a lot more bipartisan support. The next step is it goes to the White House. Biden said last week that he would veto it should it pass the Senate, which now it has.

The interesting point there, though, is if he still goes forward with the veto process and decides to kill the resolution, it would be the congressional Review act with the most bipartisan support ever that Biden has not also supported. So it'd be very overtly, Biden being. Very overtly anti crypto, essentially. Yeah, you could say it like that. It would be surprising for him to veto something with this much bipartisan support.

And again, like I said yesterday, when we were working on this story and talking to people on the Hill, they thought it was going to pass. They thought a few Democrats would get on board. But what we saw today is, like, way, way more than we were expecting. How do you read into this? Like, obviously, crypto has become very, has always been very political, but like, in this election cycle, it feels like it's become more and more important.

Santiago Roel Santos

Trump, obviously, we saw the clips from his speech in Mar a Lago. What about the first 2nd order effects here on this particular bill and play out the tape? If it were to go to that and Biden would exercise his veto, what's going on in terms of the election strategy? Do you think that's even computing in his brain? Yeah, that's his team's brain, because, you.

Casey Wagner

Know, that's a really good question. I mean, I'm inclined to think that there was some reconsideration on the Democrat side in terms of this specific resolution. So Chuck Schumer, who controls the Senate, basically he pushed the bill vote. It was supposed to be a little bit earlier. He pushed it to today, which again, in my mind, signals that they were trying to give it a little bit more time, get some more support from people that I've talked to.

The Biden administration was pretty surprised at the response to them saying that they would veto. So they issued a statement right after the House passed it saying, if the Senate passes this, we're not on board. And the response was, was pretty negative and pretty widespread. And from what I understand, that was not what the administration was expecting, no one was expecting twelve Democrats to get on board today in the Senate. So that kind of adds more to it.

It's interesting. I mean, I think a year ago, I didn't necessarily think that crypto would be a significant topic at all in the presidential election. I'm starting to think a little bit differently. I know crypto is definitely a really hot topic with some of the congressional races, and it's interesting to see how it's starting to play out in the, in the presidential race as well.

Jason Yanowitz

Do you think? What, what else are you following here, case, as you, as you speak with people in DC? Like, what are the, what are folks saying on the ground in DC right now? Just about this specific bill or. Yeah, about just like this bill and then like what, I guess, what happens next?

Yeah. Yeah. I mean, I'm really curious what the conversations with the White House are. Like, I talked to Rep. Nicol yesterday.

Casey Wagner

He supported the bill in the House. And then yesterday morning, actually, he sent a letter to Gary Gensler asking Gensler to just get rid of Saab 121. And then that would kind of, it wouldn't matter if Biden vetoed this or not because Gensler has the power to kind of like end this. And that's what Rep. Nicoll was asking him to do.

And, you know, when I spoke with him yesterday afternoon, he said that he hasn't talked to the SEC. Like, they're not responding. So it seems like there's definitely a lack of communication, from what I understand, at least, you know, I'm only hearing one side of it. The SEC frequently declines to comment, but it seems like a lot of lawmakers are trying to go to the agencies directly and that's not necessarily getting them anywhere. Which is then why you see joint resolutions.

Jason Yanowitz

Case, anything else on this? I don't think so. We'll see. The official vote count should come out tonight or tomorrow. So keep an eye on that.

Casey Wagner

And it's headed to the president's desk. We'll keep reporting on it. Cool. Appreciate you coming on, Case. Thank you.

Santiago Roel Santos

Thank you, Casey. Pretty interesting man. I mean, we had this op ed over the weekend that actually I would love to talk about. We had this op ed that Molly Jane published. So we have, so we, so blockworks has like news, and then we have the op ed section.

Jason Yanowitz

Right. Op eds, which we later learned a lot of people don't know. Op ed is like, they're opinion pieces. Right. So we published a, I had just opened up our opinion section and I now see that there's a bright red thing that just says opinion.

Santiago Roel Santos

So apparently not the views of blockworks. Yeah. Yeah. So, um. So he published this article.

Jason Yanowitz

It said only a fool would vote on crypto alone. And his sub subtitle was called was, Americans should not prioritize their own selfish financial interests over broader societal and ethical concerns. And, yeah, it was actually Leshner. Actually, both Hayden and Leshner, at dinner, they, like, he kind of showed me the phone. He's like, what is this tweet?

I was like, oh, don't know. So I don't even see a story. Mike and I both don't see stories until they're on the blockworks website, because I'm in. I'm involved in sales and sponsorships. We have a pretty strong church and state here.

And I was like, I'm not sure. Haven't seen that, but I'll read it after dinner. And then I woke up on Saturday morning with about 70 messages, just very, very angry messages, I would say, and then pulled up twitter. It's like, oh, boy, something's happening. And, yeah, sure enough, I mean, there's probably 300 or 400 quote tweets on that.

A lot of. And I think the general consensus after reading all this, myself included. Yeah, yourself included, was the. I think, actually, the content of the piece. I think the general consensus, as I could get it from, after having, really, dozens of conversations with folks over the weekend on calls and getting feedback, was the content of the piece.

People were not as upset about. It was more the tone and the. The tone and the word fool and calling people fools and calling people and the tone of being like, I know better than you. This is what you should do. Yeah, it's, like, kind of patronizing.

Yeah, I think a lot of people patronizing. Yeah, that was the tone of it. Yeah. I would actually love to hear your thoughts on it as someone who obviously likes block works. And we had dinner Friday night and stuff, but also tweeted about it, like, would love to get your thoughts on it.

Santiago Roel Santos

There's, like, opinion pieces. Like, there's, like, this really controversial. I think. I think opinion writers sometimes fall into this dynamic of they need to create stir up drama. There's Janina.

There's this opinion writer in the Financial Times, Jemima, and I've come to terms with, no matter how much you want to reason with her, reach out to her, she does not engage in discussion because her role is to create controversy and piss people off. That's just fundamentally what I think she assumes her role to be.

And I think there's a little bit of that here, primarily on the title and to your point, like the, I don't know if what went into the decision to very explicitly attack people that, I think it was just a stab at folks like Ryan Selkus and others that rallied behind Trump after he became, and he's become really pro crypto. And so, yeah, I mean, the question is, like, we always talk about, like, journalism here, what is the role of journalists? I think it's like to report, I mean, this is an opinion piece, so I get it. Yeah. I think the way you guys handle it is I don't have any problem with that.

Obviously, there's opinion pieces. People don't know what opinion pieces are. They're not the views of lockworks. They're not the views of you guys. Like, there's church and state.

That's what makes a good media organization. So I respect that. I think that is really well managed. I'm just going into the substance of the piece itself, if that makes sense. Yep.

Jason Yanowitz

Yeah, it does make sense. Yeah. I ended up talking about crypto. Crypto is very political and it is a single, like, if you've been in the industry, after all you've gone through, I mean, the amount of hostility, like, is it unreasonable to rally behind a candidate that is pro crypto? I don't think so.

Santiago Roel Santos

Are you a fool for doing that? I don't think so. Are you? I mean, obviously it does seem very patronizing to say you're wrong for voting Trump. Essentially, you're an idiot.

Jason Yanowitz

You're a fool. I understand that perspective. I don't agree with it. I think Trump is. And if you look at what his administration did, I don't think he's dumb at all.

Santiago Roel Santos

I don't vote. I'm not american. But if I were to vote, I will vote like I would vote Trump. Because if you look at what he did the last four years, it's one thing to hear him talk and he has to play to his constituent base and what they want to hear. But what actually happens under the hood, I thought was real progress for the US during his administration, and we can talk about that, but people don't want to talk about, they don't want to go into the details.

But it was real progress. Like whether you agree with how he communicates and how. Yeah, he's a polarizing character. That's fundamentally why he got elected. I think he's very anti not, doesn't represent a politician.

So he's just going to speak his mind. Why? Fine. Whatever. So, yeah, I don't know.

Like, that was not the nature of the discussion. People don't talk about it because, you know, we're in a very polarized political world, so that's fine. But I don't know. Like, let me ask you the question. You're american.

Like, you work in the industry. Like, is it not refreshing and a breath of fresh air to hear someone actually be supportive of the industry? Like, can you not empathize with people that have been feeling very stressed under the current administration say, you know what? Yeah. Single issue voter.

Does that make you a fool? I don't think so. Yeah. Yeah. I'm not.

Jason Yanowitz

I'm going to. I'm going to refrain from sharing my political thoughts too early because we're still. We still are six months out from this election, thankfully. But, yeah. Now, Mike and I had many conversations over the weekend and this week and conversations with people at blockworks.

Like, there's a decision to be made here at blockworks, right? Do you lean into this? Do you lean into politics? Because it is the conversation. It is the most important topic of the next six months.

The election has a huge impact on crypto. Do you lean in and kind of try to be at the center of that conversation and really drive the conversation forward in a responsible way? Or do you say, look, hands off, we're not touching politics, and I think we're going to lean in. I think we will know? I had a few conversations with Celcis over the weekend.

He, you know, we'll probably have a, like, I think celcus is going to publish an op ed from the other side. We'll have op eds from the middle. We'll have other op eds from. It's, it's, it's not even left and right. It's like, that's not the right way to put it.

It's, um, just different views on politics because there are, there are other conversations. I had a few calls with, uh, friends who are women in crypto who have been in crypto for several years, and they're founders and investors. And, like, you know, the way they put it to me is like, look, I'm. I'm having. I'm between a rock and a hard place right now.

Like, I'm having to choose between voting for crypto or voting for, like, protection of my body with things around abortion. Yeah. Health care and things like that. So, I mean, it's just a, it's a tricky topic, but I will, I do think that blockworks is going to try to lean into this and, like, try to drive the conversation about this forward in a responsible way, because, like, what, you know, I, like whatever happened this weekend, like, it really. It did spark this good conversation.

I think it's, well, look, that's what. Media organizations should, but somehow stop being. Becoming is this. Like, we should be openly talking about topics, but we're in a state where we've become more and more polarized as a society. The people that have strong, like, are knowledgeable, are very afraid of speak freely because of cancel culture, and because of, you know, just look at, you know, platforms like Twitter are great.

Santiago Roel Santos

Obviously, a lot of the conversation happens there, but it can be a very hostile place. Yeah, look at comments on YouTube. Like, it's not. I empathize with people that are afraid to speak their mind, and unfortunately, the people that should have the microphone don't have it. So I think if you guys can somehow become and enable people to feel comfortable to drive the conversation, have good discussion, then I think that would be progress no matter what the outcome is.

Like, you know what I mean? Like, it's not going to happen on Twitter. It can happen in a format like a podcast. It's not going to happen on national. I think podcasts are a good medium.

Jason Yanowitz

Like, I would love to on Empire, have some of these folks on and, you know, have some debates and have some conversations. Like, I was seeing the tweets. There's this one guy, it looks like he's a. I mean, his bio says dumb person, shit poster trader, but he has 200,000 followers, and he's like, very smart. This crypto news site just destroyed their business with one article.

Send block works to zero. Got, like, and a half thousand likes and 350 retweets. And I'm just like. I mean, there's no having a conversation with whoever this person is, but I do think, actually, podcasts will be a good medium for that. So, you know, there was a time where I was when I started becoming more vocal on Solana.

Santiago Roel Santos

There were some accounts that came out, and I think you sort of expect that to happen whether you talk about, you know, what the sensitive hot topics are, whether it's politics or ETH versus Solana, whatever. Tribalism. Whenever tribalism enters things and you take the other side of it. Yeah, but, you know, it's gonna. It's gonna happen.

So I actually. You go into that knowing it's gonna happen. And there was this account fishy, who was very critical and opinionated, but actually informed, and he got a lot of responses, particularly from the Solana community because he was sort of being critical of Solana and the fees and whatnot. And I actually got on the phone with him, and now when you reason with them and, you know, you actually have a private conversation, I actually think he is very well informed. He obviously has bad bias, and that's okay.

We all do. But he's. He's obviously, I. My perception was that he was a very smart, competent individual who've been around the space for a long time. He actually brought up some very valid, excellent points.

Then I used to go and, you know, talk to people in the Solana ecosystem and then think about.

And I thank him for that. And I think, you know, look, there's always this phenomenon where there's a very vocal minority. It happens in crypto community discords. It happens in politics. It happens in media organizations that are very skew in one direction, left to right.

You just sort of have to accept that there's a lot of hate online. That's fine. I mean, this is part of the nature of the game. But I don't think that should ever stop you from speaking your mind. Yeah.

Because if we are in a position where you're afraid to do it or you feel like you, I don't know, for speaking your mind in a reason informed way, you're going to be canceled or you're going to jeopardize a lot of things, then we've lost a lot. I mean, my comment to want a person out there was like, freedom of speech is also allowing people within your organization to post things you do not agree with. You know, the worst thing would have been for you to not publish that article, in my opinion, that opinion piece, in my opinion, because then, then you're not allowing for both sides of the conversation to, like, post their own opinions and what's the point? Yeah. Yeah, I agree with that.

Jason Yanowitz

I mean, we're going to keep. I mean, we'll probably publish op eds that make the other group of folks very unhappy, too. And we'll keep publishing. I mean, it's going to be. I think it'll be tricky, but I think it's a good.

I think if anyone can do it, blockworks. I've always prided us on being very non tribal. I will say so. There are some media organizations in crypto that are very tribal. And I think we've always done a good job of trying to look past the tribalism, and I think have built some pretty good credibility and reputation and trust by being able to do that and take the other side and hopefully we can try to do this with this election, which is going to be a tricky topic.

Santiago Roel Santos

But two thoughts just parting here. One, I think if there's one area of improvement, it's just the headlines. Sometimes headlines are just scandalous for the drive attention. I get it. That's the business.

Had the word fool, not if the word fool, you strike that and use another word, I think you would have gotten like a fraction of the visceral reaction. Most people don't read the contents, they just read the headline, respond to it. So, yeah, you know, everyone, you know, I don't know, more balanced choice of words probably would have been better, but maybe we wouldn't be talking about it. Particular individual wouldn't have used the word fool. So maybe it's a good thing that they use fool.

I don't know. It's like that. It's like the YouTube thumbnails, you know, Joseph is always pushing us to do like, you know, the ridiculous faces that like, you know, those kind of things. And it's like, well, would you say. We'Re in a world where you want to game the algorithm or you want to play the algorithm?

Jason Yanowitz

Would you rather have 5000 views and not do a ridiculous face or 20,000 views do a ridiculous face? It's the same content, but one of them like makes you, you're, you play. Yeah, you're falling victim to the. We purposefully don't. There are crypto podcasts that have ten times more views than ours because, you know, they, they give the audience what they want.

Santiago Roel Santos

They want price targets. Want to talk about that. Like, it's fine.

I'm not optimizing for views. I think the people that like this podcast are listening to it and I hope we're balanced. I think hopefully we're balanced. We're driving the conversation forward. I don't care if we reach a million people or a thousand people, but I think in the long term, if we keep doing this and have, we're known for being a space where we can talk freely about things and entertain multiple opinions.

If we're wrong, we go on the record of, you know, saying we're wrong and we try to bring in the most competent people, then I think that's what I'm optimizing for. I'm not optimizing perhaps, you know, being the most for like views, you know. Yeah. Next topic. Mev Doj.

Jason Yanowitz

Let me pull up this. I'm actually going to pull up the do. I'm just going to read directly from this DOJ indictment. So so, summary, to not bury the lead, the MEV. There's an MEV boost exploit for about $25 million exploit from about a year ago and the two folks who were behind that were just charged by the DOJ and face up to 20 years for the exploits.

I'm going to read directly from the DOJ indictment. Anton Bueno and James Bueno took the following steps, among others, to plan and execute the exploit. A, establishing a series of ethereum validators in a manner that concealed their identities through the use of shell companies intermediary crypto addresses, foreign exchanges, and a privacy layer network. B, deploying a series of test transactions or bait transactions designed to identify particular variables most likely to attract MeV bots that would become the victims of the exploit. Collectively, the, quote victim traders and c, identifying and exploiting a vulnerability in the MEV boost relay code that caused the relay to prematurely release the full content of a proposed block.

D, reordering the proposed block to the defendant's advantage and e, last but not least, publishing the reordered block to the Ethereum blockchain, which resulted in the theft of approximately 25 million in crypto from the victim traders. It is, um. It's pretty wild to see, uh, just that, like that. I don't know, I don't know how you feel about this, but the DOJ, like, commenting on MeV Boost and talking about relayers and, um, and honestly getting these. I don't know, I don't know how you feel about getting these people in trouble.

But I have some, I've some thoughts on it, like. So I follow this guy called Collins Belton. Collins underscore Belton on Twitter. He is usually one to, you know, have good takes. I think he said lawyers.

Santiago Roel Santos

He is a player and he, the nuance here is he's parsing through a complaint. He has a good thread. I just sent you a link. It seems to be that the nuance here is the, they faked a signature and then they, of course, like, were, after doing this, you know, meb baiting, they, you know, were googling, uh, you know, exchanges with limited Kyc, how to wash crypto. So, like that, that obviously is, uh, you know, something that they point to as like, the intent of what they were trying to do.

Jason Yanowitz

That right there, though, Santi is crazy. That they can google, that they can use. I didn't even know you could do this. Right. So what they, what they're actually saying here is, uh, they can, the prosecutors can use your Google searches for illegal, like, you Google what they were doing for, was like googling for legal advice.

Right. And they can use that as evidence against you. I honestly didn't know that they could do that. It's come up time and time again in these cases, not just in crypto. But, you know, they Google top crypto lawyers.

Like, that's, that's crazy that they can. Yeah. So, so the expert is a, for people that want to read the entire, I guess, document 0.26, it just read the point. Exploited a vulnerability in the relayer's computer code by sending the relay a false signature in lieu of a valid digital signature. Based on the research and planning prior to the exploit, the, you know, these folks, these traders knew that the information contained in the false signature could not be verified for ultimate publication to the blockchain.

Santiago Roel Santos

Instead, this false signature was designed to, and did trick the relay to prematurely release the full content of the proposed block to the defendants, including the private transaction information. Once in possession of the victim, straight or order transactions, the defendants tampered with the proposed block in the following manner. So he, when I read that Colin seems to point to this particular false signature, as would make the distinction between like a general sandwich attack and other MEV activity, meaning the false signature was key here. So it will actually be interesting how this, you know, the resolution of this case. I think that this idea of a false signature will be central and also lay a precedent into just general MeV and how it's conducted.

Because again, I don't, you know, I think when people use and talk about MeV, it's just very blunt, like blanket statement. I think there's nuance and mev. Well, the nuance here that I think that. So I think the DOJ, I was very impressed by how much the DOJ knew about like, Ethereum and Mev and realized the only thing they missed is that they. So the, the stealing the 25 million by finding an exploit in the MEV bot, the, the MEV boost relay implementation is, I think, how, how this $25 million exploit worked.

Jason Yanowitz

So what they really did, they weren't, this wasn't MeV coming from like, this wasn't an MEV bought front running retail. Right. This was me bought. This was like a creating false signature and tampering a transaction. Yeah, but this was.

They baited the MeV bots into sending the money. So this wasn't to do with retail. Right. It's like they, like the sandwich bots, like Jared from subway. Regardless of whether it's.

Santiago Roel Santos

I think the distinction of. Yeah, you're baiting an MEv bot. I get it, but I think it said differently. I don't think it would have mattered if it's baiting an MEV bot or just. Oh, I see, I see.

It's just the idea of the false signature and like, tampering with a transaction. And I'm using this terminology, transaction of content. I think that's the heart of the issue here. Now I'm going to be very. I think we should pay a lot of attention to how this gets resolved.

Just to think about generally like MeV. Right. I think the. The false signature, tampering with the transaction. I can understand why there would be like, obviously like, issues with that General Mev, you know, not so much, if that makes sense, but we should link to this.

People should go follow Collins Belt and he's always one too. Comment on these. And I personally get a lot of value into his interpretation. Yeah, we can link it. Did you follow the Alexi thing as well?

Jason Yanowitz

Was that Tornado cash? Oh, yeah, there was a. Something came out two days ago. Right? Yeah.

He was found guilty of laundering 1.2 billion. $1.2 billion. And he was sentenced to 64 months in jail. Very sad. Yeah, I think it was the Netherlands that came down on him.

Santiago Roel Santos

Yeah, it was. It was in the Netherlands. I think he was arrested in the. In Amsterdam. Yeah.

Jason Yanowitz

And then there's the roman storms case in the southern district of New York, I think, as well, coming up. So the two co founders of Tornado, right? Yeah. But then I guess I was actually reading a Collins. Collins Belton thing as well.

Like, the Netherlands is apparently extremely aggressive amongst EU members with regards to, like, KYC, AMl, and basically they're just trying to make an example of Alexei. But I mean, it's quite. It's quite sad when you think about it. He's getting five years in prison for writing code. Yeah, yeah.

Santiago Roel Santos

We'll see how the roman storm case unfolds in the US.

Jason Yanowitz

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Got any more uplifting topics for us? Santi Son exploit that just happened earlier today. This is Thursday. Initially, of course, there's a lot of drama in and confusion amongst, you know, in crypto, Twitter, but it was the hackers also, as I understand, just like tweeting is this guy stack overflow? Wait, stack overflow worked for pump.

He worked for pump fun? I believe so, yes. Yeah, yeah.

Oh, here's a lot of noise. Marginfi recently pushed out an update yesterday. Like my crude understanding of it, and I'm processing through all of it, is they leverage marginfi flash use flash loans to exploit pumped up font. It wasn't a marginfi exploit, definitely not. A margin fly exploit.

Can I read the summary from someone internal? Someone just sent this over in blockworks. They said an attacker is exploiting pump fund by buying up all the tokens. So pump dot fund, you can launch these new tokens for anyone who hasn't used it. They're buying up all the tokens of every single new project within minutes, and that fills the bonding curve to 100%.

And then they are using flash loans from Marginfi to get solar to keep buying up all the pumped up fund tokens without actually using their own soul. And by quickly bonding out the token supplies to 100%, the attacker is preventing any tokens from getting listed on the radium Dex as a tendon. So then the radium listings keep getting stuck and then what's coming out right now is that pump fund has been exploited for around 80 million via this lending vulnerability that has somehow been exploited because of what I just explained. I don't. This is.

I think we're watching this unfold in real time, but I think that's the summary. It's not small amount, say million. Yeah. Noticeably, this is a, has been a, like an attack on Solana in a long time that I can just constantly defi exploits happening. But this in my, as far as I could tell is large, but also been fairly quiet in Solana camp in terms of exploits.

Santiago Roel Santos

But this seems like large and also something that doesn't happen. Right? Literally, yeah. Okay, so Sisyphus, okay, it kind of seems like he's just flash loaning to buy a bunch of newly launched meme coins. And that's it.

Jason Yanowitz

Like, all he has are the coins. But now he actually needs to sell all the valueless tokens to someone to make money. Then Sisyphus responds. Everyone who is deploying coins is getting drained. Coin launches with initial dollars.

Flash loan happens. Coin goes to bonding with zero. Lp, loan is repaid. He's not actually making money, but I think the user money from initial deployment gets incinerated every time it happens. Got it.

Santiago Roel Santos

Okay, that makes more sense. Yeah.

Then the exploiter is launching an airdrop with these, like, funds that he's been able to get away with. Anyways, it's. We're clearly not reporting here, we're just interpreting. But it's all happening in real time. So there's a lot of fault that margin flag was exploited as far as I know.

The bull, the flash one does not process does not go through unless you can. Like, if bad debt gets created, the flash one would not go through. So margin flies is not like there's no, that 80 million is not like margin. Five is on the hook as far as, like, just an important. Yeah.

Distinction here because there's a. Most people, they're quick to just like, you know, post stuff, but create fud. But anyways, safe to say, maybe stop using popped up fun. If you have any concerns about margin fi, you know, get in touch with the team, go on discord. But, yeah, maybe not use pump fund, right.

Jason Yanowitz

All right, I'm coming in with some uplifting segment, new segment to the roundup, the YouTube comments. Every week we publish the roundup, and every week I wake up and Santi and I just get shredded in the YouTube comments. So I want to read you guys some of these comments. Oh, wait just one sec. I'm going through a tweet here.

Santiago Roel Santos

Marginfi as opposed to 52 minutes ago. So from marginfi. Marginfi is ready to help the pump font team with their exploit reminder. Operations on marginfi aren't normal. Be wary of disinformation where we help the pump team to remedy their situation.

Jason Yanowitz

Yeah, it's definitely not a margin fi hack. It's a. Yeah, yeah. Okay, moving on, moving on. YouTube comments, baby.

This is, uh, this is from the episode I did with, uh, with Arthur and Sean that you weren't able to make someone comments. So talking about me says, I thought the guy interviewing folks was an intern. Had no idea. He's a founder. Gives us all hope that anybody can start a successful company.

Thanks for the inspiration.

Santiago Roel Santos

Oh, man. We lended credence and, like, really took it. Dano's eyes keep moving closer together. He'll be a cyclops by the end of the bull run. Oh, God, I gotta go on this.

I will be lying. I mean, I always reference YouTube comments because I find them hilarious. It's great. So someone says, it's great that Sean lapel was able to join the podcast from 1998. He must be baffled by our technological advancements.

Jason Yanowitz

Jesus. Let's see. I'm gonna, I'm gonna pull the. Oh, these are so good. Our weekly roundup.

Santiago Roel Santos

The weekly roundup we did last week. Let's see the comments on this one. Where do I see comments?

Oh, this was actually good, but I won't read it because these are surprising. Two whole minutes of ads at the beginning. How much are you strapped for? Cash? Seriously, though, guys, this guy posts the.

Same comment on every pod. Santi sounds so arrogant. A lot of people always say, you sound arrogant. Do I? I don't know.

Oh, yeah. Santi sounds so organ when he says it's a lot to be a parody with ETH. With his logic, dogecoin would have overtaken bitcoin long ago. Or eos to Ethereum or BNB. Like, come on, man, we know you're smarter than this.

Jason Yanowitz

Fine.

Oh, just getting roasted out here. Just getting. That's great.

What else happened this week, dude? What about, what about GameStop? GameStop came back in his game. Is this going to be the, is this the catalyst for retail coming back in? What do you think of this?

Santiago Roel Santos

What is it that GME, like, the stock is up, like three x. It's come down a bit, but three x since roaring Kitty came back. And I think what was interesting is roaring Kitty had like a NDA, like a silence period after the movie came out or something like that. Like he was finally able to, like, be public after. Was it the Netflix stuck produce movie?

Jason Yanowitz

Yeah. Anyways, that expired. So he came back. Really weird content on his Twitter account, like just these videos and cryptic stuff. And anyways, there's also, of course, a Solana version of meme coin, GameStop, which has ripped, like orders of magnitude more than GME.

And roaring Kitty went up 15,000%. Oh, is that another meme coin? Yeah. Because his name is roaring Kitty, right. Yeah, yeah, no, no, I know that.

Santiago Roel Santos

Yeah. So the meme coins, you know, been in this choppy, like, down only trend for the last couple of months, I'd say. Yeah, it's been off their highs for quite substantial amount. Like down 40, 50, 60%, even more for others. And they.

They picked up, they caught a bid in line with, you know, GME and what was the other one, the cinema company? EMC. No, AMC. AMC. Yeah.

Jason Yanowitz

Yeah. And it's so fun to watch, like, Bloomberg and all them trying to interpret what's going on and who's buying. And granted, this is not too dissimilar from crypto. Like, if we look at GameStop is down from its high quite a. Quite a lot.

Santiago Roel Santos

I mean, it's like down 90%, I believe, or a one point was down similar to your typical crypto coin from all time high and last cycle. And so, you know, it's the same commentary that you hear from crypto folks. Like, you were hearing it on Bloomberg, like, oh, yeah. You know, you have all these people that bought the high and then you're dumping, you know, once they're, you know, this, this, this was caught a bit, but they're still heavily underwater. Like, just a reminder that very so often, because a particular token is down, only people are quick to call it a, you know, the scam, it's a worthless thing.

You know, this is not only happening in crypto, like, it happens in traditional markets too. Like, I think it's important just objectively make the distinction, be a little bit more sophisticated in your thought process. Sorry if I sound arrogant, but it's just like, because something goes down 90%, that does not necessarily make it a scam or a worthless token. It's just maybe it shouldn't have been worth, you know what I mean? Like, it's just important to.

If you truly want to find gems, you have to maybe put aside that and go deep into particular projects that you like. And if the tokens down 90% and it's trading at, like, distress value, some tokens are trading up below. What? Like the treasury holdings are like. There's just a lot of irrationality, but people are just.

They block themselves out when they see something that is down a ton. Now, I'm not suggesting GameStop is a fundamentally, like, a good company. No, it's important to the work. I'm not gonna do that for you. Sorry.

Go listen to someone else.

I don't. I don't. I don't do this to feed you, Alpha. I do this personally. All right, I got info on the.

Jason Yanowitz

On the exploit. Not really. It looks like. It's not really an exploit. It looks like in the 80 million.

I think I said this. This is an $80 million exploit in the same way that Alameda's internal balance sheet marked their maps and oxygen oxybags in the billions. Like, that's what it seems. I guess because of the bonding curve, you're valuing these tokens at a certain amount, and, like, it's really. I think this will come out as being like, just don't use pump for a little bit.

But not like a big hacker exploit. That's what it seems like. Did you just say, how did you pronounce that hacker? No, his soccer. How do you pronounce it?

Santiago Roel Santos

I think it's a silent h. Dude. No, silent like soccer. No. So, uh, it's not.

Jason Yanowitz

I don't know. Well, Daca, if you're listening to this. Please enlighten us, because most empire episodes. He told me so he will come on then. We.

I asked him, he said, no, thank you. He said, I don't do pods. Will continue serving my role as a regular listener of empire. I was like, well, we appreciate your. Your.

Santiago Roel Santos

Please enlighten us in the comments. I think it's saka, not.

Jason Yanowitz

Dba. Research day was yesterday research day. One of the best days of the year. DBA. John Charman, Michael Jordan put on a great day.

Big shout out to them. There's great talks from. We had Lee Yang from mega ETH give a talk on. It's called why ethereum sync sucks. The CTO of Jito gave a great talk on just improving Solana and potential ideas for a couple different Solana infrastructure ideas.

Stefan from Frontier gave a great talk on cake. The cake protocol. Chris goes gave a great talk on why we shouldn't call things X is money, ETH is money. And talked about breaking the crypto wheels. Just a really good research day.

It was like the event I look forward to, where you just get to sit in a chair and listen to great talks and nerd out all day and there's not really networking. There's not. No one's drinking. Like, it's just a great day. Yeah, that's good.

Santiago Roel Santos

Yeah, I was gonna go to that. I just had to come back, and I was there. I mean, I think I was with John, actually, in the Solana event. It was just him and him and I just having, like, an open conversation, just, like, with a lot of the teams that are in New York, like, with getting mentorship and guidance. And so it was just a real treat.

Jason Yanowitz

Yeah. I met Lily, also from Solana foundation, to dinner, just was chatting with her. And AK, who runs Solana or led Solana growth international, especially in Asia. And so, yeah, it's really, really exciting. What I found to be most interesting, or one of the things that I find most interesting generally, about the Solana community, is that they're very open to listening to feedback.

Santiago Roel Santos

And I think it starts from the very top. Like, Toli is someone that, you know, is very open to hearing criticism. And they've even optimized feed markets based on criticism from a lot of the, you know, ethereum folks. I think that's one of their edges, just always being open and open to criticism and very interested in, you know, especially maybe as someone like me, who is not, like, there, you know, has become more interested in Solana over time. But I look at other stuff, so, yeah, it's always really nice to interact with people within the Solana community and team.

Speaking of Solana, there was an interesting stat on May 12. So four days ago, Solana generated more what is called total economic value block. Work term, baby. We're quite. We're pushing that term.

How did you steal my thunder? I was gonna say, I mean, link Dan Smith, you know, Blackberg's research. Thank you, Dan. I retweeted this, and, yeah, it's quite interesting. I think this goes back to, and for context, the total economic value that you're linking it here.

People that are not watching is defined as transaction fees plus MEP. And people should go listen to the episode that we recorded with Kyle to talk about this point. But I think this is something. This chart is probably one of the most important to watch going forward. And, yeah, a big part of my Solana thesis.

Jason Yanowitz

Yeah, it's interesting. Total economic value. We are spending a lot of time thinking about how to value these l one s and l two s and protocols and total economic value. Well, it's not maybe the cleanest term. It's.

We're trying to think of different ways to value. It's very straightforward. I mean, it's easy to understand. Yeah, we announced some new. I was just recording a podcast, and I was just recording.

Santiago Roel Santos

Sorry. I was just recording a podcast in Spanish. And we, like, people are catching on to the idea that, like, what? I said, flex on people. Oh, people.

Yeah, people are.

It's not. It's just like, these guys that have been encrypted for a long time, I think they're the most. They're one of the most popular in Latin America. Anyways, this guy, they're this concept that, like, the two revenue streams of block based blockchains are not only transaction fees, but maybe he's catching on. And I think it's just interesting that the market, or market participants are in the community in general, is understanding that.

Jason Yanowitz

So the biggest pushback that we got to this post was that Dan's post, which went pretty viral, was that we didn't include l two s. And I'm curious what you think of this. Should we include l two s in this or not?

Santiago Roel Santos

I can think of reasons why you should and why you shouldn't. So I don't know. Because. Okay. It depends.

Right. And again, I'm thinking of the episode that we had with. What's his name? Steven. Yeah.

From arbitram. We were talking about. Like, it's always been the cell two s. Are l two s parasitic to the l one? Like, they're posting to the l one?

So some value does accrue to the l one, but, like, in the proportion, how much value captured are you not double counting if you're using the l two? If you're. If you're including the l two as part of the l one? Two separate assets. Right?

They all have their native token r op, except base. But the sequencer is capturing a lot of that value. Right? Like, when you think about the values being created in l two, the sequencer is creating a lot of. A lot of that's like mev, but that's not being distributed back to the l one.

So if you're an ETH holder, you're not directly benefiting from that. The only thing that you're benefiting from is the l two posting to the l one. And that would show up. That would already show up in this. In this measure, right?

In this metric. Through transaction fees. No. Or even marginally it may be, but mostly transaction fees.

I'm thinking, like, if you include l two s, aren't you, like, in some. Way here, Dan did the work. Dan did it. There was a lot of pushback that this chart doesn't include ETH l two s. I do not think it should and have my reasoning in the tweet below.

Jason Yanowitz

If you count the transaction fees on May 12. Anyways, it edges ethereum ahead, but shows just how close the two. Yeah. Truly are. But it's only transaction fees.

Santiago Roel Santos

What I'm saying, they're marginal, right? Oh yeah, that's a whole point of like more and more, especially with like the modular movement. Like more and more, you have more l two s, you have a lot of economic activity. But like the, the amount of fees that are flowing back to the l one are very, very small as a percentage of the total economic value is created in l two. And what trickles down to an l one, it's a fraction of that.

So yeah, I think you should count it like that. But it's a small number is what I'm trying to say. Right. Yeah, I mean, the argument, again, there's another argument against counting it, which is what we talked about with Stephen too, which is like, look, a lot of these things like optimism doesn't have fraud proofs and is governed by multisig. They don't inherit any of the security from ethereum at all, is my understanding.

Jason Yanowitz

And someone should correct me if I'm wrong there because I feel like I sometimes talk out of my ass with this stuff. But like, if you don't have a decentralized sequencer, you don't have the bridge, an immutable bridge contract. And it was actually shout out westy at Blockworks research was talking about this too. Like immutable bridge contract, decentralized sequencer, and a permissionless proof system. Like why would you include them?

Santiago Roel Santos

However you're counting, my point is, however you're counting transaction fees and MevNdl one should encompass all the activity that it's flowing into. The l one should by default include whatever is happening the l two and is posting an accruing value to the old one. But it's just counting economic activity in the old two. No, I don't think so, because it doesn't. The analogy would be Salesforce.

So think about Salesforce, Salesforce, CRM. Like you're an equity holder in Salesforce. It has an ecosystem of apps that benefit from the, you know, the ecosystem of Salesforce, all the clientele that may tap into the App Store. But like you have all these companies independent of Salesforce that are creating businesses in and of themselves. Now Salesforce, like Apple might take a cut from that, but that's going to show up in their p and L, that's going to show up in their commission fees or whatever.

They take some cut of the App Store revenue in the same way here. You should be including that, like marginal 310k or whatever that Westy didn't include originally, but you should include it because it's a stream of income to the Ethereum. If you were to do a p and l on Ethereum, you would include it as l two posting fees include that. But it's really small. The vast majority of the value that's created in these base layers, like Solana Ethereum is Mebane, right?

Jason Yanowitz

Yeah.

Santiago Roel Santos

Which is like one of the. More like you remember, like, in a state where, like, there was a very contentious and price still is some debate around, you know, l two s. And, yeah, of course they bring a lot of scalability to Ethereum, but there was some discussion on, are they actually parasitic? Are they not? How much validity is actually going to flow down to ETH?

And if you're an ETH holder, right, if you think about, you know, EFP 1559 and the burn, you know, if. If a lot of that values created an l two, an l three, and l ten, but not accruing down to the l one, then it makes, again, the argument of, well, shouldn't you be perhaps thinking of maybe I should be owning an l two token, not an l one?

Because if, like, in the state where, like, with arbitrary stylus, for instance. And again, that the. The podcast with Stephen is really, really instructive, I think he's one of the smartest people out there, and he, I think, lasers it out very clearly. There might. When we talk about up threes, you know, if people are using our stylus and, like, are using the gen or op, right?

Like they had, you know, base is using op in the game. You know, there's, like, some. There's some, like, fee that the arbitrum as an ecosystem is accruing. If you have more apps there, if you have people that are using that stack to build on top of arbitrum, that makes you bullish. Like, arbitrum is an ecosystem, marginally ethereum, more so arbitrum, if you know what I mean.

Jason Yanowitz

Yep. Does that make sense? Yeah, it does make sense. Yeah. Yeah.

Santiago Roel Santos

Okay. Yeah.

Jason Yanowitz

Sweet. I have a call. Five minutes. I need to. Yeah, this is good.

Santiago Roel Santos

Well, stay safe out there, everyone. Important that when you see this, when there's smoke, there's fire. So if you have any doubts, just play it safe. And it seems like margin fire is okay. Pump.

Just give it a break. Just pump the brakes and pump that. Fun. While I say that as an investor, pump that. So hopefully everyone is okay and this disclosure, what is saying.

So anyways, we'll be reporting that next week and just hopefully more clarity there. Yeah, we got some new permissionless speakers, too. We got Devon fincer, CEO of Opensea. Spencer Bogart, GP of blockchain. Cap Tushar from multicoin.

Jason Yanowitz

Harry the CP of arbitrum. Uma Hart Lambert. Uma Roy from succinct labs. I was with heart actually, yesterday. Nice.

Eva from Graph foundation. Jake Trevinsky Bayek from Hashed. Oh, yeah, that's great. Oh, man. Nick Dodson, CEO of Fuel.

Frederic, the co founder of Gnosis. So good people. Go register. Amazing. Fun.

Santiago Roel Santos

So speaking of, I'm actually like, I'm going to. I'll make a quick trip. There's a part of what I did with salon I'm going to do now with another ecosystem that's actually an l two. And I'm really excited. They're in Berlin, so.

Yeah, this reminds me, like, early Ethereum days, like Berlin used to be. This, like, very web three. We're. We're cooking something for Berlin. Oh, really?

Jason Yanowitz

Yeah. I can't share. Yeah, you're coming in closer here. That's great. Yeah, yeah.

More Europe stuff. So that's a good place to end before I share too much. Thanks for listening, folks. We'll see you Tuesday. Awesome, folks.

Santiago Roel Santos

Don't forget to post on YouTube, please.

Jason Yanowitz

All right. You heard about say a couple times. Just want to give them one last shout out. Big thanks to say for sponsoring this episode of Empire. There are a ton of reasons to build on.

Say, if you want to get in touch with them, you can reach out to me. I'll put you in touch directly with the team. You can also get in touch with them on Twitter, a network. You can follow the journey at say network. They are currently, currently live.

They've got save e two on public Devnet today. Mainnet goes live later in Q two. Really excited to have Sae sponsoring and partnering with us on this episode of Empire.