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SEC No-Action Letter for DoubleZero: A Breakthrough for Utility Tokens and Meme Projects?

SEC No-Action Letter for DoubleZero: A Breakthrough for Utility Tokens and Meme Projects?

Hey folks, if you're deep into the crypto world, especially meme tokens, you've probably caught wind of some exciting news buzzing on X (formerly Twitter). Ariel Givner, a fintech attorney and legal mind behind projects like MonkeDAO, dropped a bombshell thread about a no-action letter from the SEC regarding DoubleZero. This could be a game-changer, not just for serious infrastructure plays but also for meme tokens looking to add some real-world punch.

SEC No-Action Letter Header for DoubleZero

What's DoubleZero All About?

First off, let's break down DoubleZero for those who might not be familiar. DoubleZero is a DePIN project— that's Decentralized Physical Infrastructure Network, in simple terms. It's like building a global, high-speed fiber network but in a decentralized way, powered by blockchain tech. The goal? To supercharge communication in distributed systems, slashing latency and boosting bandwidth for things like blockchains on Solana, Aptos, and Avalanche.

Their native token, 2Z, isn't just some speculative asset. It's a utility token that rewards network contributors—like validators or node operators—based on the traffic they handle. Think of it as getting paid for providing the pipes that keep data flowing smoothly. You can check out more on their site here.

This setup is key because it positions 2Z as a functional incentive, not an investment vehicle promising profits from someone else's efforts.

The SEC's No-Action Letter: What Happened?

In the thread, Givner shares a screenshot of the SEC's response from the Division of Corporation Finance, dated September 29, 2025. The letter references an incoming request from DoubleZero dated September 25, and basically says: "Based on the facts you've presented, we won't recommend enforcement action if you proceed, relying on your counsel's opinion that these tokens aren't securities."

You can read the full no-action letter on the SEC's website here.

But why is this big? SEC Commissioner Hester Peirce chimed in with a statement praising the move. She explains that DePIN projects like DoubleZero use tokens as rewards for actual work—providing bandwidth, storage, or other services—rather than as shares in a company or bets on future profits. This doesn't trigger the famous Howey Test, which is how the SEC determines if something's a security.

Peirce argues that forcing these into securities regs could stifle innovation. Instead, markets should decide if these projects fly. Her full statement is a must-read for anyone tracking crypto regs here.

Givner calls it out in his post: "The SEC is finally acknowledging that tokens serving real infrastructure purposes aren’t securities. Five years of SEC overreach… finally we’re making progress." He even shouts out the team, including @RSSH273, for pulling this off.

Implications for Meme Tokens

Now, here's where it gets juicy for the meme token crowd. Meme tokens often start as fun, community-driven jokes—think Dogecoin or Shiba Inu—but many face regulatory heat because they look like unregistered securities to the SEC. The big question is always: Is there an expectation of profit from the efforts of others?

DoubleZero's win shows a path forward. If a token has genuine utility—like powering a network, rewarding contributions, or enabling real-world services—it might not get slapped with securities labels. For meme projects, this means evolving beyond pure hype. Imagine a meme token that integrates DePIN elements, like rewarding holders for running nodes or contributing to a decentralized app. Suddenly, it's not just a meme; it's infrastructure with a fun twist.

This isn't the first time we've seen hints of change. The SEC's lighter touch this year—only nine enforcement actions so far versus 47 in 2023—suggests a thaw. As Axios reports, this no-action letter could encourage more crypto startups to engage directly with regulators for clarity read more.

Of course, it's not a free pass. The letter is specific to DoubleZero's facts, so other projects need to tailor their approaches. But it's proof that U.S.-based innovation can thrive without fleeing offshore.

Wrapping It Up

Givner's thread has racked up thousands of views, likes, and replies, with the crypto community buzzing about what this means for the future. If you're building or investing in meme tokens, keep an eye on how projects like DoubleZero pave the way. Adding real utility could be the key to dodging regulatory pitfalls and unlocking massive growth.

What do you think—will this spark a wave of "utility memes"? Drop your thoughts in the comments, and stay tuned to Meme Insider for more updates on the wild world of meme tokens and blockchain tech.

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