Great read, gentlemen David Sacks, Josh Stein.

In our conversations as per Anshuman, for the Reg. D points:

  • Correct, no public re-sales most likely.
  • Posting an offer may surely, potentially, count as solicitation.
  • Definitely.

For Rule 144:

  • Yes.
  • Yes — investors will have more skin-in-game.
  • Ease of paperwork…definitely an issue.

International — Reg. S — offerings will be thorny… to ensure no marketing to US investors, as Anshuman points out.

Plenty of work to be done on this — looking forward as well to collaborating.

Economist, Ocean Lifeguard, Founder of Austere Capital Advisory (

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