Yea the SEC administrative order includes quite an Orwellian redefinition of "sale", that attempts to expand its scope far beyond what people commonly understan

Yea the SEC administrative order includes quite an Orwellian redefinition of "sale", that attempts to expand its scope far beyond what people commonly understand the word to mean: >Rather, a “gift” of a security is a “sale” within the meaning of the Securities Act when the donor receives some real benefit. and >Tomahawk received value in exchange for the bounty distributions, in the form of online marketing including the promotion of the ICO on blogs and other online forums. Tomahawk also received value in the creation of a public trading market for its securities. See Sierra Brokerage, 608 F. Supp. 2d at 940 (“where a ‘gift’ disperses corporate ownership and thereby helps to create a public trading market it is treated as a sale”). The latter, "Tomahawk also received value in the creation of a public trading market for its securities", justification, is alarming. It appears the SEC's definition of a sale is any issuance that benefits the issuer by any means, which is inconsistent with what 'sale' means in standard English, which is an exchange of a good/service for money. The SEC is going beyond just defining a barter exchange (the "bounty" provided in exchange for promotional services rendered) a sales transaction, to considering even none-exchanges as sales transactions. By the SEC's unbound definition, a charitable issuance of securities that brings goodwill and thus value to a brand would be a sale.