It doesn't matter whether it is a "currency" or not. > The test is whether the scheme involves an investment of money in a common enterprise with profits to co

It doesn't matter whether it is a "currency" or not. > The test is whether the scheme involves an investment of money in a common enterprise with profits to come solely from the efforts of others. If that test be satisfied, it is immaterial whether the enterprise is speculative or non-speculative or whether there is a sale of property with or without intrinsic value. [0] Thus if the ICO's are sold with the expectation that profiting from the purchase of those token depends entirely on Telegram completing work on their network and integrating that network with their app, then the Howey test seems to apply. Telegram currently restricts the sale of the coin (via contracts) and heavily marketed the value coming from "200 millions of Telegram users will get a TON wallet making it the world’s most adopted cryptocurrency". I don't really see how you could see this a not being a security under the Howey test. [0] https://en.wikipedia.org/wiki/SEC_v._W._J._Howey_Co https://en.wikipedia.org/wiki/SEC_v._W._J._Howey_Co.