The exchange
What you give, what you get.
An equal exchange of value means both sides can state exactly what they received. Here is ours, in four steps, with nothing implied in the gaps.
You buy a quantity of mining capacity
A hash-power purchase is denominated in megahashes per second — a defined amount of real ASIC capacity, priced like any other unit of capacity. It is not a share, a note, a stake, or any claim on our company or its results.
That capacity joins the pool and does the work
Machines are bought, racked and pointed at the chain. Your MH/s is live capacity in a physical facility you can visit, contributing computational resources to a public network you can audit. Buy enough of it and you can take an ASIC home and run it yourself — over 200 units have shipped.
The protocol pays what the protocol pays
Your daily coins are your hash divided by total pool hash, times what the network actually issued that day. We don't set that number, we don't guarantee it, and we never project it.
We're the pool operator, nothing more
Buying the machines, paying the power, keeping the software patched, defending against attacks and making sure every miner gets paid. Federal guidance calls that administrative and ministerial work — the opposite of the managerial effort that turns a purchase into an investment contract.
The Howey test
How this fails Howey — prong by prong.
SEC v. W.J. Howey Co. (1946) asks four questions. An arrangement is an investment contract only if the answer to all four is yes. Ours answers yes to one.
1. An outlay of money
Arguably yesMoney changes hands. We don't pretend otherwise — every honest commercial purchase clears this prong, from a tractor to a truckload of lumber. On its own it means nothing.
2. In a common enterprise
NoYour hash is your hash. There is no pooling of your fortunes with other buyers, no shared profit-and-loss, and no claim of any kind on mineHME's business results. Two people with identical hash get identical output regardless of what anyone else in the community does or fails to do.
3. A reasonable expectation of profit
NoWhat's delivered is coin produced by the capacity you paid for — output of a productive asset, like crops from land or ore from a claim. It can be worth far more or far less than you spent. We guarantee nothing, we publish no projections, no return targets and no earnings claims, and we say plainly on the signup page that this is not an investment and is highly speculative. What you later do with your coin is your business and is not part of any agreement with us.
4. Derived from the efforts of others
NoThe decisive prong, and the one that fails hardest. You are the miner: your computational resources validate transactions and the protocol pays you for it. Output is set by protocol issuance and network difficulty — mathematics, not management. We can't increase your coins by being clever, and we can't diminish them by being lazy. There is no promoter whose entrepreneurial effort your result depends upon.
The short version
Three of four prongs fail, and the one that matters most fails most clearly: your result comes from protocol mathematics, not from our entrepreneurial effort.
And why they'll never understand it
The category error at the heart of every objection.
Modern finance has spent a century learning to see every transaction as a claim on someone else's performance. Stocks, bonds, funds, notes, swaps — in each case you hand money to an operator and hope they perform. That lens is so dominant that when something genuinely different appears, it gets forced into the same frame.
Direct ownership of productive property doesn't fit that frame. A farmer who buys land isn't investing in the seed company. A machinist who buys a lathe isn't a limited partner in the tool maker. They bought a productive thing and they keep what it produces. Hash power is the digital version of exactly that, and it predates the securities framework by every century of property law behind it.
So the objection isn't really legal — it's imaginative. If your only model of “money in, more money out later” is a managed investment, then a self-executing protocol paying a property owner directly looks like magic or fraud. It's neither. It's a machine, some electricity, and arithmetic published in advance.
We're comfortable with the disagreement. We publish the receipts, we deliver the capacity, we make no promises about price, and we let the ledger settle every argument that follows.
“It pays daily, so it must be yield.”
A vending machine pays daily too. Frequency of delivery says nothing about the legal character of what's delivered — mining output arrives daily because blocks arrive daily.
“There's a commission structure, so it's a scheme.”
Sales compensation is how products get distributed. Commissions are paid out of the sale of capacity, not out of later buyers' money, and they don't alter what the buyer receives.
“You operate the machines, so it's your effort.”
Operating a facility is a service, like a self-storage unit or a boarding stable. Custodial maintenance is not the entrepreneurial effort Howey contemplates, and it doesn't determine your output.
“Coins have a price, so buyers are speculating.”
Every commodity has a price. Wheat farmers aren't securities issuers because wheat trades. Volatility in the produced good is a market fact, not a contractual promise from us.
Plain-language disclosure
What we will never tell you.
- That your coins will be worth more than you paid
- That daily output is fixed, guaranteed, or protected
- That anyone should expect income from participation
- That this is an investment product, a fund, or a security
- That there is no risk — mining is genuinely risky
Rewards diminish as total mine hash grows, difficulty rises over time, coin prices move in both directions, and hardware fails. Read the risk statement and the terms before you buy anything. Nothing on this page is legal, tax or investment advice.
Check the exchange yourself.
Every dollar in, every coin out, every transaction id — published daily.