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Interesting. The legal analysis sounds accurate, but who needs to push the boundaries in this environment?
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Yep, and storing any valuable data creates an incentive for someone to hack in to get it so it's best to avoid it.
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Yes. No brainer.
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I talked to another founder whose lawyers said it is non-custodial - legally at least. I think because you can unilaterally revoke their ability to spend on your behalf, and it's permissions to spend but you don't hold the money. Still, it's a honeypot. It's like storing credit card info.