Disclosure on determining the legality of POX in Hong Kong and China jurisdictions. 

---------- Forwarded message ---------
From: Gunnar Larson <g@xny.io>
Date: Fri, Feb 11, 2022 at 2:08 PM
Subject: Regulations on the Administration of Network Data Security (Draft for Comment)
To: <shujuju@cac.gov.cn>


Dear Sir or Madam:

We seek clarification to the recent notice of the Cyberspace Administration of China on Public Comments on the Regulations on the Administration of Network Data Security (Draft for Comment).

The Cyberspace Administration of China (and Hong Kong) issued new guidance on third-party products and services that cause damage to users. According to the Cyberspace Administration’s guidance, users can request Internet platform operators to pay compensation in advance for data violations. 

Hong Kong is the data hub for Stacks (STX), where internet platform operators shall assume data security management responsibilities for third-party products and services connected to their platforms. Hong Kong mandates clarity of data security responsibilities for third parties through contracts and other forms, and urges third parties to strengthen data security management, and adopt the necessary data security protection measures.

  • Stacks’ strong third-party presence in Hong Kong extends to China. One of Stacks’ board members has served as a leader of a Shanghai based incubator. 
  • The looming question is if Proof of Transfer (PoX) Stacks’ extension to Proof of Burn (PoB), where miners compete by ‘burning’ (destroying) a Proof of Work (PoW) from an established blockchain, is allegedly illegal in Hong Kong, under the Cyberspace Administration’s new guidance. 

PoX, when used for participation rewards (Such as with MIA Coin, NYCCoin and STX), could lead to miner consolidation. Because miners that also participate as holders could gain an advantage over miners who do not participate as holders, miners would be strongly incentivized to buy the new cryptocurrency and use it to crowd out other miners. In an extreme case, this consolidation could lead to a centralization of mining, which would undermine the decentralization goals of the public blockchain. 

China, along with Hong Kong, has outlawed various forms of threats to international peace and security.

We seek the Cyberspace Administration of China's guidance if the Proof of Transfer is a legal or legal consensus software algorithm in China and Hong Kong?

Sending you the very best regards. 

Thank you, 

Gunnar Laron 
--
Gunnar Larson - xNY.io | Bank.org
MSc - Digital Currency 
MBA - Entrepreneurship and Innovation (ip)

G@xNY.io
+1-646-454-9107
New York, New York 10001