USDP, BUSD - New York False Claims Act

---------- Forwarded message --------- From: Gunnar Larson Date: Fri, Apr 29, 2022, 6:47 PM Subject: USDP, BUSD - New York False Claims Act To: Weber, Richard (DFS) Dear Mr. Weber: How are you? I hope this message finds you well. Evaluating USDP and BUSD market confusion specific to the New York False Claims Act https://drive.google.com/file/d/1OhmuOfMTb4YfK6kzZ8S8Pl8d6urlB4Db/view?usp=s..., can you kindly advise if USDP and/or BUSD preclude the New York False Claims Act under NY-DFS regulation? - Specifically, has the state or local government has reached a binding settlement or other agreement with USDP and/or BUSD who potentially have violated section one hundred eighty-nine of New York's False Claims Act, resolving the matter and such agreement has been approved in writing by the attorney general, or by the applicable local government attorney (aka your office)? - According to Paxos https://paxos.com/2022/04/07/busd-issued-by-paxos-on-ethereum-vs-busd-on-the..., NYDFS agreed to the terms of the token in advance of issuing – this includes the stipulation that USDP and BUSD only be issued by Paxos on the ethereum blockchain at this time. - Paxos' marketing partner for BUSD – Binance – issues a token on its BNB smart chain called Binance-Peg BUSD. Note that Binance-Peg BUSD is strictly a Binance product; it is not issued by Paxos nor regulated by the NYDFS. Paxos holds a Primary Purpose Exemption of 25% https://drive.google.com/file/d/1Yp6wx5EefmR_bGNJOPE_0mGlzSUMLaek/view?usp=s.... As such, USDP and BUSD 1:1 reserves are potentially misleading and could fall under New York's False Claims Act, unless barred by NY-DFS. For example, a case brought by the New York Attorney General indicated that the reserves for the stablecoin Tether (USDT) were not 100% fiat-backed. This discovery was in direct contradiction to previous statements made by Tether. Mr. Weber, the marketplace confusion specific to USDP and BUSD is similar in nature to Meta and the Moscow Exchange digital asset delima. Given Meta's relationship with USDP, we wanted to learn of any NY-DFS administrative actions concerning USDP and/or BUSD that would exempt Paxos from New York's False Claims Act. Sending you the very best regards. Gunnar Larson ---------- Forwarded message --------- From: Gunnar Larson Date: Fri, Apr 29, 2022 at 12:34 PM Subject: Re: Meta Platforms, Inc. Board of Directors - USPTO, Digital Assets and Moscow Exchange To: Chollet, Nicki Cc: Meta_Defensive_Disputes , cypherpunks , , Alexi Anania Ms. Chollet: We have yet to hear back from our office concerning xNY.io - Bank.org's prerogative to protect digital asset innovation. Meta's board of directors may understand today's memo seeking clarification of intent concerning the Novi and USDP relationship. Novi and the Novi logo are trademarks owned by Facebook, Inc. *On October 19, 2021 https://www.novi.com/news/pilot-version-of-novi-now-available/ Meta's Novi digital asset project announced a pilot engaging the USDP stablecoin: * - "For the pilot we are enabling people to send and receive money using USDP (Pax Dollar) through a partnership with Paxos and Coinbase. Our support for Diem has not changed. We see great value in the way Diem is designed with robust protections for consumers and controls to combat financial crime. We intend to migrate Novi to the Diem network once it receives regulatory approval. The goal for Novi has been and always will be to be interoperable with other digital wallets and we believe a purpose-built blockchain for payments, like Diem, is critical to deliver solutions to the problems that people experience with the current payment system. Imagine if you couldn’t send an email from a Gmail address to a Yahoo address, or if you could only text people with the same mobile provider as you." - "We chose USDP for the pilot so that we can test our systems with a stablecoin that has been operating successfully for over three years and that has important regulatory and consumer protection attributes. This means that people can easily withdraw their money in their local currency when they choose. USDP reserves are fully backed by the US dollar and are held 100% in cash and cash equivalents. We chose Coinbase, which manages $180B assets on its platform, to provide custody solutions for the secure storage of our customers’ funds." Ms. Chollett, as of today USDP shows a value of $0.00 on Coinbase https://www.coinbase.com/price/usdp, and appears to no longer be supported by the Coinbase platform. Can Meta's board of directors clarify their current relationship with USDP? On April 7, 2022 https://paxos.com/2022/04/07/busd-issued-by-paxos-on-ethereum-vs-busd-on-the... USDP was re-announced in New York in partnership with BUSD. How should the marketplace interpret the intent of Meta's board of directors concerning USDP and BUSD? Sending you the very best regards. Thank you, Gunnar Larson -- *Gunnar Larson - xNY.io http://www.xny.io/ | Bank.org http://bank.org/* MSc https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&utm_medium=Search&utm_campaign=MSc-Digital-Currency-North-America&utm_term=blockchain%20unic&gclid=Cj0KCQiAyJOBBhDCARIsAJG2h5ctwwMz0MRbVSk-LaYD-GMU5UgDSw7ynxbGr_a7SkaFAZzJc1-pzxEaAi4NEALw_wcB - Digital Currency MBA https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovati... - Entrepreneurship and Innovation (ip) G@xNY.io +1-646-454-9107 New York, New York 10001 On Wed, Apr 13, 2022 at 4:44 PM Gunnar Larson wrote:

Ms. Chollett:

Thank you, kindly, for continued correspondence related to Meta Board questions specific to xNY.io - Bank.org, PBC's concern to protecting cross-border digital asset innovation.

xNY.io - Bank.org, PBC first became alarmed through Meta's obvious digital asset market problems related to Libra, Diem, Novi and USDP. Through Meta's continued digital identity transitions, xNY.io - Bank.org, PBC has pioneered cross-border digital asset logic(s). Moreover, the Moscow Exchange and Meta introduced market events over March that jeopardize digital asset market purty. Ms, Chollett, xNY.io - Bank.org, PBC will not pay for market effects related to Meta's cross-border disruption of digital asset innovation, related to Meta's obvious mark exactness (by definition) to the Moscow Exchange.

*Ms. Chollett, we cannot concern ourselves with Meta's intentions, good or otherwise, given clear problems that exacerbate market risk: *

- March 11, 2022 https://www.businessinsider.in/tech/news/russia-moves-to-declare-meta-an-ext...: Russia's leader, who is in charge of the Moscow Exchange cites Meta as an 'extremist organization' ... - March 14, 2022 https://www.lexology.com/library/detail.aspx?g=ff9f1af5-cc8a-473a-822b-8890c...: Frankfurt Kurnit Klein & Selz PC Benjamin G. Murray published SDNY insights to a Russian State-Sponsored TV Network's Attempt to Dismiss Copyright Lawsuit On Fair Use Grounds Denied. - March 17, 2022 https://www.sberbank.com/news-and-media/press-releases/article?newsID=cd44dd90-1dcf-4bb1-ab20-bc99e52d08a3&blockID=7®ionID=77&lang=en&type=NEWS: Moscow Exchange is the backend to Russia's largest bank, Sber. The announcement on 03/17/22 confirmed Sber (via the Moscow Exchange technology, at various levels) would issue digital assets. - March 18, 2022 https://cointelegraph.com/news/meta-files-8-digital-asset-and-web-3-0-tradem...: Meta Platforms Inc. filed USPTO mark applications for a mark EXACTLY DEFINED to that of the Moscow Exchange. - Ms. Chollette, below my signature you will find Meta's filing numbers and descriptions related to a mark defined as Moscow Exchange, with plans to engage the mark in commerce related to digital assets and virtual reality. - March 24, 2022 https://docs.google.com/document/d/1f_fq1GaKNaAUGEyztdm-oMtIuEW2yXj4C5aoN0GA...: xNY.io - Bank.org, PBC contacted meta, with a memo introducing our direct plan to protect cross-border digital asset innovation. Ms. Chollette, please note that Russia has labeled Meta as an 'extremist organization' ... So who really knows what the Moscow Exchange will thi

xNY.io - Bank.org, PBC is a very reasonable digital asset pioneer, and sitting in Manhattan the jury is in on market contributions from Libra, Diem, Novi and USDP. Ms, Chollette, Meta and the Moscow Exchange matter really suggest only losing marketplace contributions, obviously potentially devastating digital asset marketplace innovation(s). We aim to solve this problem immediately:

1. Ms. Collette, xNY.io - Bank.org, PBC recently shared Citigroup's Metaverse and Money https://drive.google.com/file/d/1REoa87GCmt2uhDp7ZYswbTRw4ygQgjsL/view?usp=s... whitepaper, with 33 highlights to our grave concern to Meta's potential marketplace delinquency related to Meta's mark exactness to Moscow Exchange. 2. Furthermore, Mr. Zuckerberg and Mr. Putin are both highlight quotes to Citigroup's Metaverse and Money research. 3. With the date order, footnotes, and highlights xNY.io -Bank.org, PBC kindly petitions Meta's board to understand the opportunity ... The Moscow Exchange is not our problem, and for whatever reason Meta will have no opportunity to make mark exactness our problem.

The United State of America's cross-border approach to digital asset innovation will be cultivated, fostered and protected by xNY.io - Bank.org, PBC. We aim not to be adversarial with Meta, but we will stop at no cost to invest in claim rewards if necessary. Perhaps, we can organize a time to discuss potential resolutions in the immediate term.

xNY.io - Bank.org, PBC must reserve all rights specific to harm from March 14, 2022 https://www.lexology.com/library/detail.aspx?g=ff9f1af5-cc8a-473a-822b-8890c... and March 18, 2022 https://cointelegraph.com/news/meta-files-8-digital-asset-and-web-3-0-tradem... market events.

Please feel free to call or email anytime.

Sending you the very best from New York City,

Gunnar Larson -- *Gunnar Larson - xNY.io http://www.xNY.io | Bank.org http://Bank.org* MSc https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&utm_medium=Search&utm_campaign=MSc-Digital-Currency-North-America&utm_term=blockchain%20unic&gclid=Cj0KCQiAyJOBBhDCARIsAJG2h5ctwwMz0MRbVSk-LaYD-GMU5UgDSw7ynxbGr_a7SkaFAZzJc1-pzxEaAi4NEALw_wcB - Digital Currency MBA https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovati... - Entrepreneurship and Innovation (ip)

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

97320155: Online social networking and dating services, including a specific branch tailored for networking between cryptocurrency investors.

97320153: Design and development of computer hardware and software relating to Web3, including gaming, e-commerce, blockchain transactions, etc.

97320149: Entertainment and electronic publishing services, partly within virtual reality.

97320147: Telecommunication services for electronic assets held on its platform.

97320146: Financial transaction processing services relating to tokens, blockchain assets, cryptocurrencies and other virtual assets.

97320144: Advertising services via virtual or augmented reality networks and the metaverse.

97320140: Wearable peripherals for video games connected to virtual reality.

97320136: Downloadable software in the nature of a mobile application, such as for user authentication, online charitable fundraising and most notably, for hardware or e-wallets.