Fwd: Regulations on the Administration of Network Data Security (Draft for Comment)

[Gunnar Larson]

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

---------- Forwarded message ---------
From: Gunnar Larson <g at 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 at 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 <http://www.cac.gov.cn/2021-11/14/c_1638501991577898.htm>
(Draft for Comment).

The Cyberspace Administration of China
<http://www.cac.gov.cn/2021-11/14/c_1638501991577898.htm> (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
<https://drive.google.com/file/d/1wL2kN6aMfsyT-T7g01YJSBB8meMn2SWg/view?usp=sharing>
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 <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-innovation-mba-1-5-years-or-3-semesters/>
- Entrepreneurship and Innovation (ip)

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