BSV USA Association: Antitrust Policy

1Why we have this policy

The BSV USA Association (in formation) is a trade association. We plan to organize as a nonprofit under section 501(c)(6) of the Internal Revenue Code. Our members will include holders, builders, businesses, miners, and people who work for exchanges, custodians and other service providers. Some of them compete with each other.

When competitors meet, the law watches what they agree to. Two federal laws matter most:

• Sherman Act, section 1 (15 U.S.C. § 1). It makes every contract, combination or conspiracy that unreasonably restrains trade illegal. An agreement does not need to be written. A nod, a pattern, or a "shared understanding" can be enough. Some agreements, such as price fixing, customer allocation and certain group boycotts, are treated as illegal on their face. No business reason will excuse them.
• Federal Trade Commission Act, section 5 (15 U.S.C. § 45). It bars unfair methods of competition and unfair or deceptive acts. The FTC enforces it against trade associations as well as companies.

State antitrust laws usually follow the same rules. Violations can bring criminal charges against individuals, fines for the association and its members, and private lawsuits for triple damages.

A trade association is a natural place for these problems to start. That is why nearly every serious trade association has a policy like this one. Ours matters more than most, for three reasons:

1. Our stated goal is market access: getting BSV listed, custodied and supported by US venues. That puts us in constant contact with exchanges, custodians and miners.
2. Our members include businesses that compete with each other on fees, services and customers.
3. The BSV ecosystem has a history of litigation with exchanges. The association has committed that it will not fund or bring litigation against any exchange. This policy helps keep our conduct consistent with that commitment.

This policy protects members, volunteers and the association. It is not meant to stop people from talking. It is meant to keep the talk on the right side of the line.

2Who this policy covers

This policy applies to everyone who acts in or for the association:

• directors, officers, committee chairs and working-group leads;
• members, volunteers and contractors;
• guests and speakers at any association meeting, Space or call.

It applies in every setting where association business happens. That includes formal meetings, the weekly public X Space, the organizers' group chat, direct messages about association business, email, shared documents, and informal talk before or after a meeting.

3What you must never discuss or agree to

Do not discuss, exchange information about, or agree on any of the following with a competitor, in any association setting.

Prices, fees and spreads. - Trading fees, withdrawal fees, listing fees, spreads, commissions, mining fees, custody fees, or any other price a member charges or pays. - Plans to raise, lower, hold or standardize any of them. - Discounts, rebates, credit terms or margins.

Listing and service terms between competitors. - What terms a member business will accept or offer when it lists, supports or custodies an asset. - Shared positions on what a venue "should" charge us, or on terms we will all refuse.

Boycotts and coordinated refusals to deal. - Any agreement, express or implied, to stop doing business with, refuse to use, or punish any exchange, custodian, miner, wallet, index provider, issuer or other business. - This includes "nobody list with them until they relist BSV", "let's all pull our coins from X", or "no one mine for pool Y". - Each member decides for itself, alone, whom to do business with. The association never decides that for its members.

Allocation of customers or markets. - Dividing customers, regions, products or business lines among competitors. - Agreements not to compete for a customer, a contract, a venue or an employee.

Coordinated pressure campaigns dressed up as member action. - Organized mass messaging, tagging or contact campaigns aimed at a specific business, its executives or its staff, to force a business decision. - Using automated agents, bots or many accounts to make a campaign look larger or more spontaneous than it is. - Campaigns that pair a demand with an implied threat, such as a boycott, a review-bombing effort, or a lawsuit. - Members may each, on their own, ask a venue to support BSV through that venue's official channels. The association may count and report real demand (see section 4). What the association must not do is organize a pressure campaign and present it as independent member action.

Competitively sensitive business information. - Non-public data on a member's costs, margins, volumes, customer lists, hashrate plans, capacity, wages, or business plans, when shared between competitors.

Trading and price of BSV. - Agreements to buy, sell, hold or time trades in BSV to move its price. - Price targets presented as a group plan. - This is mainly a market-manipulation and securities-law risk rather than an antitrust one. We list it here because the same meetings could produce it.

4What is fine

Most of what the association plans to do is lawful and useful. These activities are fine when done openly and with the safeguards in this policy:

• Public data rooms. Publishing technical, legal and security information about the BSV network that any venue, custodian or regulator can read. Examples: incident history, a reorg monitor, confirmation-depth guidance, node packages.
• Technical standards. Developing voluntary, open technical standards, when participation is open, the process is documented, and no member is forced to adopt them.
• Joint applications to venues. Preparing a factual listing or support package that the association submits through a venue's published process. The package must not include terms or threats agreed among competitors. Each venue decides alone.
• Demand evidence. Counting real users and businesses who want support, when each person acts on their own through official channels and the count is honest.
• Education. Courses, articles, Spaces, conferences and explainers about BSV technology and use.
• Lobbying and public comment. Petitioning government, filing comments on rules (for example, the GENIUS Act rulemaking), and meeting with regulators. Joint petitioning of government is generally protected.
• Aggregated statistics. Industry-wide figures compiled by a neutral party or counsel, when the data is historical, aggregated across enough sources that no single member can be identified, and shared without discussing what anyone should do with it.
• General market discussion. Talking about public news, public prices, and public filings, without agreeing what to do in response.

When in doubt, ask before you act. See section 8.

5Meeting rules

These rules apply to every association meeting, including board meetings, committee and working-group calls, and the weekly Space.

1. Written agenda. Every meeting has an agenda, circulated in advance. For the weekly Space, the agenda is published the day before. Stick to it.
2. Antitrust reminder. Each meeting opens with a short reminder that this policy applies. A suggested script is in Appendix A.
3. Minutes. Every board, committee and working-group meeting has minutes. Minutes record who attended, the topics discussed, and decisions made. They are accurate and concise. They do not record off-agenda chatter, jokes or speculation as if they were positions. Minutes are reviewed and approved at the next meeting.
4. Counsel on request. Any director, officer or member may ask that counsel attend a meeting or review an agenda. Counsel attends any meeting where competitively sensitive topics may come up, such as a joint venue application, a standards effort, or a data-collection project.
5. The "stop the discussion" rule. Anyone, at any time, may say "stop, antitrust" or words to that effect. The chair must halt the discussion right away. The topic stays closed until counsel has reviewed it. If people keep going, the chair ends the meeting. The minutes note that the discussion was stopped and why. Nobody will be criticized for raising the concern in good faith.
6. No side meetings. Do not hold informal "rump" sessions before, during or after a meeting to discuss what was ruled off-limits.

6The weekly Space and the group chat

The association runs a weekly public X Space and an organizers' group chat. Both are association settings. This policy applies to them in full.

The weekly Space. - The host reads the antitrust reminder at the start, or pins it where listeners can see it. - The Space follows its published agenda. - Speakers who start discussing a forbidden topic are asked to stop. If they continue, the host removes their speaking role. - The host does not call on listeners to message, tag or pressure a named business as a group. - The Space is recorded. Minutes are published within a day.

The group chat. - The chat is not private in any legal sense. Treat every message as one that could be read aloud in court or published. - The chat rules, once posted, include this policy by reference and a link to it. - Moderators remove messages that breach this policy and warn the sender once. A second breach leads to removal from the chat. - Polls in the chat must not ask members to agree on prices, fees, boycotts or coordinated actions toward any business. - Do not paste in competitively sensitive information about your own business or anyone else's.

Direct messages. Association business carried on in direct messages is still association business. The same rules apply.

7The claims ledger

The association keeps a public claims ledger. It lists every public claim the association or its leaders make, the evidence for it, and its status. The ledger is hashed to the BSV chain each month.

The ledger supports this policy in three ways:

1. No unverified claims about businesses. Nobody speaks for the association about what an exchange, custodian, miner or other business has said, promised or decided, unless the claim and its evidence are in the ledger first.
2. A record of contacts. Contacts with venues and custodians on behalf of the association are logged with the date, the people involved, the channel used, and a summary. This creates a record that each venue was approached openly and individually.
3. Corrections. When a claim turns out to be wrong, the ledger records the correction. We correct in public.

The ledger never records competitively sensitive information about any member.

8Questions, reporting and enforcement

Questions. If you are unsure whether something is allowed, stop and ask. Send the question to the Director or to counsel. Wait for an answer before going ahead.

Reporting. If you believe this policy has been breached, report it to the Director, to any other director, or to counsel. You may report anonymously by a channel the board will set up. The association will not retaliate against anyone who reports in good faith.

Investigation. The board, with counsel, reviews every report. People involved have notice and a chance to respond before any action is taken.

Consequences. Depending on the facts, a breach may lead to: - a warning; - removal from a meeting, the chat or the Space; - removal from a committee, working group or office; - suspension or end of membership, under the bylaws.

The association may also need to report conduct to authorities or take other steps on counsel's advice. Disagreeing with leadership is never, by itself, a breach of this policy.

9Annual acknowledgment

Every director, officer, committee chair and working-group lead signs an acknowledgment when they take on the role and again each year. Every member agrees to this policy when they join. A suggested form is in Appendix B.

The board reviews this policy each year, with counsel.

App. AMeeting reminder (suggested script)

"Before we start: the BSV USA Association follows an antitrust policy. We do not discuss or agree on prices, fees, spreads, listing terms, boycotts, or dividing customers or markets. We do not organize pressure campaigns against any business. Each member makes its own business decisions. If anyone thinks we are getting close to the line, say 'stop' and we will stop. The policy is linked in the agenda."

App. BAcknowledgment (suggested form)

I have read the BSV USA Association Antitrust Policy. I understand it and agree to follow it. I will raise concerns when I see a possible breach. I understand that a breach may lead to removal from my role or membership.

Name: __ Role: __ Date: __