A digital token or crypto asset is a crypto asset security if it meets the definition of a security, which the Securities Act defines to include “investment contract,” i.e., if it constitutes an investment of money, in a common enterprise, with a reasonable expectation of profit derived from the efforts of others. As described in greater detail below, during the relevant period, Ishan provided material, nonpublic information about, and Nikhil and Ramani traded in, at least nine crypto asset securities that meet this definition.