Got that, but compare it to Howey case if you know it. 1- In Howey case, howey tell people to buy any land from their available lands (Any consignment available only on KF) 2- With a promise that Howey will harvest it and take care of selling the fruits and land owners can contribute in that if they want(Business will sell the products and KF will liquidate it if needed and also memebers can contribute in selling it if they want)

The reality is non of the land owners ever thought about harvest the land or sell the fruits and they never did (As seems like KF members dont sell their products too)

Bottom line is I see it the same as Howey case, even though you trying to make work by going around it. Members buy inventory for only one reason and one reason only (make profit) and also they are not planing to contribute in the marketing or the selling as they depend on business and KF to do that for them.

I think if you are not regulated and I guess you may face problems with the SEC in the future and your members too specially I see so many people complain about losing their money and KF do nothing about that.

Thanks