On October 11, 2019, the United States Securities and Exchange
Commission (the “SEC”) filed an enforcement action and
obtained a temporary restraining order against Telegram Group Inc.
and its wholly-owned subsidiary TON Issuer Inc. (together
“Telegram”), in connection with Telegram’s
planned offering of billions of digital tokens called
“Grams.” The SEC’s complaint alleges that the
Grams are securities under the meaning of United States law, and
that Telegram failed to properly register its offers and sales of
Grams, as required by United State law. The complaint also alleges
that Telegram has sold approximately 2.9 billion Grams at
discounted prices to 171 initial purchasers worldwide since January
2018, and that Telegram was planning to launch its own blockchain
no later than October 31, 2019, at which time the Grams’
initial purchasers, as well as Telegram itself, would be permitted
to sell their Grams. As a result of the temporary restraining order
in the