Order Instituting Cease-and-Desist Proceedings Pursuant to Section 8A of the Securities Act of 1933, Making Findings, and Imposing Penalties and a Cease-and-Desist Order (In re CarrierEQ, Inc. d/b/a AirFox)

AirFox conducted an ICO raising roughly $15 million from over 2,500 investors, promoting AirTokens' expected value increase through its founders' market-building efforts, offering early-purchase discounts, promising secondary-market tradeability, and running a paid bounty promotional campaign targeted at digital-currency investors rather than the prepaid-phone users the tokens were nominally meant to serve, all without registering the offering or qualifying for an exemption.