On November 19, 2020, the U.S. Securities and Exchange Commission issued a no-action letter to IMVU, Inc in connection with the sale of its VCOIN token. IMVU describes itself as the world’s largest avatar-based social platform with a global network of over seven million monthly active users. These users create 3D avatars to meet new friends, interact, and play games in virtual environments online and through IMVU’s app. IMVU’s No-Action Letter Request to the SEC argued that…

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