When pressed to identify the securities in question, the SEC points to things that Kraken does not and could not trade, broker, or settle. Instead of identifying an investment contract, the SEC asks the Court to accept an “investment concept” as sufficient. Instead of identifying an enterprise, the SEC asks the Court to accept an “ecosystem.” But Kraken does not trade, broker, or settle “concepts” or “ecosystems.” The SEC never plainly alleges that what actually is traded, brokered, and settled on Kraken is itself an investment contract. This failure spotlights the fundamental problem with the SEC’s case. The only things that are alleged to be traded, brokered, or settled on Kraken are digital assets—which are not investment contracts.