SOWL Token

9/20/2025 - Where We've Been & What We've Been Working On... Thank you for your patience and understand as we’ve been working tirelessly behind the scenes to meet the requirements needed to be following all guidelines and standards necessary. Below is an update that breaks down what we are specifically working towards getting clearance or resolutions on before moving forward with next steps: Because our project involves both blockchain elements and child-focused educational gaming, this compliancy review is a critical step. We remain confident that our careful approach and previously acquired kidSAFE COPPA Certification are strong assurances of our commitment to safety and compliance. In the meantime, we are continuing diligent work with our team to: Review our master code and gaming process to confirm that all features remain kid-friendly and compliant with Apple App Store and Google Play Store requirements. Ensure integration of cryptocurrency elements into the next version of our product is compliant with securities, consumer protection, and child-focused regulations. Reassess our smart contract and tokenomics to confirm compliance with applicable federal and state laws. Additionally, here is a breakdown of the compliance measures we are actively reviewing and awaiting clearance on: 1) Federal Regulators & Laws Governing Crypto-Paying Mobile Apps a. SEC — Securities Laws (Howey Analysis / Framework): Determines whether tokens or features (like lending, “earn,” or return programs) qualify as securities. If classified as securities, registration or exemption is required. We are awaiting state determination on classification, since our EarlyBird app and SOWL token projects have user options to be interlinked. b. CFTC — Commodities Oversight: Covers certain crypto assets (like bitcoin) under commodities trading and market integrity rules. Relevant if apps involve derivatives, futures, or leveraged products. While confident that our digital artifacts and verbiage meet these standards, we are reviewing to ensure full compliance. c. FTC — Consumer Protection Rules: Disclosures, truthful advertising, opt-in monetization. Extra attention applies to children’s products (see below). In addition to already having our thorough privacy policy and terms and conditions, we are reviewing all digital frames and artifacts to ensure alignment. 2) Children-Specific Federal Rules a. COPPA — Children’s Online Privacy Protection Act: Requires parental consent before collecting personal data from children under 13. Covers in-app accounts, emails, geolocation, device identifiers, etc. Parents must have notice, deletion rights, and protections for kids’ data. While confident that our digital artifacts and verbiage meet these standards, we are reviewing to ensure full compliance. b. FTC COPPA Rule Changes (2025): Stricter rules limiting monetization of children’s data. Prohibits targeted ads to children. Requires stronger parental controls and stricter data-minimization/retention. We are taking the time to thorough vet all source code and smart contracts to ensure we meet these updated compliancy measures where necessary. c. Additional FTC Oversight on Kid-Targeted Practices: Scrutinizes in-app purchases, rewards, ads, and manipulative “dark patterns.” Extra caution applied to our crypto-earning and rewards systems. We are ensuring that there is clear and distinct verbiage for child-users vs. general users of the gamified educational resources. d. State Children’s Privacy & EdTech Rules: Several states impose additional restrictions on collection/use of student data. Important for us since our app is designed for educational use by children. While awaiting this state-level clearance, we continue building. Our developers are working on how to best integrate our contracted product into a web-friendly format, along with educational and curriculum-based resources. This will allow families and educators to see and interact with what we’ve created while regulatory matters are finalized. We know the regulatory landscape is complex, especially at the intersection of children’s education, gaming, and blockchain. Still, we remain steady in our mission and committed to transparency. Thank you for allowing us the chance to share in detail the measures we are undertaking, the clearance we are awaiting, and the steps we are continuing to push forward on in the meantime. As always, thank you for your patience, encouragement, and support. Should we receive any updates from the Securities Division before our next monthly communication, we will be sure to share them so that we know how to best proceed. Thank you all again. With an abundance of gratitude, The EB x SOWL Executive Committee