Katherine Ross

A new class action lawsuit, helmed by Hoppin Grinsell, has been filed against BProtocol Foundation and Bancor DAO.



“The lawsuit alleges that Defendants violated federal securities laws and various state laws by offering and selling investment contracts to Bancor liquidity providers, without registering under applicable federal securities laws as an exchange or brokerdealer, and without a registration statement in effect for the securities it offered and sold,” a press release for the lawsuit said.



When Bancor, a DeFi liquidity protocol, rolled out the second version of the investment product, it introduced impermanent loss protection — insurance for losses caused by value differences between automated market makers and spot markets. 



The function attracted liquidity providers (LPs) to the protocol, which led to over $2.3 billion worth of crypto assets invested in it.



But &#8220;the quantity of the crypto assets held by Bancor was insufficient to meet its obligations to LPs. If a sufficiently large number of LPs withdrew their investments at the same time, the protocol would crumble, much like a run on the bank,&#8221; the lawsuit <a href="https://storage.courtlistener.com/recap/gov.uscourts.txwd.1218725/gov.uscourts.txwd.1218725.1.0.pdf" target="_blank" rel="noreferrer noopener">alleges</a>.



In 2022, after withdrawals triggered a payment obligation from the liquidity providers, Bancor suspended the impermanent loss protection, leaving the providers to incur &#8220;the very losses that Defendants had promised to ‘100% protect’ against.&#8221;



Blockworks at the time <a href="https://blockworks.co/news/bancor-halts-impermanent-loss-safeguard-to-fight-off-hostile-antagonist" target="_blank" rel="noreferrer noopener">reported that Bancor temporarily paused</a> its impermanent loss protection feature due to &#8220;<a href="https://blockworks.co/news/bancor-describes-hostile-antagonist-behind-impermanent-loss-defense" target="_blank" rel="noreferrer noopener">hostile market conditions</a>&#8221; and &#8220;manipulative behavior.&#8221; Mark Richardson, Bancor product architect said “it would be difficult to imagine the protocol withstanding such a large flight of liquidity all at once.”



Through conferences and interviews, Bancor and its representatives targeted US investors, the lawsuit alleges. Representatives for the protocol used condoms and t-shirts to advertise to potential investors.



In 2021, a New York City court <a href="https://www.scribd.com/document/495824058/Bancor-Dismissal?irclickid=TLy1zAzcqztNWrKzLcSXdTO3UkAXM1RsexpoXI0&amp;irpid=10078&amp;utm_source=impact&amp;utm_medium=cpc&amp;utm_campaign=affiliate_pdm_acquisition_Skimbit%20Ltd.&amp;sharedid=coindesk.com&amp;irgwc=1" target="_blank" rel="noreferrer noopener">dismissed</a> a class action suit against Bancor and BProtocol Foundation, which alleged that the protocol offered unregistered security offerings.



Hoppin Grinsell and Bancor did not immediately respond to requests for comment.&nbsp;



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Bancor

Bancor Perks for Liquidity Providers Broke Securities Laws: Lawsuit

Ben Strack

The anonymity of crypto wallets has historically left Web3-focused marketing executives in the dark about their audience’s age, country or purchasing history, stifling efforts to reactivate existing users and acquire new ones.



A new tool seeks to change that.



Addressable, founded last June, scans various wallet data points, such as tokens purchased, balance, and overall transaction activity levels.&nbsp;



“Generally what we’re trying to understand is what is the wallet owner interested in and what are they doing on the blockchain,” Addressable co-founder Asaf Nadler said. “And on social media, we’re trying to understand the same thing.”&nbsp;



<figure class="wp-block-image size-large"><img loading="lazy" decoding="async" width="1024" height="683" src="https://blockworks-co.imgix.net/wp-content/uploads/2023/02/addressable-photo-3-1024x683.jpg" alt="" class="wp-image-46854" srcset="https://blockworks-co.imgix.net/wp-content/uploads/2023/02/addressable-photo-3-1024x683.jpg?w=1024 1024w, https://blockworks-co.imgix.net/wp-content/uploads/2023/02/addressable-photo-3-1024x683.jpg?w=300 300w, https://blockworks-co.imgix.net/wp-content/uploads/2023/02/addressable-photo-3-1024x683.jpg?w=768 768w, https://blockworks-co.imgix.net/wp-content/uploads/2023/02/addressable-photo-3-1024x683.jpg?w=1536 1536w, https://blockworks-co.imgix.net/wp-content/uploads/2023/02/addressable-photo-3-1024x683.jpg?w=2048 2048w, https://blockworks-co.imgix.net/wp-content/uploads/2023/02/addressable-photo-3-1024x683.jpg?w=386 386w, https://blockworks-co.imgix.net/wp-content/uploads/2023/02/addressable-photo-3-1024x683.jpg?w=392 392w, https://blockworks-co.imgix.net/wp-content/uploads/2023/02/addressable-photo-3-1024x683.jpg?w=329 329w, https://blockworks-co.imgix.net/wp-content/uploads/2023/02/addressable-photo-3-1024x683.jpg?w=80 80w" sizes="auto, (max-width: 1024px) 100vw, 1024px" /><figcaption class="wp-element-caption">CTO Tomer Shlomo, CEO Tomer Sharoni, and Chief Scientist Dr. Asaf Nadler | Source: Addressable</figcaption></figure>



Addressable’s app parses through data from roughly 500 million crypto wallets, the company said, which is stored in one of its databases. Its matching algorithms seek to link those to a separate grouping of more than 100 million social media profiles. 



Read more: <a href="https://blockworks.co/news/what-is-a-crypto-wallet">The Definitive Guide on Crypto Wallets</a>



The app is currently matching 17 million crypto wallet holders to Twitter accounts — via analyzing various social media engagements — to help marketing pros in the crypto segment better understand, and reach, specific audiences.&nbsp;



“A marketer can say I want to target whoever bought tokens from me, or bought tokens from my competitors, or is playing blockchain games in the bear market,” Nadler added.


<div class="wp-block-image">
<figure class="aligncenter size-large"><img loading="lazy" decoding="async" width="1024" height="588" src="https://blockworks-co.imgix.net/wp-content/uploads/2023/02/IMG_3064-1024x588.png" alt="" class="wp-image-46851" srcset="https://blockworks-co.imgix.net/wp-content/uploads/2023/02/IMG_3064-1024x588.png?w=1024 1024w, https://blockworks-co.imgix.net/wp-content/uploads/2023/02/IMG_3064-1024x588.png?w=300 300w, https://blockworks-co.imgix.net/wp-content/uploads/2023/02/IMG_3064-1024x588.png?w=768 768w, https://blockworks-co.imgix.net/wp-content/uploads/2023/02/IMG_3064-1024x588.png?w=428 428w, https://blockworks-co.imgix.net/wp-content/uploads/2023/02/IMG_3064-1024x588.png?w=455 455w, https://blockworks-co.imgix.net/wp-content/uploads/2023/02/IMG_3064-1024x588.png?w=381 381w, https://blockworks-co.imgix.net/wp-content/uploads/2023/02/IMG_3064-1024x588.png?w=80 80w, https://blockworks-co.imgix.net/wp-content/uploads/2023/02/IMG_3064-1024x588.png?w=1080 1080w" sizes="auto, (max-width: 1024px) 100vw, 1024px" /><figcaption class="wp-element-caption">The Addressable app in action | Source: Addressable</figcaption></figure></div>


But the marketer will not see sensitive data, Nadler said, as the app maintains the privacy of crypto wallet holders and Twitter accounts by aggregating the data when it leaves its database.&nbsp;&nbsp;



Addressable is looking to match wallets to social media accounts on Instagram and TikTok in the future.&nbsp;



<h2 class="wp-block-heading">Targeting an audience</h2>



In a demo with Blockworks, Nadler showed what a marketer would do to target those holding a Bored Ape NFT, for example, in their crypto wallet. Such holders make up a community some view as especially valuable to reach when launching a new NFT collection, he said.&nbsp;



“They will not respond to any [direct message] you make to them directly; they get lots of DMs,” he said of Bored Ape Yacht Club (BAYC) NFT holders. “But if you get on their radar and they become followers of you, you have a better chance.”



While the BAYC collection, released in 2021, totals 10,000 NFTs, the Bored Ape Yacht Club’s Twitter page has about a million followers.&nbsp;



As Nadler navigated the app, 5,900 such wallets came up in Addressable’s database as holding a Bored Ape NFT. Those were matched to 5,100 Twitter accounts — to which a marketer could send out a promoted tweet.



By whittling down the massive follower base of the Bored Ape Yacht Club to a contingent representing less than 1% of that, Web3 marketers can avoid “shouting to the void,” Nadler said.



“How do you avoid spending the huge amount of money…and get directly to these people?” he explained. “You need the blockchain information to do that.”



Marketers also get a full view of the conversion rate from both social media and the blockchain, Addressable executives said. In addition to seeing the number of social media engagements, the app helps marketers see how many people bought its token, for example.&nbsp;



<h2 class="wp-block-heading">Users weigh in on the tool</h2>



Addressable users include DeFi protocol <a href="https://home.bancor.network/" target="_blank" rel="noreferrer noopener">Bancor</a> and Web3 games developer platform <a href="https://www.immutable.com/" target="_blank" rel="noreferrer noopener">Immutable</a>.&nbsp;



Nate Hindman, Bancor’s head of growth, said the company is getting set to launch an automated trading protocol built for custom on-chain limit orders.&nbsp;



“There is currently no way to perform oracle-free limit orders on decentralized exchanges…so we are specifically looking to attract DeFi users who might be interested in setting automated entry/exit strategies in their positions and performing automated buy low, sell high strategies on-chain,” he said.&nbsp;



Addressable has allowed Bancor to promote educational initiatives on the protocol to specific entities based on their level of on-chain trading and usage.&nbsp;



“We are able to see the users that come from Addressable-sourced audiences, and they are particularly well aligned with our target audiences,” Hindman added.&nbsp;



Russell Tan, marketing lead for <a href="https://blockworks.co/news/gods-unchained-developer-slashes-staff-despite-hiring-spree-hype">Gods Unchained</a>, a digital trading card game developed by Immutable, said he has used Addressable to target holders of other Web3 trading card games, which he called “a niche space.”



The executive added the results were “impressive” when compared to Immutable’s existing database, as the company saw a lower cost per click across the different segments it tested.&nbsp;



“Understanding the nature of on-chain activity, I believe they are able to accurately provide the right audiences, and have been able to build out specific audiences based on our requirements,” Tan said.



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Matching Crypto Wallets to Twitter Accounts: Web3 Marketing Takes Off

Shalini Nagarajan

<div id="highlights-block_62b57931f6d18" class="highlights">
 <ul>
 <li>After Bancor paused a key feature, wallets linked to Celsius and Nexo withdrew large positions</li>
 <li>The team exercised emergency powers to prevent “a small handful of large players” from causing catastrophe, Bancor’s Nate Hindman told Blockworks</li>
 </ul>
 
</div>



Bancor, a pioneer in Decentralized Finance, temporarily <a href="https://cms.blockworks.co/bancor-halts-impermanent-loss-safeguard-to-fight-off-hostile-antagonist/" target="_blank" rel="noreferrer noopener">halted</a> its popular impermanent loss (IL) insurance feature last weekend, raising concerns that the protocol isn’t truly “decentralized.”



Impermanent loss refers to the unrealized amount that occurs when you provide liquidity to a pool in the form of cryptocurrency, and the value of those tokens changes since you deposited them.



Ever since the automated market maker said it wants to give the protocol room to breathe, it has observed wallets linked to crypto lenders Celsius and Nexo remove liquidity from the system while taking a haircut.



Blockworks spoke to Bancor’s Head of Growth Nathaniel Hindman and Head of Research Mark Richardson to understand what they saw as “manipulative behavior” that made them safeguard the protocol. The pair identified two major factors: large short positions taken out against the protocol’s BNT token, while at the same time a surge in withdrawals and selling of the liquidity mining rewards, which are paid out in BNT by the protocol.



<h3 class="wp-block-heading">Large short positions</h3>



In a June 19 <a href="https://blog.bancor.network/market-conditions-update-june-19-2022-e5b857b39336" target="_blank" rel="noreferrer noopener">blog</a>, Bancor said it would temporarily pause IL for liquidity providers (LPs) due to an ongoing “attack” and a “hostile antagonist.” The attack, they believe, relates to wallets linked to Celsius’ attempt to exit large positions in the protocol. They found accounts on two exchanges, FTX and OKX, that held short interest worth $2.5 million in total against the platform’s BNT token.



“It’s not catastrophically large,” Richardson said in an interview. “But whoever is sustaining these positions is borrowing the maximum daily limit every day.” He assumed the rapid withdrawals were made to cover liquidations or debt.



“Because of the financial situation that they&#8217;re in, they are being a lot more reckless in the way that they&#8217;re managing their exit from the market,” he said.



Additionally, they believed someone spread misinformation on the message board 4chan about the way Bancor runs its protocol. That drove panic and led to a number of active withdrawals piling up, similar to a bank run, encouraging other people to follow — until a majority of the protocol’s Total Value Locked (TVL) was queued up to leave, according to the product architect.



Large withdrawals end up making BNT less liquid, which means the token is less able to absorb the selling pressure. But Bancor was built to deal with short interest, Hindman said — emphasizing that it wasn’t just this incident that led to the IL pause.



<blockquote class="wp-block-quote is-layout-flow wp-block-quote-is-layout-flow">“It’s been this perfect storm of events.&#8221;</blockquote>



It&#8217;s not just the shorts,” he said. “It&#8217;s also having some of the largest centralized players in the industry utilizing our system, and then having them go insolvent at the same time and withdrawing and dumping large amounts of liquidity mining rewards.”



<h3 class="wp-block-heading">Bancor LP&#8217;s liquidity mining rewards &#8220;went on too long&#8220;</h3>



While decentralized exchanges like Uniswap don’t protect against impermanent loss, Bancor pitched such compensation as a unique selling point. LPs receive BNT tokens as rewards for committing their capital to Bancor pools. This was the “original sin” that caused headaches for the protocol, Hindman said.&nbsp;



“BNT liquidity mining rewards really went on too long,” he said, adding that large stacks have been accumulated in the hands of some people who are now rapidly dumping them, “putting this maximum strain on the system.”



So the combination of a market meltdown, substantial short positions and tons of BNT rewards being dumped simultaneously caused the team to intervene.



<blockquote class="wp-block-quote is-layout-flow wp-block-quote-is-layout-flow">“We could see very easily that we weren&#8217;t going to be able to withstand that for much longer,” Richardson said.&nbsp;</blockquote>



There have been some <a href="https://twitter.com/cobie/status/1538671298129416192" target="_blank" rel="noreferrer noopener">concerns</a> that Bancor simply mints new BNT to compensate liquidity providers under its ILP mechanism.



<figure class="wp-block-embed is-type-rich is-provider-twitter wp-block-embed-twitter"><div class="wp-block-embed__wrapper">
<blockquote class="twitter-tweet" data-width="550" data-dnt="true">Does Bancor &quot;impermanent loss protection&quot; just pay out newly minted BNT tokens in order to cover the loss if there wasnt enough made in fees&#8230;&#8230;???&mdash; Cobie (@cobie) <a href="https://twitter.com/cobie/status/1538671298129416192?ref_src=twsrc%5Etfw">June 19, 2022</a></blockquote><script async src="https://platform.twitter.com/widgets.js" charset="utf-8"></script>
</div></figure>



Hindman denied this by calling it a misconception. “Some of these criticisms have come from the biggest investors of some of our competitors and folks in the industry that just haven&#8217;t taken the time to understand this system,” he said.



He said Bancor operates similar to an insurance company, by offering the IL insurance in exchange for a percentage of trading fees on the network.



“Currently about 15% of trading fees are confiscated from liquidity provider earnings in order to fund the insurance, and that&#8217;s also on top of Bancor co-investing its BNT inside our own pools in order to generate protocol fees that offset this cost,” he said.



Minting of BNT is a last resort, only employed when the protocol fees, from trading activity, are not enough.



<h3 class="wp-block-heading">DAO emergency powers vs. centralized authority</h3>



Bancor said it had to activate its “emergency powers” in order to respond to the crisis, raising eyebrows about whether that goes against the fundamentals of a Decentralized Autonomous Organization. Technically, there isn’t supposed to be a centralized leadership group within a DAO.



But the Bancor team says they felt it necessary to assign emergency rights to certain people who can take decisions in a crisis. 



They were able to take the initiative because of a <a href="https://gov.bancor.network/t/bip21-dao-multisig-intervention-policy/3504">proposal</a> four months ago, which was ultimately voted on and ratified by the DAO. That granted emergency powers to the DAO’s <a href="https://docs.decentraland.org/decentraland/how-does-the-dao-work/">multi-sig</a> to implement such actions.



“In these early days of decentralized protocols, especially those that are as complex as Bancor, we think it&#8217;s only responsible that the DAO give emergency rights to a multi-sig,” Hindman said, referring to a multi-signature wallet that manages protocol upgrades and parameters, providing a measure of centralized control.



<blockquote class="wp-block-quote is-layout-flow wp-block-quote-is-layout-flow">“We weren&#8217;t going to sit by and watch as a community what we think was a small handful of large players suck the system dry.”</blockquote>



Bancor is now working to propose stronger protections for its IL insurance system to the DAO, even as independent observers <a href="https://twitter.com/hasufl/status/1538778386285441025" target="_blank" rel="noreferrer noopener">question the viability</a> of the whole system.



“We understand that it&#8217;s certainly controversial, but we do think it was the right decision to make,” said Hindman.



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Bancor Uses ‘Emergency Powers’ to Fight ‘Hostile Antagonist’

Sebastian Sinclair

<div id="highlights-block_62aff73d1f58c" class="highlights">
 <ul>
 <li>&#8220;Manipulative behavior&#8221; from a &#8220;hostile antagonist&#8221; is causing headaches for the Bancor protocol</li>
 <li>Bancor has now paused an important feature designed to shield against impermanent loss</li>
 </ul>
 
</div>



Decentralized automated market maker (AMM) and exchange protocol Bancor has temporarily paused its impermanent loss protection feature, citing &#8220;hostile market conditions&#8221; and &#8220;manipulative behavior.&#8221;



There is no ongoing attack and funds on the protocol are secure, Bancor said in a <a href="https://blog.bancor.network/market-conditions-update-june-19-2022-e5b857b39336" target="_blank" rel="noreferrer noopener">blog post</a> on Saturday. Trading is still active across all of Bancor&#8217;s liquidity pools.



The decision to shield the protocol from &#8220;potentially manipulative actors&#8221; was undertaken to give the protocol some &#8220;room to breathe and recover,&#8221; Bancor said in its post. 



It comes as digital asset ecosystems continue to falter amid a liquidity crisis and market contagion following crypto lender Celsius&#8217; decision to halt withdrawals and transfers from its platform. 



Impermanent loss (IL) is a unique phenomenon in decentralized finance. It occurs when the value of liquidity providers&#8217; staked assets deviate from AMM pools&#8217; dual asset pairs, relative to pricing on external markets.



Changes to external pricing outside of a protocol&#8217;s pool aren&#8217;t automatically adjusted, leaving open opportunities to take advantage of price differentials via arbitrage. An IL is calculated by taking into account the current value of a liquidity provider&#8217;s staked asset against what the asset would be worth had it been left in a wallet or an exchange.



Bancor&#8217;s protection feature, designed to withstand IL by distributing its native token BNT to those affected, will be reactivated on the protocol once the market stabilizes, Bancor said.



Mark Richardson, Bancor&#8217;s product architect and head of research said during a <a href="https://twitter.com/i/spaces/1RDGlgrVoWOKL?s=2" target="_blank" rel="noreferrer noopener">Twitter Spaces</a> discussion on Sunday evening his team had discovered &#8220;another Celsius wallet&#8221; intending to withdraw $10 million from the protocol.



It came amid a &#8220;wave of additional panic&#8221; stemming from a high number of withdrawals piling up, akin to a bank run event, according to Richardson.



&#8220;It would be difficult to imagine the protocol withstanding such a large flight of liquidity all at once,&#8221; Richarson said. The architect also pointed toward a &#8220;hostile antagonist&#8221; as attempting to profit off of Bancor&#8217;s woes by opening short positions against the platform&#8217;s BNT token.



&#8220;The ethical thing is to protect the protocol and its users against this type of antagonistic behavior,&#8221; Richardson said who pointed toward letting the situation play out or &#8220;do something about it.&#8221;



Richardson also said Bancor had activated its emergency powers to respond to its ongoing crisis, where the decision was reached to pause protections on IL as an immediate response. 



The protocol&#8217;s team will now seek ratification for its decision via a proposal within Bancor&#8217;s decentralized autonomous organization, Richardson said.



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Bancor Halts Impermanent Loss Safeguard To Fight Off ‘Hostile Antagonist’

Macauley Peterson

<div id="highlights-block_627befabd8d8c" class="highlights">
 <ul>
 <li>Focus on providing sustainable liquidity for DAOs and token treasuries</li>
 <li>Revamps impermanent loss protection and single-sided staking from V2.1</li>
 </ul>
 
</div>



The latest version of an automated market maker for cryptocurrencies launched on Ethereum’s mainnet Wednesday with a host of features for liquidity providers.&nbsp;



Bancor AMM has dubbed the new trading platform V3, an evolution for the company that invented the automated market maker (AMM) liquidity pool concept <a href="https://www.forbes.com/sites/rimmaboshernitsan/2018/10/23/this-blockchain-entrepreneur-is-reimagining-value-by-putting-empathy-first/" target="_blank" rel="noreferrer noopener">in 2017</a> — which Uniswap later iterated upon to become the dominant decentralized exchange protocol with <a href="https://defiprime.com/dex-volume" target="_blank" rel="noreferrer noopener">more trading volume</a> than its competitors combined.&nbsp;



The latest edition improves upon the prior version’s two key innovations — impermanent loss protection and single-sided liquidity provision.



“With regard to the functioning of the protocol, the product and the user experience, we were looking to alleviate basically all of the major pain points that we could find,” Bancor Head of Research Mark Richardson told Blockworks.



One of the risks of providing liquidity in a DEX, or decentralized exchange, is the change in the relative value between the tokens in a given pair — known as impermanent loss, or IL. To be profitable, a liquidity provider must earn swap fees from trades on the exchange sufficient to compensate for the IL disparity.&nbsp;



Bancor debuted a novel IL protection feature in a previous version, but it had one major shortcoming: An LP needed to provide liquidity for at least 100 days for full protection.



V3 eliminates that delay, replacing it with a “cooldown period” of seven days to withdraw from a position, plus a new 0.25% withdrawal fee, but in exchange, the IL coverage kicks in immediately.



“Our chief economist Stefan Loesch ran a bunch of Monte Carlo simulations using 14 months of data from version 2.1 and concluded that something like a seven-day cooldown period is going to be sufficient for that,” Richardson said.



Single-sided liquidity — adding only one token to a pool — was a key component of earlier versions, as each pool is paired with Bancor’s native BNT token.&nbsp;



The problem: a limit on the amount of deposits the protocol could handle. Once a cap was reached, more BNT had to be added to a pool to open up space for additional token deposits.&nbsp;



That led it to become a sort of “exclusive club,” according to Richardson, stunting growth.



“For a DeFi protocol to unnecessarily restrict your [total value locked] is kind of shooting yourselves in the foot.”



As a salve, V3 introduced what the team calls “the first-ever fungible Single-Sided Pool Tokens.” Unlike normal pool tokens, these LP positions incorporate an auto-compounding feature, aimed at decentralized autonomous organization (DAO) treasuries, which allows token teams to incentivize liquidity.



Previously, when a new Web3 project wanted to incentivize the formation of a pool, it tended to attract so-called mercenary capital, which would farm and sell the project’s tokens, reducing the treasury’s holdings&nbsp;



Now, DAOs and individual decentralized finance (DeFi) users can deposit capital into a Bancor pool, and see their token incentives auto-compound. That alleviates the need to manually claim them and saves on Ethereum gas fees — transactions that power the blockchain.



Uniswap’s V3 lacks a way for third parties to incentivize liquidity, explaining why many teams continue to offer incentives for market makers on the older Uniswap V2, which — more than a year after Uniswap V3’s launch — remains among the top 10 DEXes by trading volume, <a href="https://www.coingecko.com/en/dex" target="_blank" rel="noreferrer noopener">according to CoinGecko</a>.



Also, unlike Uniswap V3, which uses non-fungible tokens (NFTs) to represent an LPs share of a pool, Bancor’s new LP tokens are easily composable in other DeFi products — for instance they might be used as collateral in <a href="https://makerdao.com/en/" target="_blank" rel="noreferrer noopener">Maker</a> to mint DAI or supplied to Aave.



“Uniswap V3 has a completely different philosophy and objective,” Richardson said. “It doesn’t care about continuous liquidity. It doesn’t even espouse that markets should function correctly. It’s basically just a limit order protocol — it has all the shortcomings of an order book, and that makes it very difficult for things like natural price discovery.”



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