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 So where's the money transmitter here? @IRS 
 Transaction is not settled until the receiver device comes online and contacts the mint. The mint is (illegal) money transmitter. 
 The mint doesn't transfer anything, it only keeps track of spent tokens. 
 That's 100% transfering in our book. The transaction would be impossible without the mint. 
 So ISPs are money transmitters too then since I do online banking through them, and so is google since I use their devices, and so is Firefox, etc.   
 Just accept that we will interpret the Law however we see fit to get what you want. If you don't like it, you can vOtE hArDeR 🤣 
 This is the canned reply you should give every time anyone asks you anything 
 A frying pan transfers heat therefore a mint transfers money 
 Correct. Thanks for understanding. Now spread the good word