the legal advising side of crypto is increasingly divorced from crypto's market realities for years, the legal advice would've been to do airdrop and let community organically create a market if it wants to, then as project/token matures eventually a CEX will probably pick it up...and not to do market-making deals... this is close to absolutely dead; the understanding now is that if you don't get your token listed on a CEX around launch when there is max hype, and have a professional market-making arrangement at the same time, it may never be listed and your project might be doomed by low liquidity & poor price discovery forever meanwhile, weirdly, it becomes clearer and clearer on the legal side that CEX and market-making arrangements are the single biggest factor likely to count against a token in a securities law analysis (various crypto cases applying Gary Plastics precedent etc.) no lawyer can really solve your regulatory problems at this point, and so you should be careful about overpaying....it's likely going to be very ngmi advice that you're almost certainly going to disregard... this is not the lawyers' fault, all they can do is follow the law and advise accordingly...but theoretically sound legal advice in crypto is more and more divorced from the market realities...