SECURITIES AND EXCHANGE COMMISSION v. BINANCE HOLDINGS LIMITED et al Document 53: Declaration

District Of Columbia District Court
Case No. 1:23-cv-01599-ABJ-ZMF
Filed June 12, 2023

DECLARATION of Mary Beth Maloney in Support of Opposition by BINANCE HOLDINGS LIMITED re [4] MOTION for Temporary Restraining Order filed by SECURITIES AND EXCHANGE COMMISSION. (Attachments: # (1) Exhibit 1 -10, # (2) Exhibit 11 - 20, # (3) Exhibit 21 - 30, # (4) Exhibit 31 - 40, # (5) Exhibit 41 - 50, # (6) Exhibit 51 - 60, # (7) Exhibit 61 - 70, # (8) Exhibit 71 - 80, # (9) Exhibit 81 - 90, # (10) Exhibit 91 - 102)(Nelson, Daniel)

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Page 1 UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,
v.
No. 1-23-cv-01599-ABJ
BINANCE HOLDINGS LIMITED,
BAM TRADING SERVICES INC.,
BAM MANAGEMENT US HOLDINGS
INC., AND CHANGPENG ZHAO,
Defendants.
DECLARATION OF MARY BETH MALONEY IN SUPPORT OF JOINT
MEMORANDUM OF LAW ON BEHALF OF DEFENDANTS BINANCE HOLDINGS
LIMITED AND CHANGPENG ZHAO IN OPPOSITION TO PLAINTIFF’S
EMERGENCY MOTION FOR A TEMPORARY RESTRAINING ORDER
I, MARY BETH MALONEY, hereby declare under penalty of perjury the following:
1.
My name is Mary Beth Maloney. I am a partner with the law firm of Gibson,
Dunn & Crutcher (“Gibson Dunn”) and am admitted pro hac vice to this Court for the purposes
of appearing in this action. I represent Defendant Binance Holdings Limited (“BHL”) in the
above-captioned action. I submit this Declaration in support of the Joint Memorandum of Law
on Behalf of Defendants Binance Holdings Limited and Changpeng Zhao In Opposition To
Plaintiff’s Emergency Motion For A Temporary Restraining Order (“Defendants’ Opposition”),
including the Declaration of Jeffrey R. Harris (“Harris Declaration”) and the Declaration of
J. Gregory Eastman (“Eastman Declaration”). Based on information provided to me, I could
and would competently testify to the truth of the matters stated herein.
Page 2 2.
Attached at Exhibit BH-1 is a true and correct copy of the September 1,
Binance Blog Post titled, “Who Is Guangying Chen, and Is Binance a ‘Chinese Company’?,”
found at:
https://www.binance.com/en/blog/from-cz/who-is-guangying-chen-and-is-binance-a-chinesecompany-2386330931319516973, as it appeared on June 11, 2023.
3.
Attached as Exhibit BH-2 is a true and correct copy of the web archive of the
October 25, 2022 Business Insider article titled, “Meet Changpeng ‘CZ’ Zhao, the CEO of
Binance and the richest man in crypto who worked at a gas station before making his $30 billion
fortune,” found at:
https://web.archive.org/web/20221025065415/https://www.businessinsider.com/zhaochangpeng-binance-billionaire-crypto-mcdo
as it
appeared on June 11, 2023.
4.
Attached as Exhibit BH-3 is a true and correct copy of the November 15,
CNN article titled, “Who is Binance founder Changpeng ‘CZ’ Zhao, the billionaire who wants to
‘rebuild’ crypto?,” found at:
https://www.cnn.com/2022/11/15/business/binance-founder-changpeng-zhao-ftx-intlhnk/index.html, as it appeared on June 11, 2023.
5.
Attached as Exhibit BH-4 is a true and correct copy of the December 10,
DailyCoin article titled, “Changpeng Zhao: The Man Named ‘CZ’,” found at:
https://dailycoin.com/how-binances-changpeng-zhao-became-powerful-man-in-crypto/, as it
appeared on June 11, 2023.
Page 3 6.
Attached as Exhibit BH-5 is a true and correct copy of the January 11,
StartupTalky article titled, “Changpeng Zhao – Success Story of the Binance Founder,” found at:
https://startuptalky.com/changpeng-zhao-binancefounder/#:~:text=Changpeng%20Zhao's%20interest%20in%20cryptocurrencies,in

20the%20crypto%20market, as it appeared on June 11, 2023.
7.
Attached as Exhibit BH-6 is a true and correct copy of the April 5, 2022 Times
Decrypt article titled, “Binance Coin – Meet the team,” found at:
https://decrypt.timestream.in/projects/binance-coin-meet-the-team, as it appeared on June 11,
2023.
8.
Attached at Exhibit BH-7 is a true and correct copy of the bylaws of BAM
Management US Holding Inc., dated February 5, 2019.
9.
Attached at Exhibit BH-8 is a true and correct copy of the Certificate of
Incorporation of Bam Trading Services Inc., dated January 31, 2019.
10.
Attached at Exhibit BH-9 is a true and correct copy of the bylaws of BAM
Trading Services Inc. (“BAM”), dated February 5, 2019.
11.
Attached at Exhibit BH-10 is a true and correct copy of a Binance.US webpage
of state licenses, found at:
https://support.binance.us/hc/en-us/articles/360050532193-Licenses, as it appeared on June
10, 2023.
12.
Attached at Exhibit BH-11 is a true and correct copy of a web archive of
Binance Terms of Use, effective on June 14, 2019, found at:
https://web.archive.org/web/20191115111959/https://support.binance.us/hc/en-
Page 4 us/articles/360033952672 that was bates stamped BHL-SEC-BUSD-0000675 and produced to
the Commission.
13.
Attached at Exhibit BH-12 is a true and correct copy of a web archive of the
September 24, 2019 Binance.US announcement titled, “Binance.US Opens Trading For BTC,
ETH, XRP, BCH, LTC, BNB and USDT,” found at:
https://web.archive.org/web/20191115111959/https://support.binance.us/hc/enus/articles/360033952672, as it appeared on June 10, 2023.
14.
Exhibit BH-13 is intentionally omitted.
15.
Attached as Exhibit BH-14 is a true and correct copy of a letter that I
understand was sent from Commission Senior Trial Counsel Jennifer Farer to BHL, dated May
30, 2023.
16.
Attached as Exhibit BH-15 is a true and correct copy of a letter that I understand
was sent from Stephanie Brooker, Kendall Day, and Richard Grime of Gibson Dunn and William
Baker, Benjamin Naftalis, and Douglas Yatter of Latham & Watkins LLP to the Commission, dated
June 4, 2023.
17.
Attached as Exhibit BH-16 is a true and correct copy of a letter that I understand
was sent from the Commission to William McLucas of WilmerHale LLP
(“WilmerHale”), dated May 30, 2023.
18.
Attached as Exhibit BH-17 is a true and correct copy of a letter that I understand
was sent from William McLucas of WilmerHale on behalf of BAM to the Commission, dated June
1, 2023.
Page 5 19.
Attached as Exhibit BH-18 is a true and correct copy of a letter that I understand
was sent from William McLucas of WilmerHale on behalf of BAM to the Commission, dated June
2, 2023.
20.
Attached as Exhibit BH-19 is a true and correct copy of an email chain that I
understand is between David Ware and Richard Grime from Gibson Dunn on one hand, and the
Commission on the other hand. The most recent email in the chain is dated June 5, 2023.
21.
Attached as Exhibit BH-20 is a true and correct copy of a proposed stipulation
that I understand was sent from Stephanie Brooker of Gibson Dunn on behalf of all defendants
dated, June 11, 2023.
22.
Attached at Exhibit BH-21 is a true and correct copy of the April 21,
Motley Fool article titled, “What is Staking in Crypto,” found at:
https://www.fool.com/investing/stock-market/market-sectors/financials/cryptocurrencystocks/what-is-staking/, as it appeared on June 10, 2023.
23.
Attached as Exhibit BH-22 is a true and correct copy of the November 30,
Tech In Asia article titled, “Three months after launch, this unbanked crypto exchange made
$7.5m in profit,” found at:
https://www.techinasia.com/cryptocurrency-exchange-binance, as it appeared on June 11,
2023.
24.
Attached at Exhibit BH-23 is a true and correct copy of Binance.com’s message
to U.S. users, dated November 9, 2020, that was bates stamped BHL-SEC-BUSD-0308230 and
produced to the Commission.
Page 6 25.
Attached at Exhibit BH-24 is a true and correct copy of a Binance.com August
20, 2021 announcement titled, “Important Changes About Binance Identity Verification” , found
at:
https://www.binance.com/en/support/announcement/important-changes-about-binanceidentity-verification-51bf294e26324211a47
as it appeared on June 10,
2023.
26.
Attached at Exhibit BH-25 is a true and correct copy of the Commission’s
website article titled, “Framework for ‘Investment Contract’ Analysis of Digital Assets,” found
at:
https://www.sec.gov/corpfin/framework-investment-contract-analysis-digital-assets, as it
appeared on June 10, 2023.
27.
Attached as Exhibit BH-26 is a true and correct copy of the December 21,
Binance Blog post titled, “Introducing BNB Auto-Burn: a new Protocol for the Quarterly BNB
Burn,” found at:
https://www.binance.com/en/blog/ecosystem/introducing-bnb-autoburn-a-new-protocol-forthe-quarterly-bnb-burn-421499824684
as it appeared on June 11, 2023.
28.
Attached at Exhibit BH-27 is a true and correct copy of the webpage found at:
https://coinmarketcap.com/currencies/bnb/, as it appeared on June 10, 2023.
29.
Attached at Exhibit BH-28 is a true and correct copy of the Travala
advertisement titled, “Book Hotels with Binance Coin (BNB),” found at:
https://www.travala.com/payment/binance-coin-bnb, as it appeared on June 10, 2023.
Page 7 30.
Attached at Exhibit BH-29 is a true and correct copy of the CanWork
advertisement titled, “Access Global Freelance Talent with Smart-Contract Confidence,” found
at:
https://canwork.io, as it appeared on June 10, 2023.
31.
Attached at Exhibit BH-30 is a true and correct copy of the Aeron advertisement
titled, “Pilot Shop,” found at:
https://aerotrips.com/shop, as it appeared on June 10, 2023.
32.
Attached at Exhibit BH-31 is a true and correct copy of the webpage found at:
https://machix.com/, as it appeared on June 10, 2023.
33.
Attached as Exhibit BH-32 is a true and correct copy of the October 22,
BNB Chain blog post titled, “Introducing BEP-95 With a Real-Time Burning Mechanism,”
found at:
https://www.bnbchain.org/en/blog/introducing-bep-95-with-a-real-time-burningmechanism/, as it appeared on June 11, 2023.
34.
Attached at Exhibit BH-33 is a true and correct copy of the webpage found at:
https://github.com/bnb-chain/BEPs/pull/176, as it appeared on June 10, 2023.
35.
Attached at Exhibit BH-34 is a true and correct copy of the webpage found at:
https://paxos.com/busd/, as it appeared on June 10, 2023.
36.
Attached at Exhibit BH-35 is a true and correct copy of the November 15,
Binance Blog post titled, “Understanding BUSD and Binance-Peg BUSD,” found at:
https://www.binance.com/en/blog/ecosystem/understanding-busd-and-binancepeg-busd5526464425033159282, as it appeared on June 10, 2023.
Page 8 37.
Attached at Exhibit BH-36 is a true and correct copy of the PWG, FDIC and
OCC report titled, “Report on STABLECOINS,” dated November 1, 2021.
38.
Attached at Exhibit BH-37 is a true and correct copy of the August 19,
Binance Blog post titled, “Are Stablecoins the Safe Haven of Crypto? Protect Your Wealth With
BUSD and BGBP Stablecoins,” found at:
https://www.binance.com/en/blog/all/are-stablecoins-the-safe-haven-of-crypto-protect-yourwealth-with-busd-and-bgbp-stabl
as it appeared on June 10,
2023.
39.
Attached at Exhibit BH-38 is a true and correct copy of the Paxos article titled,
“Outside of the Paxos platform, where can I use my Paxos stablecoins?,” found at:
https://paxos.com/2020/06/02/outside-of-the-paxos-platform-where-can-i-use-my-paxosstablecoins/, as it appeared on June 10, 2023.
40.
Attached at Exhibit BH-39 is a true and correct copy of the September 23,
CoinTelegraph article titled, “BUSD: A case study for stablecoin compliance and security,”
found at:
https://cointelegraph.com/news/busd-a-case-study-for-stablecoin-compliance-and-security,
as it appeared on June 10, 2023.
41.
Attached at Exhibit BH-40 is a true and correct copy of the February 13,
CoinDesk article titled, “What’s the Point of Stablecoins? The Reasons, Risks and Types to
Know,” found at:
https://www.coindesk.com/learn/whats-the-point-of-stablecoins-understanding-why-theyexist/, as it appeared on June 10, 2023.
Page 9 42.
Attached at Exhibit BH-41 is a true and correct copy of the Software License
Services Agreement between BAM Trading Services Inc. and Binance Holdings Limited, dated
January 7, 2020.
43.
Attached at Exhibit BH-42 is a true and correct copy of the Master Services
Agreement between BAM Trading Services Inc. and Binance Holdings Limited, dated January 7,
2020.
Attached as Exhibit BH-43 is a true and correct copy of a letter that I
44.
understand was sent by Brian Shroder on behalf of BAM to the Commission dated December 30,
2022.
45.
Attached at Exhibit BH-44 is a true and correct copy of the Commission’s
website post of Commissioner Hester Peirce’s January 20, 2023 remarks before the Digital
Assets at Duke Conference, found at:
https://www.sec.gov/news/speech/peirce-remarks-duke-conference-012023, as it appeared
on June 10, 2023.
46.
Attached at Exhibit BH-45 is a true and correct copy of the July 21,
CoinDesk article titled, “SEC Chair Hints Some Stablecoins Are Securities,” found at:
https://www.coindesk.com/markets/2021/07/21/sec-chair-hints-some-stablecoins-are-securities/,
as it appeared on June 10, 2023.
47.
Attached at Exhibit BH-46 is a true and correct copy of the October 14,
Reuters article titled, “SEC’s Gensler says CFTC authority over stablecoins should be bolstered,”
found at:
https://www.reuters.com/technology/secs-gensler-says-cftc-authority-over-stablecoinsshould-be-bolstered-2022-10-14/, as it appeared on June 10, 2023.
Page 10 48.
Attached at Exhibit BH-47 is a true and correct copy of the March 31,
Commission “Response to Staff Accounting Bulletin,” found at:
https://www.sec.gov/news/statement/peirce-response-sab-121-033122, as it appeared on June 10,
2023.
49.
Attached at Exhibit BH-48 is a true and correct copy of the October 7,
Fintech Times article titled, “Binance: Helping to Build Financial Freedom in Africa with
Cryptocurrency and Blockchain” found at:
https://thefintechtimes.com/binance-helping-to-build-financial-freedom-in-africa-withcryptocurrency-and-blockchain/, as it appeared on June 10, 2023.
50.
Attached at Exhibit BH-49 is a true and correct copy of the September 4,
Financial Times article titled, “Cryptocurrencies: developing countries provide fertile ground,”
found at:
https://www.ft.com/content/1ea829ed-5dde-4f6e-be11-99392bdc0788, as it appeared on
June 10, 2023.
51.
Attached at Exhibit BH-50 is a true and correct copy of the January 13,
Financial Express article titled, “What can cryptocurrencies ensure for economic development of
third-world countries,” found at:
https://www.financialexpress.com/business/blockchain-what-can-cryptocurrencies-ensurefor-economic-development-of-third-w
as it appeared on June 10,
2023.
52.
Attached at Exhibit BH-51 is a true and correct copy of the February 5,
Reason article titled, “Bitcoin Is Protecting Human Rights Around the World,” found at:
Page 11 https://reason.com/video/2021/02/05/bitcoin-is-protecting-human-rights-around-the-world/, as it
appeared on June 10, 2023.
53.
Attached at Exhibit BH-52 is a true and correct copy of the July 26,
National article titled, “Why cryptocurrencies are a lifeline for people in developing countries,”
found at:
https://www.thenationalnews.com/business/money/2022/07/27/why-cryptocurrencies-are-alifeline-for-people-in-developing-co
as it appeared on June 10, 2023.
54.
Attached at Exhibit BH-53 is a true and correct copy of the November 30,
International Banker article titled, “Why Emerging Markets are Early Adopters of Crypto as
Legal Tender,” found at:
https://internationalbanker.com/brokerage/why-emerging-markets-are-early-adopters-ofcrypto-as-legal-tender/, as it appeared on June 10, 2023.
55.
Attached at Exhibit BH-54 is a true and correct copy of the December 19,
Gallup article titled, “Income Biggest Barrier to Banking in Developing Countries,” found at:
https://news.gallup.com/poll/159380/income-biggest-barrier-banking-developing-countries.aspx,
as it appeared on June 10, 2023.
56.
Attached at Exhibit BH-55 is a true and correct copy of the December 15,
CoinDesk article titled, “Even if a Thousand Projects Don’t Make It, Blockchain Is Still a
Change Catalyst,” found at:
https://www.coindesk.com/tech/2019/12/15/even-if-a-thousand-projects-dont-make-itblockchain-is-still-a-change-catalyst/, as it appeared on June 10, 2023.
57.
Attached at Exhibit BH-56 is a true and correct copy of the February 23,
New York Times article titled, “Bitcoin Has Saved My Family,” found at:
Page 12 https://www.nytimes.com/2019/02/23/opinion/sunday/venezuela-bitcoin-inflationcryptocurrencies.html, as it appeared on June 10, 2023.
58.
Attached at Exhibit BH-57 is a true and correct copy of the June 8, 2023, New
Vox article titled, “Now Might Be A Good Time To Consider Quitting Crypto,” found at:
https://www.vox.com/23752826/binance-coinbase-sec-crypto-investors, as it appeared on June
10, 2023.
59.
Attached at Exhibit BH-58 is a true and correct copy of the April 2020 BNB
Smart Chain Whitepaper, found at:
https://github.com/bnb-chain/whitepaper/blob/master/WHITEPAPER.md#consensus-andvalidator-quorum, as it appeared on June 10, 2023.
60.
Attached at Exhibit BH-59 is a true and correct copy of the webpage found at:
https://www.bnbchain.org/en/staking, as it appeared on June 10, 2023.
61.
Attached at Exhibit BH-60 is a true and correct copy of the webpage found at:
https://coinmarketcap.com/rankings/exchanges/, as it appeared on June 10, 2023.
62.
Attached at Exhibit BH-61 is a true and correct copy of the webpage found at:
https://docs.bnbchain.org/docs/validator/create-val, as it appeared on June 10, 2023.
63.
Attached at Exhibit BH-62 is a true and correct copy of the webpage found at:
https://dappradar.com/rankings/protocol/binance-smart-chain, as it appeared on June 10, 2023.
64.
Attached at Exhibit BH-63 is a true and correct copy of the webpage found at:
https://www.binance.com/en, as it appeared on June 10, 2023.
65.
Attached at Exhibit BH-64 is a true and correct copy of the webpage titled,
“Welcome to Binance,” found at:
https://www.binance.com/en/about, as it appeared on June 10, 2023.
Page 13 66.
Attached at Exhibit BH-65 is a true and correct copy of the webpage found at:
https://www.binance.com/en/mission, as it appeared on June 10, 2023.
67.
Attached at Exhibit BH-66 is a true and correct copy of the 2021 AICPA
Auditing Standards AU-C Section 200.
68.
Attached at Exhibit BH-67 is a true and correct copy of the spreadsheet titled
H360 - BAM Trading Services Inc.xlsx.
69.
Attached at Exhibit BH-68 is a true and correct copy of the spreadsheet titled
H360 - BAM Management US Holdings Inc.xlsx.
70.
Attached at Exhibit BH-69 is a true correct copy of the webpage found at:
https://www.primetrust.com/about, as it appeared on June 11, 2023.
71.
Attached at Exhibit BH-70 is a true correct copy of the webpage found at:
https://www.wintermute.com/about/, as it appeared on June 11, 2023.
72.
Attached at Exhibit BH-71 is a true correct copy of the webpage found at:
https://subspace.network/, as it appeared on June 11, 2023.
73.
Attached at Exhibit BH-72 is a true correct copy of the webpage found at:
https://www.coinbase.com/about, as it appeared on June 11, 2023.
74.
Attached at Exhibit BH-73 is a true correct copy of the webpage found at:
https://www.kbit.com/, as it appeared on June 11, 2023.
75.
Attached at Exhibit BH-74 is a true correct copy of the webpage found at:
https://www.auros.global/about/, as it appeared on June 11, 2023.
76.
Attached at Exhibit BH-75 is a true correct copy of the March 27, 2020 Forbes
article titled, “Coinbase Buys Crypto Trading Firm Tagomi To Boost Institutional Trading
Business,” found at:
Page 14 https://www.forbes.com/sites/jeffkauflin/2020/05/27/coinbase-buys-crypto-trading-firmtagomi-to-boost-institutional-tradi
as it appeared on June 11,
2023.
77.
Attached at Exhibit BH-76 is a true correct copy of the Bloomberg web profile
titled, “Alameda Research,” found at:
https://www.bloomberg.com/profile/company/1872413D:HK#xj4y7vzkg, as it appeared on June
11, 2023.
78.
Attached at Exhibit BH-77 is a true correct copy of the AU Section 350.05 on
“Audit Sampling”, as it appeared on June 11, 2023. This is relied upon in the Declaration of J.
Gregory Eastman.
79.
Attached at Exhibit BH-78 is a true correct copy of the webpage found at:
https://gdpr.eu/what-is-gdpr/, as it appeared on June 11, 2023.
80.
Attached at Exhibit BH-79 is a true and correct copy of the entry for “Net
Income” in the Financial Accounting Standards Board, “Master Glossary,” found at:
https://asc.fasb.org/MasterGlossary, as it appeared on June 11, 2023.
81.
Attached at Exhibit BH-80 is a true and correct copy of the June 5, 2023 The
Wall Street Journal article titled, “SEC Says Binance Misused Customer Funds, Ran Illegal
Crypto Exchange in U.S.,” found at:
https://www.wsj.com/articles/sec-sues-crypto-exchange-binance-over-u-s-rule-violations6918ed0f, as it appeared on June 11, 2023.
82.
Attached at Exhibit BH-81 is a true and correct copy of the June 8,
Economist article titled, “Regulators put the future of America’s crypto industry in doubt,” found
at:
Page 15
as it appeared on June 11, 2023.
83.
Attached at Exhibit BH-82 is a true and correct copy of the March 2016 article
from the Review of Financial Studies titled, “Policy Uncertainty and Corporate Investment,”
found at:
https://academic.oup.com/rfs/article-pdf/29/3/523/24450983/hhv050.pdf, as it appeared on
June 11, 2023.
84.
Attached at Exhibit BH-83 is a true and correct copy of the August 2013 article
from the Journal of Law, Economics, & Organization titled, “The Effect of Regulatory
Uncertainty on Investment: Evidence from Renewable Energy Generation.”
85.
Attached at Exhibit BH-84 is a true and correct copy of the August 2016 article
from the Journal of Monetary Economics titled, “Lending on Hold: Regulatory Uncertainty and
Bank Lending Standards.”
86.
Attached at Exhibit BH-85 is a true and correct copy of the January 2020 article
from the Journal of Monetary Economics titled, “The economic effects of trade policy
uncertainty.”
87.
Attached at Exhibit BH-86 is a true and correct copy of the January 2020 article
from the American Economic Journal: Economic Policy titled, “Trade and investment under
policy uncertainty: theory and firm evidence.”
88.
Attached at Exhibit BH-87 is a true and correct copy of the November
article from the Journal of Economic Asymmetries titled, “Economic policy uncertainty: A
literature review.”
Page 16 89.
Attached as Exhibit BH-88 is a true and correct copy of the CoinMarketCap
article titled, “Stablecoins And BUSD: What Are They And How do they work?,” found at:
https://coinmarketcap.com/community/articles/33431/, as it appeared on June 11, 2023.
90.
Attached as Exhibit BH-89 is a true and correct copy of the webpage found at:
https://www.binance.com/en/bnb, as it appeared on June 11, 2023.
91.
Attached as Exhibit BH-90 is a true and correct copy of the October 21,
Binance Blog post titled, “Binance and BNB Chain: What’s the Difference?,” found at:
https://www.binance.com/en/blog/ecosystem/binance-and-bnb-chain-whats-the-difference6186229776062522437, as it appeared on June 11, 2023.
92.
Attached as Exhibit BH-91 is a true and correct copy of the December 16,
Federal Reserve article titled, “The stable in stablecoins,” found at:
https://www.federalreserve.gov/econres/notes/feds-notes/the-stable-in-stablecoins20221216.html, as it appeared on June 11, 2023.
93.
Attached as Exhibit BH-92 is a true and correct copy of the November 16,
Binance Blog post titled, “BUSD: All You Need To Know About the Stablecoin,” found at:
https://www.binance.com/en/blog/futures/busd-all-you-need-to-know-about-the-stablecoin421499824684903051, as it appeared on June 11, 2023.
94.
Attached as Exhibit BH-93 is a true and correct copy of the CoinMarketCap
webpage, found at:
https://coinmarketcap.com/currencies/binance-usd/, as it appeared on June 11, 2023.
95.
Attached as Exhibit BH-94 is a true and correct copy of the Cryptocompare
article titled, “February 2023 Exchange Review,” found at:
Page 17 https://www.cryptocompare.com/media/44051283/feb_exchange-review-vf.pdf, as it appeared
on June 11, 2023.
96.
Attached as Exhibit BH-95 is a true and correct copy of the CoinGecko article
titled, “Potential Impact of CFTC’s Lawsuit on Binance.US Users,” found at:
https://www.coingecko.com/research/publications/binance-us-monthly-users, as it appeared on
June 11, 2023.
97.
Attached as Exhibit BH-96 is a true and correct copy of the Robinhood article
titled, “Cardano (ADA), Polygon (MATIC), Solana (SOL) Update,” found at:
https://robinhood.com/us/en/support/articles/cardano-polygon-solana-update/, as it appeared on
June 12, 2023.
98.
Attached as Exhibit BH-97 is a true and correct copy of the Yahoo Finance
article titled, “Robinhood moves to cut support for Cardano, Polygon, and Solana,” found at:
https://finance.yahoo.com/news/robinhood-moves-cut-support-cardano-142427041.html/, as it
appeared on June 12, 2023.
99.
Attached as Exhibit BH-98 is a true and correct copy of the Blockworks article
titled, “Crypto.com to suspend US institutional exchange,” found at:
https://blockworks.co/news/crypto-com-suspending-us-institutional-exchange, as it appeared on
June 12, 2023.
100.
Attached as Exhibit BH-99 is a true and correct copy of the webpage found at:
https://www.binance.com/en/legal/licenses, as it appeared on June 12, 2023.
101.
Attached as Exhibit BH-100 is a true and correct copy of the September 23,
2022 Wall Street Journal article titled, “Binance Hires Compliance Chief From Crypto Rival
Kraken,” found at:
Page 18 https://www.wsj.com/articles/binance-hires-compliance-chief-from-crypto-rival-kraken11663925403, as it appeared on June 12, 2023.
102.
Attached as Exhibit BH-101 is a true and correct copy of the Block article
titled, “Binance’s new compliance chief sees mission to put crypto exchange giant ‘beyond
reproach, found at:
https://www.wsj.com/articles/binance-hires-compliance-chief-from-crypto-rival-kraken11663925403, as it appeared on June 12, 2023.
103.
Attached as Exhibit BH-102 is a true and correct copy of the CoinMarketCap
webpage found at:
https://coinmarketcap.com/exchanges/binance-us/, as it appeared on June 12, 2023.
* * *
I declare under penalty of perjury that the foregoing is true and correct. Executed on
this 12th day of June 2023 in New York, New York.
/s/ Mary Beth Maloney
Mary Beth Maloney
Counsel for Defendant Binance Holdings
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