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I like the idea,

I'm miss one thing: the minute someone says "I'd buy 100NIL for X ETH", the IFO becomes an ICO no? We just added an extra-step.

Airdrops and token giveaways of unregistered security tokens is still a securities fraud.

You need either to register your token with the SEC, or find an exemption from registration or prove that your token is not a security.

If you can prove that your token is not a security, then you can sell it as well (providing you are doing proper KYC/AML and not an MSB or money transmitter.)

IANAL