This submission to the SEC, made in response to the Wells Notice, aims to provide clear and comprehensive insights into the CyberKongz ecosystem. Our objective is to assist the commissioners in thoroughly understanding the facts.

This document presents a detailed explanation demonstrating why the sale of Genesis Kongz and the subsequent distribution of Banana tokens do not satisfy the criteria of a security under the Howey test.

Furthermore, we articulate sound reasoning to establish why creators of NFT projects should not be classified as unregistered Broker-Dealers.

With consideration for the privacy of those involved, personal names have been omitted.