It appears former Divvee management struggle with the concept of simplicity.

First the company offered access to discounts. Then it became a promotional platform. Then they were going to offer Ryze AI ROIs. Then they merged with Hodo Global into Nui. Then Nui announced it wasn’t partnering with Ryze AI. Then they were going to merge with Wealth Generators. Then they weren’t.

Now Nui are preparing to launch their Kala cryptocurrency, through yet another company; Symatri.

There’s no mention of Nui on the Symatri website. The Nui website however  mentions both its promotional platforms, Core and Reach, are “powered by Symatri”.

Through Symatri, Nui hopes to introduce a cryptocurrency offering into their MLM opportunity.

The Symatri Ecosystem is perfectly structured to foster a vibrant economy around achieving financial security.

Through completing CORE activities, members can earn Kala.

Within the REACH marketplace, all Kala users can purchase from a vast array of products and services.

Nui/Symatri will pay affiliates in Kala, and that can then be used on an internal e-commerce platform.

Seeing as Core and Reach are just the re-branding of Divvee’s Rank & Share, I have no idea why they felt the need to create yet another company. Let alone separate websites for Nui, Symatri and Kala.

Anyway, to get the ball rolling Kala is being offered to Nui affiliates through an ICO.

Nui affiliates can invest in up to 21 billion Kala ICO tokens, ranging in price from 1 cent to five cents.

After the ICO, Nui will offload the rest of its premined coins to affiliates who participate in the MLM opportunity.

Complete activities through our CORE platform and earn CORE points, then transfer those into Kala.

Whether Kala will be publicly tradeable is unclear. A FAQ on the Kala Token website states:

Like other cryptocurrencies, the value of Kala will fluctuate, and it will be expected to trade on market exchanges.

This suggests that, at least initially, Kala will be an internal points system.

And thus we have a problem.

Kala, within the context of the Nui/Symatri MLM offering is made up of two layers; Core points and Kala tokens.

Both have internal values, set by Nui/Symatri.

The Kala FAQ states Symatri hopes to have integration completed by Spring, 2018. That means public trading will likely happen after that date, if at all.

So in the meantime Kala is nothing more than an internal points system, attached to Core points, another internal points system.

Nui affiliates invest in Kala directly or obtain them through Core (it is unclear whether Kala will be purchasable through Nui/Symatri after the ICO).

From a regulatory standpoint, you have affiliates in an MLM opportunity investing in tokens, which the issuer is attaching value to.

Value they control and are able to increase over time.

Seeing as Kala isn’t publicly tradeable, that represents a passive investment opportunity – which would require registration with the SEC.

And that brings us to the title of this article.

In a November 26th affiliate update published on the Kala Token website, the company states:

Our legal representation includes the top law firms in the U.S., Latin America, and Asia.

Specifically, these law firms are specialized in cryptocurrency and are ready to stand by us.

They are on our advisory board and have partnered with us on the legal side.

Having the best cryptocurrency legal representation on the planet gives us and you the assurance that we’re in line with regulations and policies and are proficient in what we’re accomplishing.

“Unnamed layers”; a cliché in and of itself throughout the more dubious side of the MLM industry.

Regardless of whether Nui/Symatri actually have engaged lawyers, there’s the only opinion on ICOs that actually matters – that of the SEC;

Depending on the facts and circumstances of each individual ICO, the virtual coins or tokens that are offered or sold may be securities.

If they are securities, the offer and sale of these virtual coins or tokens in an ICO are subject to the federal securities laws.

Here we have an MLM company promoting an income opportunity attached to an ICO they claim has “inherent value”.

While it’s true Nui/Symatri aren’t your typical “we’re going to be the next bitcoin, massive ROI profits LOLOLOLOL!!!” crypto MLM offering, expecting a ROI on Kala tokens is still a part of the business.

Moreso if Kala can be traded internally at a value set by Nui/Symatri.

Problematically, neither Nui or Symatri are registered with the SEC.

At best Nui/Symatri will offer unregistered securities such until Kala goes public, after which it will likely follow the typical MLM altcoin pump and dump trajectory.

And bear in mind, that’s on top of Nui’s Mintage Mining offering, which also raises unregistered securities concerns.

The Reach marketplace appears to be an Amazon affiliate offering, meaning you hand over Kala tokens, Nui/Symatri purchase what you want from Amazon and then ship the item.

That’s hardly going to be enough to sustain a legitimate cryptocurrency.

Divvee launched Rank & Share over a year ago and it hasn’t taken off. Adding a cryptocurrency isn’t going to all of a sudden make the rewards platform any more viable.

What Kala, like any cryptocurrency, needs is external use.

With Kala unlikely to have any application outside of Nui/Symatri, as is typical of MLM altcoins – affiliates will be the only users.

At best Kala will be yet another pump and dump MLM altcoin launch, at worst an unregistered securities offering – with potentially serious regulatory consequences.