Grass fails to provide ownership or executive information on its website.

Grass’ website domain (“getgrass.io”), was registered in March 2023. The private registration was last updated on February 29th, 2024.

As per Grass’ website Terms and Conditions;

This agreement (“Agreement”) is between you and Lower Tribeca Corp.(“Company”, “we”, “us”, “our”) and governs your access to and use of the Grass app (“App”) that facilitates bandwidth sharing.

A January 1st SEC Form D filing reveals Lower Tribeca Corp is a shell company purportedly registered in the Bahamas.

Christopher Nguyen (right) is the sole cited Director of Lower Tribeca Corp in the filing.

Nguyen’s name led me to a December 2023 DT News article citing Grass as a product of Wynd Network. Nguyen, as “Chris Nguyen”, is cited as Wynd Network’s CTO.

Wynd Network rebranded as Wynd Labs on March 5th. The company runs a barebones website at “wyndlabs.ai”. No ownership or executive information is provided.

Through my own research I was able to ascertain one of Wynd Network’s co-founders, Andrej Radonjic (right).

Radonjic’s LinkedIn profile places him in Canada. Legal action involving Radonjic and Geckobyte Labs places him specifically in Ontario.

Randonjic appears to be a random crypto bro with no MLM experience.

As always, if an MLM company is not openly upfront about who is running or owns it, think long and hard about joining and/or handing over any money.

Grass’ Products

Grass has no retailable products or services.

Affiliates are only able to market Grass affiliate membership itself.

Grass’ Compensation Plan

Grass’ compensation plan is built around “grass points”.

Grass points are earned through use of Grass’ app and app usage by recruited affiliates.

Note that at time of publication, grass points don’t appear to be withdrawable.

Direct cash-out options aren’t currently supported, we’re exploring additional payment methods, including gift cards.

Grass Affiliate Ranks

There are ten affiliate ranks within Grass’ compensation plan.

Along with their respective qualification criteria, they are as follows:

  1. Iron – sign up as a Grass affiliate
  2. Bronze – accumulate 373 grass points or recruit six affiliates
  3. Silver – accumulate 2595 grass points or recruit eleven affiliates
  4. Gold – accumulate 11,351.30 grass points or recruit seventeen affiliates
  5. Platinum – accumulate 36,351.14 grass points or recruit thirty-four affiliates
  6. Emerald – accumulate 118,247.20 grass points or recruit eighty-six affiliates
  7. Diamond – accumulate 375,443.13 grass points or recruit one hundred and thirty-six affiliates
  8. Conqueror – accumulate 2,767,564.12 grass points or recruit one hundred and fifty-four affiliates
  9. Vanguard – accumulate 7,394,899.99 grass points or recruit one hundred and eighty-five affiliates
  10. Titan – accumulate 49,616,939 grass points or recruit two hundred and twenty-one affiliates

Referral Commissions

Grass pays recruitment commissions down three levels of recruitment (unilevel):

  • level 1 (personally recruited affiliates) – 20% of grass points generated via app usage
  • level 2 – 10% of grass points generated via app usage
  • level 3 – 5% of grass points generated via app usage

Grass App Usage Bonus

Grass affiliates receive 5000 grass points for clocking 100 hours usage of Grass’ app.

The affiliate who recruited them receives  50% matching bonus (2500 points).

Joining Grass

Grass affiliate membership is free.

Grass Conclusion

Grass as an MLM company is problematic in that within the opportunity itself, nothing is marketed to or sold to retail customers.

Affiliates download software, run it and receive grass tokens. This is done on the representation affiliates might one day be able to cash out their tokens, or the tokens “will be retroactively converted into network ownership.”

This leads us into potential securities fraud.

Before we get into that though let’s analyze Grass’ app pitch; “Get paid for your unused internet”.

The basic premise of Grass’ app pitch is that after you give it access to your internet connection, it resells that access to undisclosed third-parties.

Grass is a network for selling that bandwidth to corporations & institutions, with a suite of applications that do this in the background of your phone or computer.

The idea of reselling bandwidth for the sake of it makes no sense. Whoever is buying access to the bandwidth still needs to expend bandwidth to access the resold bandwidth, so why not just do whatever directly?

Once you scratch under the surface of Grass, things get potentially more nefarious.

Buyers seek unused internet bandwidth to access a more diverse range of IP addresses, which enables them to see certain websites from a retail perspective.

By utilizing your unused internet bandwidth, they can conduct market research, or perform tasks like web scraping to train AI.

“Market research” should set off alarm bells. As should confirmation that Grass is reselling internet access to be used to access third-party websites.

DDOS botnets anyone?

As for AI;

Grass is a decentralized network for accessing the public web, and thus accessing the data necessary to train AI models.

[Grass] enables AI labs to directly scrape the internet for web data to train their AI models, and second, it can also supply them with data sets directly.

“Scraping the internet for web data” is, in my opinion as a publisher, code for copyright theft. Notably, Grass fails to disclose to consumers where it sources it own AI data sets from.

Pending the outcome of several recently filed AI-related copyright lawsuits, Grass and its app users could find themselves on the receiving end of a suit.

Personally I’m skeptical of Grass’ claimed bandwidth customer base.

SimilarWeb tracked ~11.3 million monthly visits to Grass’ website for February 2024. That’s impressive but just under 20% of that traffic was tracked from China and Russia.

Grass claims its bandwidth clients “include Fortune 500s, as well as institutions like Colleges and Universities”. I can’t imagine residential internet connections in China and Russia being worth much to anyone.

Notwithstanding potential national security implications between the US, China and Russia (good luck pulling apart that jurisdictional nightmare).

The US was the third largest source of Grass website traffic, coming in at 7.3%. This is a good time to sidestep into Grass’ potential securities fraud.

Typically when BehindMLM uncovers securities fraud it’s in relation to Ponzi schemes. With Grass there’s no money asked of app users, so we can rule out Ponzi related securities fraud.

Where things get murky is Grass’ representation that “grass points” equate to “network ownership”.

At the end of the beta [grass tokens] will be retroactively converted into network ownership.

Consumers are being solicited to download and run Grass’ app, on the promise of what essentially amount to virtual shares.

The previously cited Form D Lower Tribeca Corp filed with the SEC back in January makes no specific mention of grass points virtual shares being awarded to consumers.

There is a declaration of $2.1 million of claimed exempt securities, but that has nothing to do with Grass’ consumer-facing MLM opportunity.

Although it isn’t soliciting money from its users, and there doesn’t appear to be any way to directly invest into grass points, Grass could still be committing securities fraud by way of offering unregistered securities.

As a user of the app, in addition to personal security the longevity of Grass with respect to regulatory compliance should also be a concern.

Finally we also have potential violations of the FTC Act.

First and foremost from ownership, executive, client data and its own AI dataset – Grass’ disclosures to consumers is atrocious.

As far as Grass’ compensation plan goes, nothing is marketed or sold to retail customers, making it a pyramid scheme under current FTC guidelines.

It should be noted that whether Grass does or doesn’t generate revenue from third-parties is irrelevant – nothing is marketed or sold to retail customers within its MLM opportunity.

As with potential securities fraud, consumer harm (excluding hardware, electricity and bandwidth fees) is minimal due to there being no direct cost to participate. Still, Grass running a pyramid scheme would be a violation of the FTC Act and subject to FTC regulation.

The chance of Grass attracting the attention of the FTC increases exponentially if Grass affiliates are able to cash out their grass points (be it through gift cards or directly).

Again against the backdrop of regulatory compliance, the longevity of Grass is brought into question again.

Approach with caution.