SafeHarbor2.0
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Add to the disclosure requirements
It's necessary, but not sufficient, to post disclosures on a public website; the disclosures must be readily available to the public in the venues where the Initial Development team is talking about the network. Otherwise, I could post disclosures on www.thisisadisclosurethatyouwillnevereverfind.com, and be compliant with the rule, but ineffective at communicating the disclosure to the public.
Fair point about closing the loophole and focusing on effective disclosure, but requiring a link in all "websites, software, and services" could get messy.
What about: ...and must provide a reference to such website on any communications to the general public relating to the network or Token and made by or on behalf of the Initial Development Team
?