In order for Shuizang to return to the essence of Shuizang, we must first pass the level of compliance and legality.
Written by: Lawyer Liu Honglin
Platform introduction
At the turn of July and August, "FireBunny" went online quickly, causing the discussion in the digital Tibetan circle, which had been silent for a while, to suddenly soar. The Fire Rabbit platform aims to provide a full range of services for artists and creators from the application of Metaverse, the incubation of contracted artists and Ip, the transformation and sales of digital collections, etc. The platform aspires to promote China's excellent traditional culture, promote the brilliance of intangible cultural heritage, rejuvenate cultural relics, and cultural tourism, and excavate and export outstanding domestic artists and cultural creations. Cultural innovation, showing unique charm, enhancing collectors' awareness of culture, multi-dimensional experience of cultural diversity, and developing new business energy.
As of August 4, 2023, Dianchain shows that the market value of Huotu is 223 million, and the daily turnover is about 18.88 million.
According to the retrieval from public channels, the company that Fire Rabbit belongs to is Hainan Shengyuan Digital Technology Co., Ltd. Hainan Shengyuan Digital Technology Co., Ltd. was established on June 21, 2023, 100% controlled by natural person Yang Wenbin, with a registered capital of 5 million RMB. And Mr. Yang has great personal influence in the digital Tibetan circle, and the rapid popularity of Fire Rabbit is undoubtedly related to his own popularity in the digital Tibetan circle, which has attracted a large number of fans and users. According to the official announcement of Huotu, from the opening of registration on July 23 to 14:00 on July 30, the number of valid user registrations reached as high as 72,500.
core gameplay
register and log in
According to Huotu’s official statement, regarding the registration of new users on the platform, Huotu does not adopt the invitation code mode, but allows all people to register. There is even a screenshot of the chat history of Mr. Yang Wenbin circulating on the Internet, claiming that Huotu will not implement the whitelist mode to prevent ordinary users from being denied the opportunity to enter the market. However, during the author's test period, during the registration process on August 1, 2023, there was a short-term problem that new users could not register because they could not receive the verification code. Now the registration function has returned to normal.
wallet binding
The wallets currently supported by Huotu include the Huifu Wallet of Shanghai Huifu Payment Co., Ltd. and the Yeepay Wallet of Yeepay Payment Co., Ltd. The wallet will charge users a certain management fee.
Digital Collectibles Airdrop and Consignment
(1) "The Gods"
"The Gods", as the first collection of Fire Rabbit, is operated by Boom Labs digital art creation organization, which re-expresses Greek mythology in the form of digital art, and pays tribute to the enthusiasm of art and imagination. Among them, the consignment price of "Goddess of Wisdom·Athena" is as high as 20,000 yuan.
(2) "Hello Little Chestnut"
"Hello Little Chestnut" was created by artist Qiyao 77, trying to make breakthroughs and innovations. Currently, the Huotu platform uses "Xingdai Chestnut" for airdrop activities. For every copy of "God of Wisdom Athena", 4 copies of "Xingdai Chestnut" will be airdropped (rights can be superimposed); "God of Light·Apollo" will be replaced with "Xingdai Li" at a ratio of 1:3 (rights can be superimposed).
Volume Purchase
At present, Fire Rabbit verifies, registers and opens bulk purchase rights to the top 100 users who have made net purchases during multiple periods. The platform only opens this function to the above-mentioned qualified users. According to the announcement, the bulk purchase function will be opened to the majority of users through more activities in the future.
invite friends
Huotu also uses the usual publicity methods used by the Shuzang platform to attract new users, but for the time being, it has not found Huotu's requirements for user-oriented newcomers and corresponding newcomer rewards.
Digital Blind Box
As of the last time the author logged into Huotu, the function area of the digital blind box has not yet been opened.
underlying technology
Huotu adopts the BSN open alliance chain. BSN is a blockchain global infrastructure led by the National Information Center for overall planning and top-level design, jointly initiated and constructed by China Mobile, China UnionPay and other units.
Compliance assessment
(1) Civil legal risk
Regarding the qualitative nature of the copyright of digital collections issued on the Huotu platform, the copyright of digital collections purchased by users on the digital collection platform is owned by the issuer or the original creator, and users are not allowed to use digital collections for any commercial purposes. Therefore, the holder of the digital collection does not grant the purchaser the complete commercial use right of the purchased digital collection, nor does it grant the purchaser the right to use the purchased digital collection to produce creative derivative works.
(2) Administrative supervision risk
Business qualification
The Huotu Data Tibet platform is operated by Hainan Shengyuan Digital Technology Co., Ltd. After inquiry, Hainan Shengyuan Digital Technology Co., Ltd. has indeed obtained the website ICP record, EDI license and other qualifications, but the author has not yet inquired about the blockchain information service record of Hainan Shengyuan Digital Technology Co., Ltd. / Fire Rabbit Platform in the State Cyberspace Administration of China , Inquire about the information about the network cultural business license on the website of the Ministry of Culture and Tourism, and inquire about the information about the online publishing service license on the website of the State Press and Publication Administration, and other necessary qualifications for digital collection platforms.
According to Article 11 of the "Regulations on the Administration of Blockchain Information Services", it is stipulated that all enterprises participating in blockchain services must carry out blockchain filing, and blockchain information service providers should register within ten working days from the date of providing services. Filing procedures will be completed within a few days through the blockchain information service filing management system of the State Internet Information Office. After the filing is completed, the blockchain information service provider shall indicate its filing number in a prominent place such as the Internet website and application program that it provides services to the outside world.
What is more noteworthy is that Article 22 of these regulations makes it clear that blockchain information service providers who violate the regulations, fail to perform the filing procedures in accordance with the above regulations, or fill in false filing information, shall be subject to the responsibility of the state and provinces, autonomous regions, and municipalities directly under the central government. The Internet Information Office will order corrections within a time limit based on their responsibilities; if they refuse to make corrections or if the circumstances are serious, they will be given a warning and a fine of not less than 10,000 yuan but not more than 30,000 yuan.
Similarly, those who fail to obtain necessary qualifications such as an Internet culture business license and an online publishing service license will face corresponding administrative penalties.
In addition, according to Article 15 of the "E-Commerce Law", e-commerce operators shall continue to publish business license information, administrative license information related to their business operations, and information that is not required in accordance with Article 10 of this Law on a prominent position on their homepage. Information such as the registration status of market participants, or the link identification of the above information.
However, the author noticed that the Huotu platform did not publicize the obtained business licenses, license registrations, and relevant qualifications in prominent places on the webpage and website. This is also a compliance risk that Huotu needs to address urgently.
Prevent the financialization of digital collections
In April 2022, the China Internet Finance Association, the China Banking Association, and the China Securities Association jointly issued the "Initiative on Preventing NFT-related Financial Risks", stating that "resolutely curb the tendency of NFT financialization and securitization, and strictly prevent illegal financial activities." risk.” There are relatively large compliance risks in the opening of the secondary trading market on many Tibetan platforms, and many platforms will therefore limit secondary transactions to avoid financialization risks.
Although Huotu has opened a secondary market to allow users to buy and sell, the platform clearly prohibits platform users from using collections for hype, off-market transactions, fraud, and other illegal uses in many places such as user agreements and announcements. Necessary measures will be taken, including but not limited to closing orders, deleting illegal information, etc.
However, according to the author's observation, the platform mostly implements a semi-limited price model for the collections. Even if the prices of various collections are limited, the price ceiling is still very high. After the launch of Fire Rabbit, the consignment price of platform collections still has a relatively large increase. Even, Fire Rabbit is considered to be the "biggest serving of pig's knuckle rice" in the data and Tibetan industry. It is said that after a user draws a piece of Apollo from Fire Rabbit, he immediately sells it at a high price of 1.3w. The official account of Huotu has also been blocked due to “business activities related to virtual currency transactions or secondary transactions of digital collections”. Huotu may face greater challenges in administrative supervision.
(3) Criminal risk
In the digital collection industry, complaints from large groups of users often bring administrative penalties and even criminal risks to the platform. Therefore, the Shuzang platform will attach great importance to actively responding to customer complaints and reports. We have noticed that within a few days of Huotu’s launch, many rights protection groups and insider articles have sprung up, and there are even large-scale reposts of Huotu’s publicity pictures. As of the date of writing, the trend of public opinion has improved, which may be due to the high market value of Huotu, or it may be due to the timely feedback of the Huotu team on user demands. But in any case, how to properly solve the user's rights protection problem and how to better build a customer complaint service mechanism are problems that the Huotu team needs to respond to and solve all the time.
summary
Huotu immediately gained a very high degree of attention within a few days of its launch, attracting a large number of users to enter the market, which can be regarded as a recent phenomenon. The rapid rise to popularity and popularity have also made some netizens question, and even many users have formed their own rights protection groups. How Huotu will perform in the future and how to solve compliance and legal issues will affect users' trust in the platform, which in turn will affect the stable, continuous and stable development of the platform. As for Mr. Yang’s vision—to bring Shuizang back to the essence of Shuizang, whether it can be realized through Fire Rabbit, it must first pass the hurdle of compliance and legality.
