How Does the SAFT Model Attempt to Satisfy the “Functional Network” Test?

The SAFT model attempts to satisfy the "functional network" test by legally separating the investment contract (the SAFT itself) from the eventual delivery of the utility token. The SAFT is sold as a security to accredited investors under an exemption, raising the capital needed to build the network.

The utility token is only delivered once the network is demonstrably functional and decentralized. The argument is that at the time of delivery, the token is no longer an investment in a common enterprise but a consumable product, thus satisfying the functional network criteria and avoiding security classification for the token itself.