How Does the SEC Interpret the Term ‘Investment of Money’ in the Context of Cryptocurrency?

The SEC interprets 'investment of money' broadly to include any commitment of assets by the investor. In the context of cryptocurrency, this means the exchange of fiat currency, another cryptocurrency (like Bitcoin or Ethereum), or even labor/services for the token.

The key is that the investor parts with something of value with the expectation of a return. The form of the currency or asset exchanged is not the determining factor.