Name a Notable SEC Enforcement Action Based on the Howey Test for an ICO

The SEC action against Telegram's TON (Telegram Open Network) ICO is a prominent example. The SEC successfully argued that the sale of Gram tokens constituted an unregistered securities offering, applying the Howey Test.

The court issued an injunction preventing the distribution of the tokens, even to non-US investors, highlighting the SEC's broad reach. This case reinforced the view that the Howey Test applies robustly to digital assets, regardless of the issuer's intent or the token's proposed utility.