Stout provided an independent valuation opinion regarding the fair market value of rights, title, and interests under certain restricted and unrestricted digital asset token purchase and award agreements as of the valuation date. The engagement was performed for estate planning and federal gift tax reporting purposes.

The subject interest consisted of publicly traded digital tokens subject to contractual transfer restrictions, including an initial lock-up period followed by staged unlocking provisions. Our analysis first determined the public equivalent value based on observed market trading data as of the valuation date and then evaluated the economic impact of the contractual liquidity constraints embedded within the agreements.

To quantify the appropriate discount for lack of marketability, we performed a two-pronged analysis. First, we applied a comparative framework utilizing the Stout Restricted Stock Study, benchmarking relevant financial and market risk characteristics against empirical restricted stock transactions. Second, we conducted a quantitative option-based analysis using a put option methodology to estimate the economic cost of illiquidity over the effective holding period, incorporating observed market volatility and transfer restrictions.

The valuation was prepared in accordance with applicable Treasury Regulations defining fair market value for estate and gift tax purposes and incorporated documented assumptions, empirical market evidence, and quantitative modeling to support defensibility under IRS review.