The U.S. Securities and Exchange Commission (SEC) charged Hydrogen and market maker Moonwalkers with market manipulation and an unregistered offering of securities. Among them, Hydrogen distributed its Hydro tokens through bounty programs and airdrops in 2018. At the same time, it also sold tokens directly to users through its trading platform. During this period, Hydrogen CEO hired Moonwalkers to conduct token trades (Wash Trade), Created a false impression of an active market, stabilized the price of tokens, and increased user interest. According to the SEC, Wash Trading’s conduct constituted both market manipulation and an unregistered securities offering despite avoiding ICOs in favor of airdrops and bug bounties.