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WHITEPAPER
VERSION 0.9.1 JUNE, 2018
 CONTENTS 2

Table of Contents

Executive Summary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

What Problem We Are Solving / Intro . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

The Market We Are In . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Why We Are the Right Guys for the Job /Team. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Our Product. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
Fully-automated trading strategies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Structural arbitrage
Statistical arbitrage
Event-driven strategies
On-chain data analysis
Additional types
Strategy development process
Risk management
Intelligent execution algorithms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
Trading signals and alerts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
CRYPTTO platform design overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Competitive Landscape . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

When We Will Deliver . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

What We Need to Deliver / Use of Funds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

Tokenomics. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

Proof of Work . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

Risk and Legal Disclaimers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

 SUMMARY 3

Executive Summary

In the nascent crypto trading markets, the levels of Our suite of products will include fully-automated
competition are relatively low and inefficiencies abound, market-neutral trading strategies, intelligent
creating ample opportunities for active trading strategies execution algorithms, and trading signals with
to earn healthy risk-adjusted returns. manual or semi-automated execution.

However, that is bound to change as high returns

Fully-automated trading strategies, available on our
inevitably attract new entrants and increased
platform, will include structural and statistical arbitrage,
competition will unavoidably drive the returns down,
event- and data-driven strategies and strategies, based
pushing the weakest players into unprofitability.
on the on-chain data analysis.
To remain competitive, crypto traders will need to evolve
All our trading strategies will be short-term (seconds to
and seek a totally different level of expertise,
hours) and market-neutral, meaning that the market
infrastructure, and resources.
moves up or down won't affect their profitability.
At the moment such tools are only available to the largest
Our strategies will be trading in users' crypto exchange
quantitative hedge funds and high-frequency trading
accounts on their behalf through API access with users
firms. However, the rise of blockchain and crypto
having full control over the choice of strategies and
technologies have created a unique opportunity for a
capital allocation.
willing professional trading firm to provide access to its
platform, strategies, and algorithms to individual All our strategies will be extensively back-tested and will
investors across the world. be deployed in production environment with our own
capital before becoming available on the platform. Our
The core team behind CRYPTTO has been at the
robust risk management system will continuously
forefront of quantitative high-frequency trading for well
monitor and control all trading aspects and platform
over a decade.
security.
Our experience in the highly-competitive traditional asset
We will also provide access to our proprietary suite of
classes (US equities, option, and futures), the team we've
intelligent execution algorithms that will allow traders to
assembled over the years, and the technology we've built
achieve better execution prices and drastically reduce
give us a quantifiable edge in short-term trading
their trading costs.
strategies in the crypto markets. An edge we will be
sharing with the community via the CRYPTTO platform. In addition, our users will have an extensive choice of
various technical, news and sentiment-based, and on-
CRYPTTO is developing a Quantitative High- chain data-based signals, alerts, and indicators with
Frequency Trading Platform that will provide manual or semi-automated execution on all major crypto
access to a suite of products that were exchanges.
previously available only to HFT hedge funds and
CRYPTTO trading platform will have 3 levels that will
prop trading firms.
differ in functionality and access requirements.

Our fully-automated trading strategies will be available

exclusively to the users of the A (atto) level. Membership
in the A level will be limited and access will be available
only through staking auctions.
 SUMMARY 4

In May 2018 we have launched two structural arbitrage
strategies in production mode on several exchanges as
part of our Alpha Platform Preview. These strategies are
now being scaled across instruments and exchanges. We
have also released a free Real-time Normalized Market
Data Feed from major crypto exchanges.
We plan to launch our Beta Platform in October 2018.
It will include two or more structural arbitrage strategies
scaled across most liquid instruments and major
exchanges, at least one statistical arbitrage strategy and,
possibly, an event-driven strategy.
The strategies will be fully operational and the
Beta Platform will have UI and security features
to allow on-boarding of the first third-party users.
We plan to provide exclusive access to our Beta
Platform to our pre-sale participants.
The public launch of our Platform is planned for
December 2018. At launch, our platform will provide a set
of fully-automated trading strategies and a suite of
intelligent execution algorithms.
Our hardcap is USD 25,000,000.
High-frequency trading is a very expensive business to
set up and operate competitively and it is a non-stop
scientific and technological race.
Our hardcap was chosen to allow us to develop state-of-
the-art trading platform, infrastructure, and strategies, to
develop them fast, and to have the necessary resources
to keep our platform competitive and future-proof for the
long time to come.
Our TTO token is the sole means of access to our
platform. It is used for subscription payments on all
levels of our platform, to fulfill staking requirements of
the F (femto) level, and to fulfill dynamic staking
requirements (access auctions) of the A (atto) level of our
platform.
Total supply of our tokens is 100,000,000 TTO. 70% will
be sold in the crowdsale. 30% will be retained by the
team, our partners, and advisors.
All team tokens will be subject to vesting tied to platform
and strategies development milestones.

Then, we will focus on expanding our fully-automated

strategies offering, scaling our strategies across
instruments and exchanges, optimizing and upgrading
our platform, and adding trading signals and alerts
functionality.

The ultimate goal is to ensure that our platform remains

competitive and provides value to our users in the form
of profitable trading opportunities for many years to
come, despite the ever-increasing competition,
technological or market regime changes.
 INTRO 5

What Problem We Are

Solving / Intro

Blockchain and crypto technologies are ultimate
disruption and democratization tools. They challenge the
status quo in many established industries, break down
barriers – regulatory, geographical, cost of entry etc., and
provide access to the global community on a scale
unmatched before.
Industries, that for decades were accessible only to “the
chosen few”, find themselves amidst the “change and
adapt (i.e. open-up) or die” situation. Banking, venture
investing and many other industries are undergoing an
unseen before transformation at an accelerating pace.
Suddenly, to launch a successful global start-up, you do
not need to move to California and spend years building
industry relationships. And launching a global payment
network with millions of users across the world does not
require access to capital, huge infrastructure, and a
compliance department size of a small country, but a few
lines of code posted onto an online forum.
One of the industries that still remains closed and
inaccessible to general public is the professional
quantitative/algorithmic/high-frequency trading. Returns
in this field are substantial and uncorrelated to the
general market movements – a rare, highly sought-after
quality.
That is certainly true for traditional financial markets and
there is very little one can do to change the situation.
However, the rise of the crypto markets and blockchain
infrastructure has created a unique window of
opportunity for a willing professional quantitative trading
player to provide access to opportunities, insofar
available only to the best quantitative hedge funds and
high-frequency trading firms, to individual investors
across the world.
CRYPTTO is this willing player, and it is our
mission to provide equal access to the
professional quantitative trading tools to
all crypto investors out there.
From proprietary trading signals to fully-automated
market-neutral trading strategies, from low-latency
execution platform to intelligent AI-powered execution
algorithms – CRYPTTO provides you unique access to
the best modern trading tools on the market.
These tools not only give you a quantifiable edge now -
without them, it will be difficult to remain a profitable
crypto trader as more and more professional players
from traditional markets enter the space.

However, the barriers to entry are high indeed: to become

and remain a competitive player in this field one would
need to bear huge infrastructure costs and obtain a level
of highly-specialized expertise that only comes with
multiple years of experience and costly mistakes.

On the other hand, if you are an individual investor and

want to participate in professional trading firm's success
by providing capital and receiving returns on it – the odds
you'll be able to do that are next to impossible unless you
are an institutional investor or an ultra-high-net-worth
individual (UHNWI) and have a family office at your
disposal.
 MARKET 6

The Market We Are In

Here we are going to define the market we are in, its boundaries, structure,
key characteristics, and then analyze how it is likely to evolve going forward.

Market Boundaries

The market we are in is the market of ultra-short

term (microseconds to hours) professional
trading of cryptocurrencies.
public markets (stocks, futures, options, etc.) and the
crypto markets (cryptocurrencies, tokens, etc.).
This market is a part of a much larger market of investing
in publicly traded assets or claims on assets. This large Here is a diagram1 illustrating the “universe” of public
market can be broken down into investing in traditional markets investing: both traditional and crypto:

INVESTMENT ACTIVE PASSIVE

MANAGEMENT: implied: markets inefficiencies possible implied: markets
are efficient
Trading / Speculation

INVESTMENT HORIZON Long Term Short Term Ultra-short Term

(intraday) GOALS
Diversification
Investment analysis: Fundamental Fundamental Technical Technical Asset allocation
Cost minimization
What is analyzed: Price vs. value Price vs. Expected Expected
forecast change price change price change

Typical strategy: Value/growth Mostly event-driven: Price/volume patterns Price/volume patterns TYPICAL STRATEGY
Micro Momentum Event-driven (news) Indexing
Macro Sentiment «Simple» arbitrage
Quant (statistical) Statistical arbitrage
models Market microstructure
Sentiment driven
Liquidity provision
(market making)

The first divide here is between the active and passive
investment management. It arises from the cornerstone
theoretical question of whether the financial markets are
efficient or not.
If, as was argued by the Nobel prize winner Eugene
Fama2 in 1970, markets indeed are efficient, meaning that
the asset prices always incorporate and reflect all
available information, then one cannot “beat the market”
by actively selecting under- or overpriced assets to buy or
sell.
In this case, one’s goals should be diversification (to
diversify away the risk of the individual assets), asset
allocation (to achieve the desired risk/return profile), and
trading costs minimization (through low turnover). For
most investors, it’d mean investing in a broad-market
index (index fund, to be precise)3.
However, empirical evidence points to the fact that the
financial markets are often far from efficient. Lack of
liquidity, market fragmentation, incomplete information,

1. This diagram and its subsequent analysis heavily draw on the work and thinking of Columbia Business School Value Investing
professors Paul Johnson and Tano Santos
2. https://onlinelibrary.wiley.com/doi/abs/10.1111/j.1540-6261.1970.tb00518.x
3. Buying an index fund can also make sense even if you do not believe in market efficiency – in case you do not have access to active
strategies that can consistently outperform the markets after accounting for all fees and trading costs. In fact, in traditional markets,
buying an index fund would probably be by far the best investment strategy for most of the unsophisticated individual investors
 MARKET 7

and a number of behavioral factors can and regularly do
create market inefficiencies. In fact, Eugene Fama
himself, by the time he got his Nobel prize in 2013 for his
1970s work on efficient markets, has basically proven
their inefficiency4.
Market inefficiencies are even more pronounced
in the nascent crypto markets where they can
often be spotted with a naked eye5, creating
ample opportunities for the active investment
strategies to earn healthy risk-adjusted returns.
have, the reasons they have it, and the conditions that are
necessary to systematically realize it. Professional
trading is dealing with short time horizons – from
microseconds to days and weeks, very rarely months.
Two gravest mistakes many inexperienced
participants in financial markets make are
speculating while thinking that they are investing
and considering themselves professional traders
while clearly lacking the expertise and discipline
to be one.

The key divide within the active investment management At CRYPTTO, we concentrate on the intraday, ultra-short-
category is between the investing per se and trading or term trading. Speed is our home turf, we have been
speculation. perfecting our strategies and technology trading US
equities, options, and futures for over a decade, and
“Investing is buying an asset, or claim on an asset, based
everything we do is optimized for speed by design. We
on an estimate of the fundamental value of the
fall into the professional trading bucket – behind our
underlying asset. The investor buys the asset because he
every strategy is a clear trading thesis that is extensively
feels the price is below the asset’s value or that the price
tested before going into production, and then is re-tested
will increase because the asset’s value is increasing at a
and optimized again before scaling. We manage
rate that will produce an attractive return. The value is
expected profitability and risk of our strategies tightly, we
determined by the cash flows the asset will provide its
do not rely on the market’s mercy as our strategies do
owners over the asset’s useful life”6. Investing necessarily
not make directional bets9.
deals with the longer time horizons (months to years) to
realize its returns.
Ultra-short-Term
(intraday)

Trading or speculating (we believe these terms should be

used interchangeably) “is buying or selling an asset
based solely on expected price changes without regard Casual Professional
to either the asset’s fundamental value or changes in that Trading Type

value”7.
Trading Horizon

Short-Term

Trading / speculating, in turn, could be either professional

or casual / amateur. It is the proliferation of the latter that
is responsible for the often-negative connotation of the
word “speculation”.

Professional traders “have extensive experience, have

developed key insights and judgment, and are systematic
and disciplined in their strategies”8. It means that
professional traders clearly understand the edge they

4. https://www.sciencedirect.com/science/article/pii/0304405X93900235
5. https://data.bitcoinity.org/markets/arbitrage/USD
6, 7, 8. https://www.linkedin.com/pulse/fundamental-value-paul-johnson/
9. Non-directional bets or market-neutrality of our strategies is explained in detail in Chapter 5
 MARKET 8

Market Structure
Now that we have defined the market we are in, let us look at
key market elements and participants and try to outline major
differences between the traditional and crypto markets.

Traditional public markets

By the traditional public markets here we mean one of the
most developed and high-volume asset classes – US equities.
It's structure is defined in part by the legacy of its three-
hundred-years' history and in part by the ever-increasing
regulations and the technological evolution.

ORDER GENERATION Retail Investor

Directed order Non-directed order

ORDER MANAGEMENT Broker-dealer

Directed orders Non-directed orders

20-40% 60-80%

Price discovery, Wholesale

order matching Exchange
market maker
and execution
90% chance you
trade with a market
maker within
the exchange
SETTLEMENT NSCC* Settlement in 3 days
NSCC – National Securities Clearing Corporation

The key gatekeepers in traditional markets are the broker-
dealers. Virtually all traditional public markets orders flow
through them – both from the individual investors and
large institutions. Before the advent of the “discount
brokers” made possible by the rise of the internet, broker-
dealers made their living mainly by charging hefty
transaction fees.
Fees have come down a lot recently, and now the main
source of broker-dealers’ income is the so-called order
flow internalization or, in other words, selling the
“unsophisticated” retail order flow to the large market-
making firms10 who are are happy to pay for the
opportunity to trade against retail market participants.
In fact, almost all non-directed orders11 from individual
investors are sold to the wholesale market makers
12
This leaves the exchanges with the
predominantly “sophisticated” institutional order
flow, making profitable trading there
exponentially more difficult.
Trading competition within the exchanges is so vigorous,
that, sending an order to the exchange, you have not
more than 1 in 10 chances to trade with an actual
person. 9 times out of 10 on the other side of your trade
will be a market maker or a proprietary HFT firm.
Market structure and order flow for the institutional
investors in traditional public markets differ only slightly.
The broker-dealers are still there as the gatekeepers. The
first difference is that there is a lot less internalization of
the order flow happening as the wholesale market

and are matched and executed outside the exchanges. makers are less interested in buying it13.

10. That's what made possible the creation of the famed “zero fees” brokers, the “robinhoods” of the world
11. Orders, for which the sender did not specify execution venue (i.e. NYSE or NASDAQ)
12. Source: Bank of America Merrill Lynch's Market Structure News (March 2018)
13. The explanation of why they do not want to pay for the institutional order flow is beyond the scope of this whitepaper. But, in short, it has to do with the
regulations that oblige to execute the internalized orders at the best market bid or ask (across all US markets) at the moment of internalization. For small
retail orders it means that the market maker will earn the spread minus the internalization fee with virtually zero risk. With the large institutional orders market
makers run into the real risk of market moving against them while they still hold this large order in their inventory.
 MARKET 9

The second difference is that the key issue for the

institutional buyers and sellers is to hide or mask their
intention of posting a large order so that the market
makers/HFTs won’t jump ahead, effectively increasing
institution’s trading costs. This leads to the extensive
employment of execution algorithms, breaking down
orders between exchanges, dark pools etc. by both the
institutions themselves and the brokers at their direction.
Whether they succeed or not in doing this is beyond the
scope of this discussion (hint: not really).

Crypto markets
Market structure and order flow for the institutional
investors in crypto markets is basically the same as for
the retail investors, just the order flow itself is skewed in
favor of the OTC trading desks and away from DEXes.

ORDER GENERATION Retail Investor

Order management, price

discovery, order matching, Centralized DEX / P2P OTC trading desk /
execution and settlement exchanges shapeshift-like

There are 3 major buckets into which the differences Bucket 2 – differences that developed because of the
between the crypto and traditional market structure fall. specific properties of blockchain and crypto technologies
and cannot be recreated in the traditional markets.
Bucket 1 – differences that appeared because the crypto
markets were developed from scratch with no legacy First and foremost, this bucket consists of the
customs and regulations. decentralized exchanges and the ability to securely and
efficiently perform P2P exchange transactions enabled
This bucket includes the absence of the broker-dealers
by the smart contracts.
and the clearing houses.
Decentralized exchanges are almost unsuitable for the
It means that the order management is basically
professional trading at the moment due to lack of speed,
performed by the investors themselves, and the
low liquidity, and high transactions costs. However, we
settlement is done either by the exchanges or by the
clearly see this situation changing as the industry and the
smart contracts in case of DEXes.
technology develops.
It is difficult to say whether it’s a good thing or a bad
We might even say that there is a high chance that the
thing – there are arguments for both. And it is entirely
decentralized exchanges are the future of the
possible that the institutions performing functions similar
cryptocurrency markets.
to the current broker-dealers and the clearing houses will
develop (in fact, they already do). However, it is hard to
imagine that these institutions will ever become so all-
encompassing as it is the case in the traditional markets.
 MARKET
Bucket 3 – differences that exist because the crypto
markets are still in the early stages and which will inevitably
disappear as they develop.
The main difference here is the much smaller share of
the market makers and HFTs in the total transaction
volume. It is hard to estimate with any type of precision,
but our best guess is that still over half of all
transactions on centralized exchanges and around 90%
on DEXes are natural order flow transactions. And if we
disregard instances when the cryptocurrencies are
traded just in order to increase the total trading volume of
a token or an exchange – the natural order flow
transactions’ share is even higher.
Thus, compared to the traditional markets, the
exchange order flow is still relatively
unsophisticated, and the competition levels in
systematic intraday trading are low. However,
that is bound to change.
Future Market Developments
All new markets and industries in free economies follow
pretty much the same path. Once a new market or an
industry is established, companies start moving in. In the
beginning, competition is low and the first movers are
able to earn outsized returns for a while. However, high
returns inevitably attract new entrants, unless there are
firm barriers to entry (which are exceptionally rare,
contrary to most people beliefs ). 14
Increased competition unavoidably drives down
the returns across the industry. New players
continue entering and driving down the returns
until they are no longer above average (above
their cost of capital, to be precise), making new
entry unattractive.
All industries without barriers to entry inescapably end up
with a high level of competition, where only a few most
efficient players remain truly profitable (earning returns
higher than their cost of capital). And true barriers to
entry are very difficult to come by: first mover advantage,
economies of scale, high capital requirements, and even
14. For an excellent discussion of the barriers to entry and competition in general we suggest reading Competition Demystified by Bruce Greenwald, which
has heavily influenced our thinking and the ideas, presented in this chapter.
15. Not to waste time and space here, we invite you to read the Competition Demystified by Bruce Greenwald to clear any doubts you may have
10
proprietary technology – the usual things that come to
mind – are not true barriers to entry, as they can and will
be overcome, provided the expected returns are high
enough15.
That is exactly what has happened with intraday trading
industry in the traditional markets.
Fifteen or so years ago in traditional markets, you would
be able to execute arbitrage opportunities manually –
you just had to type fast. News propagated over minutes
– you had plenty of time to react and still make a
profitable trade. The assets had wider spreads. In a
single-dealer market such as NYSE, you typically were
able to deduce specialist’s intentions and trade along
with him. Index and ETF arbitrage was relatively easy –
both deviated from their fair value regularly.
As the technological evolution made electronic trading
possible, the “easy money” to be made led to the
proliferation of quantitative/algorithmic/high-frequency
trading firms – hundreds if not thousands of them
popped up on the Wall Street.
Ever increasing competition inevitably changed the
market: manual arbitrage opportunities are long gone,
news propagates over tiny fractions of a second, spreads
are minuscule, institutions and market makers mask and
hide their orders, indexes and ETFs hardly ever deviate
from their fair value.
Thus, many of the strategies that you had been able to
execute manually 15 years ago simply do not exist
anymore and for most of what is left you’d need a top-tier
infrastructure, systems, technology and back-office stack
to compete.
But even that might not be enough – exactly as predicted
for the industry with no defendable barriers to entry, only
the most efficient players survive once the competition
catches up. During the recent years, the intraday trading
industry saw a wave of bankruptcies and consolidation.
Now, only a handful of the largest and a small amount of
the most efficient small players are left.
In crypto, the current situation clearly resembles that of
the traditional markets 15 years ago.
 MARKET 11

Professional systematic trading in crypto markets certainly does provide outsized returns at the moment. Just look at how
the news of the recent addition of Zcash to Gemini propagated:

350
ZEC/USD, JUN 19, 2018
340
BITFINEX 30 min
330

320

310

300

290

280

270

260

250

240
11:30 12:00 12:30 13:00 13:30 14:00 14:30 15:00 15:30 16:00 16:30 17:00

This is May 14th, 2018 when Gemini announced the
addition of Zcash to its trading pairs that led to a spike in
Zcash’s trading volume and price. Each candle on the
graph represents a 5 minutes interval. As you can see,
even if you reacted 15 minutes after the announcement
was made, you could still make a 10-20% return from
your trade.
Those timeframes and returns are unthinkable in the
traditional markets. Here is a recent example of equity
traders reacting to Amazon's earnings:

1640

AMZN, APR 26, 2018

1620
Quarterly
earnings
released
1600

1580

1560

1540

1520

The first trades had happened microseconds after the Continuously increasing competition in crypto trading, as
press-release became available and the trading in any other industry, will inevitably drive down average
opportunity was gone in under 3 minutes. returns and, eventually, push the weakest players into
unprofitability. In crypto it will take much less than 15
That is why crypto markets already do and will continue
years - the manual arbitrage in crypto markets is virtually
to attract new entrants.
over already, and it took less than a year.
In crypto, there are even fewer barriers to entry than there
To remain competitive, crypto traders will need to
were in the traditional markets. Moreover, as more and
more professional traditional markets players move to
evolve and seek a totally different level of
crypto once the initial institutional inertia is overcome
expertise, infrastructure, and resources.
and the regulatory environment is clear enough, their
We believe that the CRYPTTO platform provides exactly
skills and experience will provide them with the
that.
immediate advantage.
 TEAM 12

Why We Are the Right

Guys for the Job / Team

Blockchain and crypto are in many ways revolutionary
and disruptive technologies that often benefit from the
efforts of young and fresh development minds,
unencumbered by the previous experiences and
established beliefs.
Our experience in the highly-competitive traditional
markets, the team we've assembled over the years, and
the technology we've built give us a quantifiable edge in
the crypto markets. An edge we will be sharing with the
community through the CRYPTTO platform.

However, crypto trading is not exactly a totally new and
different industry. Traditional markets' trading technology
stack, research tools, and frameworks are directly
applicable to crypto. Therefore, deep understanding of
and access to them provide a clear competitive
advantage in these nascent markets.
Our profitable track record through different traditional
markets regimes testifies to our ability to keep our
products competitive and future-proof, regardless of
market and technological advancements.
CRYPTTO is a completely separate business unit but it
draws extensively on ATTO's existing platform and

The core team behind CRYPTTO has been at the research and development capabilities.

forefront of quantitative trading for well over a
decade.
We are the team behind ATTO Trading Technologies –
a technology and science-driven high-frequency
quantitative trading firm that researches, develops and
operates a portfolio of modern quantitative trading
strategies across several asset classes (equities, futures,
options).
Team ATTO is a team of around 20 experienced
engineers, traders, and data scientists and over half of
them are currently working on the CRYPTTO platform
development.
We are also in the active search of C++ developers,
quantitative researchers and data scientists16 to
complement and expand the CRYPTTO team as we are
preparing to scale our strategies and platform.

Trading Technologies

ATTO was founded in 2010 and has offices in New York

and Eastern Europe. Our founders have many years of
trading experience, having started in the financial
markets in the turn of the century. We remain competitive
by using our proprietary ultra-low-latency trading
platform, world-class research infrastructure, and our in-
depth knowledge of the modern electronic markets
microstructure.

16. If you are one, please, apply at hr@cryptto.io

 TEAM
CRYPTTO Team
Denis Popov
Founder and CEO
VIEW PROFILE
Denis is a veteran in quantitative high-
frequency trading. Having started his
career in 1999 as a buy-side proprietary trader in New
York, Denis had been one of the pioneers of automated
news-driven trading strategies in the US equities
markets.
In 2005 Denis had founded Denex Trading that operated
a portfolio of event-driven strategies and in 2006
launched its first fully-automated algorithmic trading
strategies in US equities. Denex Trading served as a
foundation on which ATTO Trading was founded in 2010.
While at ATTO, Denis spearheaded the development of its
ultra-low-latency trading platform along with the
infrastructure that supports the full cycle of quantitative
strategies development (data collection and
management, prototyping, simulation, visualization, risk
management and post-trade analysis).
The platform operates on collocated servers in all US
equity and futures data centers supporting lowest
latency native protocols for market data and execution
and is highly optimized from the software and hardware
(FPGA) perspectives.
This platform allowed the development of multiple
profitable trading strategies and now serves as the basis
for the CRYPTTO platform development.
Denis is a graduate of King's College (Pennsylvania),
where he received his BSc in Finance and Computer
Science in 1999.
Gene Zeltsman
Co-founder/CTO/Systems Architect
VIEW PROFILE
Gene has over 20 years of capital
markets software and hardware
engineering experience. Last 12 years he specializes in
high-frequency trading strategies and platform
development.
13
Gene has started his professional career in 1994 and for
12 years had worked in various senior engineering roles
for a number of first-tier financial institutions and
technology consultancies in New York (J.P. Morgan,
Chase Manhattan, and ABN AMRO among others).
After a brief stint as a full-time poker player, Gene had
joined Denis at Denex Trading and, later, at ATTO, where
he was responsible for all aspects of the overall
technology vision, trading platform development and
operations, trading strategies design and
implementation, working directly with the quants and the
traders.
While at ATTO, Gene assembled and trained a team of
developers that are able to deliver highly competitive
product under tight time constraints.
Gene has graduated in Computer Science from NYU in
1993.
Maksim Hramadtsou
Co-founder and COO
VIEW PROFILE
Before joining CRYPTTO, Maksim has
been managing a USD 500 mln full-
cycle real estate investment and development company
with 700 employees, having become its CEO at the age of
29.
Maksim's most prominent real estate project is the full
redevelopment of the iconic TSUM department store in
Kyiv, Ukraine, opened in 2016, which took 5 years and
USD 200 mln to complete.
Maksim in an experienced public markets investor and a
proponent of the value investing philosophy.
At CRYPTTO Maksim oversees the go-to-market strategy
and day-to-day operations, including all the ICO-related
issues.
Maksim holds a joint MBA degree from the Columbia and
London Business Schools and an MA in Political
Economy from the Central European University in
Budapest.

Talha Chaundry
Head of Trading /Chief Risk Officer
VIEW PROFILE
Talha has over 15 years of experience in trading and risk
management. Before joining ATTO and, later, CRYPTTO,
Talha served as Managing Director and Head of Trading
of Sun Trading – a large high-frequency trading firm.
At CRYPTTO, Talha oversees trading strategies
development and operation and is responsible for risk
management.
Talha holds an MBA in Finance and Information Systems
from McGill University in Toronto and was trained as an
Aeronautical Engineer.
He holds FINRA licenses series 4, 7 and 24 (Associated
Person). Talha teaches Quantitative Trading to MBA
students at Rutgers Business School.
Avi Kohn
Senior Quantitative Researcher / Trader –
Event-driven Strategies
VIEW PROFILE
Avi is responsible for the development and operation of
our event-driven trading strategies utilizing Natural
Language Processing algorithms.
Avi is an experienced developer and high-frequency
trader. Before ATTO and CRYPTTO, he has worked as a
proprietary high-frequency trader at Summit Securities
and the CSA Group.
Avi is a trained Electrical and Electronics Engineer with
degrees from the City College of New York and Yeshiva
University.
Eugen Kushnerov
Senior Quantitative Researcher / Trader
VIEW PROFILE
Eugen is responsible for research,
development, and operation of our quantitative trading
strategies.
Eugen has 9 years of experience in quantitative
strategies design and development and holds a Ph.D. in
Mechanical Engineering.
14
Roman Melnyk
Quantitative Researcher
VIEW PROFILE
Roman is researching and developing our
quantitative trading strategies.
Roman holds an MSc in Theoretical and Applied
Statistics from Lviv National University.
Guangyu (Simon) Gu
Junior Quantitative Researcher
VIEW PROFILE
Simon is working on research and
development of our quantitative trading strategies.
Simon holds a Master in Quantitative Finance degree
from Rutgers Business School and a BA in Finance from
Sichuan University.
Alex Evsenev
Senior Low-Latency C++ Developer
VIEW PROFILE
Alex is a senior software engineer with 15
years of experience and a strong background in
cybersecurity and networking. For the last 7 years, Alex
has been developing ATTO's ultra-low-latency trading
platform.
Denis Romanchuk
C++ Developer
Denis has 5+ years of C/C++ software
engineering experience. He holds a BA in
Electrical Engineering from Kyiv Polytechnic University.
Ivan Ryzhkov
Development and Operations Engineer
VIEW PROFILE
Ivan has over 10 years of professional
experience. Before ATTO and CRYPTTO he has done
work for Deutsche Bank, Google, and Barclays Capital.
Ivan is supporting operations of our strategies and
platform.

Veniamin Zolotukhin
Front-end Developer, UI designer
VIEW PROFILE
Veniamin has 19 years of experience in web
design and development. At CRYPTTO he is responsible
for creating UI and building the platform's front-end.
Natalya Stepanenko
Director of Talent Management
VIEW PROFILE
Natalya has 15 years of experience in talent
management and development.
At ATTO and CRYPTTO she is responsible for the talent
search, development, and retainment.
15
Our Advisors
Craig Robertson
VIEW PROFILE
Currently, Craig is the Head of US Product
and Listed Derivatives at Société Générale – one of the
leading banking and financial services groups with a
market capitalization of over USD 30 bln.
Craig has over a decade of experience in quantitative
high-frequency trading, having served as the Managing
Director of Coastal Management (a quantitative hedge
fund), VP at Nomura Securities, and AVP at Barclays
Capital.
Craig is advising us on trading and technology.
Marina Chernyshevich
VIEW PROFILE
Marina is a computational linguistics expert
with 12 years of experience in the field.
Marina is a Ph.D. candidate in Mathematical and Applied
Linguistics and currently works as a Principal Linguist
Developer for IHS Markit - one of the largest global
information providers for the financial markets with a
USD 20 bln market cap.
Marina advises us on natural language processing (NLP)
and sentiment analysis.
 PRODUCT
Our Product
CRYPTTO is developing a Quantitative High-Frequency
Trading Platform that will provide access to a suite of
products that were previously available only to HFT
hedge funds.
Our suite of products will include fully-automated
market-neutral trading strategies, intelligent
execution algorithms, and proprietary trading
signals with manual or semi-automated
execution.
Before we dive into the platform's functionality, let's
clarify some of the terms we use to describe it.
Our platform is focused on quantitative high-frequency
trading or, more precisely, quantitative algorithmic high-
frequency trading. If you try googling these terms you'll
get overwhelmed by the often-confusing definitions, but,
in simple terms:
quantitative implies creation of mathematical models to
identify trading opportunities;
algorithmic implies that the actual trading is performed by
a set of programmed instructions (an algorithm) and not
a human trader;
and high-frequency means that our strategies will be
among the fastest to react to new information, be it
trades, quotes or news.
Here is a simple diagram that sums up the relation of
those 3 terms:
Quantitative
Trading
Algorithmic
Trading
HFT
CRYPTTO platform is the inner circle on this diagram.
16
Development of the high-frequency trading platform has
two major components: technological and scientific:
HFT Platform
Technology Science
Connectivity Strategies
Networking Signals
Back-office Algorithms
technological stack
HFT connectivity and networking have several
commoditized elements (that can be purchased from a
specialized provider), however, it's the integration of
those elements and the back-office technological stack
that are proprietary and in the large part define future
results.
The technology side of our platform includes:
• Distributed server infrastructure with co-location
where possible
• Optimized communication channels and networking
protocols
• Market data receiving and recording module
• Back- and forward-testing and simulation module
• Execution module with ultra-fast trading API
connected to all major exchanges
• Live trading analysis and risk-management module
CRYPTTO's technology stack builds heavily on the
solutions and capabilities developed and optimized by
ATTO for its proprietary trading in the traditional markets
in the course of the last 8 years.
CRYPTTO platform's scientific (and user-facing)
component includes:
• fully-automated market-neutral trading strategies;
• execution algorithms that aim to reduce trading costs
by achieving passive liquidity and improve execution
prices by randomizing orders;
• trading signals with manual or semi-automated
execution based on market data, news and sentiment,
and on-chain activity analysis.
Here is their detailed description.
 PRODUCT
I. Fully-Automated Trading
Strategies
Users of our platform will be able to employ a number of
fully-automated strategies that will be trading in their
crypto exchange accounts on their behalf.
All the strategies available at platform launch will
be market-neutral, meaning that they won't be
making any directional bets and, consequently,
market moves up or down won't affect their
profitability.
Rather, their performance might increase in times of the
drastic market movements because the accompanying
volatility is the main source of our strategies' trading
opportunities.
As the platform develops, we will add several event-driven
strategies that might have some short-term directional
exposure, but the underlying signals will not be correlated
with the market and the expected profitability in almost
all cases will be greater than the possible market move in
other direction17.
All our strategies will be extensively back-tested and will
be validated in production using own capital prior to
becoming available on the platform.
Our “first batch” of strategies will include strategies of
two main types: structural arbitrage18 and statistical
arbitrage. As the next step, we will add event-driven
strategies and strategies, based on the on-chain data
analysis.
We will constantly keep expanding the number, scale and
execution efficiency of the fully-automated strategies
available on our platform.
Structural arbitrage strategies
“Arbitrage is the simultaneous purchase and sale of an
asset to profit from an imbalance in the price. It is a trade
that profits by exploiting the price differences of identical
or similar financial instruments on different markets or in
different forms. Arbitrage exists as a result of market
inefficiencies and would therefore not exist if all markets
were perfectly efficient”19.
17. An example will be a positive breaking news event in one coin, while the market generally is heading down
18. Not to be confused with the capital structure arbitrage
19. https://www.investopedia.com/terms/a/arbitrage.asp
20. This section draws heavily on the analysis by Manoj Narang in his firm's letter to the SEC on April 21, 2010.
17
Structural arbitrage strategies can be applied to all
fungible (interchangeable) assets. Fungibility for these
purposes can be linear (e.g. BTC on two different
exchanges) or non-linear (e.g. a basket of stocks
comprising an index vs. futures on the index vs. ETF
tracking the index).
Our “first batch” of strategies will include inter-exchange
arbitrage of a single pair of instruments (e.g. BTC/USD
between GDAX and Bitfinex) and triangular intra-
exchange arbitrage (e.g. BTC/ETH/USD on GDAX),
scaled across multiple instruments and exchanges.
As the next step, we will add several other structural
arbitrage strategy types, such as derivatives arbitrage
(takes advantage of the difference between the known
future price of the derivative and the underlying) and
index arbitrage (exploits price difference between the
index and the basket of its components).
We also have several more complex structural arbitrage
strategies in development, which we'd rather not discuss
in greater detail in this document due to their proprietary
nature.
Structural arbitrage strategies are a very attractive
source of returns due the very high winning trades ratio,
and consequently, very low risk. That, obviously, attracts
a lot of market players competing for them. Our edge is
well-developed strategies, the ultra-low latency of our
platform, and our intelligent execution algorithms (more
on those further in this chapter).
Statistical arbitrage strategies
Such strategies are based on the fact that many assets
that are traded on public markets, including
cryptocurrencies, are correlated20.
The correlation might be either structural, e.g. between
the index and its components, or statistical, that arises
because the prices of the assets are driven by general or
systematic factors (economic growth, adoption,
regulatory framework etc.). As there are fewer such
factors that form the prices of the crypto assets,
correlations in crypto markers are higher.
 PRODUCT
Structural correlations tend to be strong, steady and
robust, and are “the domain” of the structural arbitrage
strategies, described above.
Statistical correlations, on the other hand, tend to be less
pronounced, time-varying and non-stationary. They tend
to exist more often and persist for longer than the
structural correlations that are competed away by the
“simple” arbitrage strategies.
There are many off-the-shelf statistical tools (e.g.
libraries in Python and R) available and many platforms
make creating StatArb strategies seem very easy. The
reality, however, is totally different – to create and
maintain profitable StatArb strategies one must possess
deep understanding of the market structure,
mathematical tools and methods and have enough
experience to timely recognize market changes and
adapt the strategies to them.
Statistical arbitrage strategies are created by mixing a
variety of underlying predictive signals based on time-
series analysis of market data and are characterized by
the forecasts of each individual trade expected return
without making any bets on the general market direction.
Our statistical arbitrage strategies make a lot of small
trades, which are profitable more than 50% of the time,
and let the laws of statistics work its magic: with the
sufficiently large number of trades the “over 50%”
individual trade winning percentage translates into the
daily and weekly strategy winning percentage
approaching 99.9%. It means that you will be profitable
every day despite having only 51-52% of the individual
winning trades.
A typical opportunities and trades profile of our StatArb
strategies follows the normal distribution and looks
something like this:
Large negative
returns are
Small returns
are abundant
Large positive
returns are
infrequent infrequent
We are planning to have a number of StatArb strategies
available on our platform and expect to be continuously
improving them as the market evolves.
21. For a nice introduction to the exciting world of NLP, please, check the article by our advisor Marina Chernyshevich:
https://medium.com/cryptto-io/nlp-what-is-natural-language-processing-75a80c32d19e
22. Proof and examples are available upon signing an NDA (Non-Disclosure Afreement)
18
Event-driven strategies
High-frequency event-driven strategies seek to track
different types of events that can influence prices of the
crypto assets, understand their meaning utilizing
proprietary algorithms, predict the likely direction of the
post-event short-term price movement and act on this
information before the other market participants.
In most cases, the information about the events is
propagated through the news that can have a variety of
non-uniform and not structured sources. Discovering,
monitoring, and capturing those sources is a critical part
of any event-based trading strategy.
News/events could be more (listings/delistings, forks,
regulatory action) or less (founder selling his stake)
obvious, requiring intelligent event detection techniques.
Trading experience, quality data sets, and rigorous back-
testing methods are needed to discover the relationships
between news events and moves in the specific market
instruments.
News analysis is mostly done utilizing various natural
language processing (NLP) techniques, aided by machine
learning (ML)21.
The news isn't required to follow any predefined format;
hence, automated interpretation of the news requires
flexible but stable and fast interpreting algorithms.
Price changes in the market occur quickly, requiring fast
response times. The profit potential of a news trade
decreases exponentially from the time of release.
News releases cause volatile price changes that
generally change the regime of the intraday trading. That
is why fast and intelligent execution is as critical to the
profitability of the strategy as the proper and timely event
identification.
At CRYPTTO, we have deep expertise in news-based
trading. Our founder was on the forefront of the
automated news trading in the noughties, and the ATTO
trading platform capabilities at the moment allow us to
be literally the first in the world to react to various highly
competitive news events in the traditional markets, such
as quarterly earnings releases, regulatory filings or
tweets from the market-moving twitter accounts22.
 PRODUCT
Rest assured, our event-driven strategies in crypto
markets will create a lot of value for the users of our
platform.
Strategies, based on the on-chain
data analysis
These trading strategies, despite having unique
underlying data, will employ the well-tested techniques
used for market data analysis in the traditional markets.
At the moment we are looking at the blockchain data at
two main angles:
1) Trying to clean the data from noise (such as mixer
transactions) and establish statistical relationships
that have meaningful predictive power on short time
horizons to serve as a basis of a trading strategy.
This approach at its core is very similar to the
methods we employ to develop our statistical
arbitrage strategies.
Our early results are very encouraging, and, as our
algorithms get more data to analyze and become
progressively better at it, we expect this process to
result in a number of robust strategies;
2) Trying to “map” the on-chain space by identifying
exchange wallets, ICOs, storages, and other
significant on-chain actors and build models and
algorithms that will allow the creation of event-driven
trading strategies based on the significant on-chain
movements/transactions.
Despite most blockchains being inherently transparent,
the data sets are quite “noisy” and, thus, difficult to
analyze. The rise of the numerous different blockchains
and, especially, off-chain (i.e. BTC Lightning Network) and
cross-chain protocols (Cosmos, PolkaDot) further
complicates the analysis.
However, our researchers remain on top of it, and
CRYPTTO is very well positioned to take advantage of
these opportunities and make them available to our
platform users.
Additional types of trading
strategies
There are several additional types of fully-automated
strategies that we are working on. Namely, strategies
based on market microstructure analysis (making ultra-
short-term predictions by analyzing exchange order
19
books and trades in real time), and market-making
strategies (aimed at earning the spread by providing
consistent liquidity to market participants).
These strategies are highly valuable as they have high
expected profitability while accommodating sizable
trading capital, and we have a successful track record of
developing them in the traditional markets.
However, unlike the four other types of strategies that we
plan to offer on the platform, these strategies would be
more difficult to implement on multiple accounts due to
latency constraints and low ratio of filled to posted orders
due to their passive nature. Rather, they must be run
through a single account.
We are actively working to find a clear path to adding this
type of trading (through a single account) to our platform
within the utility token framework.
Though we are very hopeful that such regulations will be
developed in the foreseeable future in several
jurisdictions, at the moment we are unable to firmly
commit to providing this type of trading on our public
platform.
Our Trading Strategies Development
Process
All our strategies are developed using a robust, tried-and-
tested process. In very simple terms, this process has
seven main stages:
1. Conception / Prototype
Main trading “idea” is defined and strategy's logic is
researched and prototyped.
2. Back-testing
The strategy thesis is tested for viability against the
historical trade data using a high-level programming
language (we mostly use Python for these purposes).
3. Development
The strategy is implemented in C++ programming
language and is ready to run in the production
environment.
4. Simulation
The strategy is tested in the simulation engine on
recorded market data. Our simulation environment is
designed to properly account for system latencies,
networking latencies to exchanges, each exchange
matching engine speed and fill logic and queue
position.
 PRODUCT
That is why our simulation engine provides around
90%+ accuracy of results compared to the production
environment.
5. Production testing
The strategy is tested against live trading data to
ensure that its code behaves as expected.
6. Production
The strategy is “live” in the production environment
generating real profits and losses.
7. Optimization And Scaling
Performance is tracked and analyzed, providing
essential feedback for parameter adjustments to
optimize performance. The strategy is expanded in
terms of the instruments and markets (trading pairs
and exchanges) to fully exploit available trading
opportunities.
This process, of course, is continuous and iterative.
Risk Management
Having successfully traded for almost two decades, risk
management is the cornerstone of everything that we do.
Our platform has a robust risk management system that
minimizes possible risks at the strategy development
stage and continuously monitors and controls all live
trading aspects.
Generally, there are four main types of risks that the
users of our fully-automated strategies will face:
1. Counterparty risk
The biggest risk is an exchange becoming insolvent
due to a variety of reasons. This problem is partially
mitigated by the assets being held at many
exchanges.
2. Intrusion (unauthorized access) risk
We utilize industry's best practices to achieve highest
level of the platform security and will conduct regular
audits by the leading cybersecurity firms.
3. Technology risk
We are building CRYPTTO upon a mature trading
platform with stringent system and strategy deploy
and version control process.
4. Strategy behavior risk
We have a pre- and post-trade risk management
system in place to prevent unexpected losses.
23. Liquidity meaning high traded volume, where one does not have to worry about the market impact (moving the price) by posting one's order.
20
II. Intelligent Execution Algorithms
Execution logic and speed can represent the difference
between trading profitably and losing money and
achieving 100% of the desired position or missing the
trade. The more you trade, the more important it
becomes.
What is an execution algorithm?
When you (or a computer in case you are utilizing our
automated strategies) decide to buy or sell a crypto asset
you need to decide HOW EXACTLY you want to do it and
give a set of specific instructions to the exchange or your
trading platform that will perform an actual trade
according to them.
This set of specific instructions of HOW you want to buy
or sell a crypto asset is an execution algorithm.
Execution algorithms are created with the goal of
optimizing one or more trade parameters (time, price or
volume). By choosing a specific execution algorithm you
are deciding WHAT you want to optimize and HOW you
want to optimize it – meaning which tradeoffs you are
willing to make and what level of exposure to what risks
you are willing to accept to achieve the best possible
result within those constraints.
Simple directed orders
Currently, on crypto exchanges, most traders submit
simple buy/sell orders that are also known as “directed
orders” where the trader specifies the exchange on which
the order should be placed and defines basic order
parameters by choosing the order type, such as market or
limit orders.
In case of the market order, you are optimizing for the
best possible execution time for a given volume,
regardless of price. In case of the limit order, you are
optimizing for a specific execution price, while accepting
the risk of not achieving the desired volume.
Simple directed orders are sufficient for the needs of
“retail” trading – infrequent buying or selling of the
relatively small positions or for larger positions in the very
liquid23 instruments.
However, if one of the above conditions does not hold –
your trading frequency (turnover) increases, your
 PRODUCT
positions become large or the instruments you trade less
liquid – with the simple order types your trading costs
begin to rise and/or your execution price becomes
suboptimal. In other words – you start losing money on
execution.
Classic execution algorithms
The negative effects of using simple directed orders for
large and/or frequent trades are explained by the direct
price impact of your orders and the indirect impact of the
informational advantage that your posted orders give to
other market participants.
Direct price impact appears due to the fact that more
often than not there is a limited amount of liquidity at the
certain price levels or in other words there is simply not
enough market participants willing to sell or buy the
assets that you want to exchange at the price and in a
timeframe that you desire.
This effect is aggravated by the advantage that the other
(very fast) market participants gain from discovering your
posted large buy or sell orders and posting their orders in
front of you. They are not doing anything illegal – they
are simply able to predict ultra-short-term market
movements analyzing the publicly available order book,
develop a corresponding strategy and execute their
orders in a fraction of a second.
Consequently, institutional investors, large traders and
other professional market participants utilize a number of
execution algorithms that are aimed at “achieving the
best possible execution price based on your chosen
strategy, while minimizing market impact and preventing
information leakage for your large orders”24.
The most popular and frequently used among such
algorithms are VWAP and TWAP.
VWAP (volume-weighted average price) algorithm is slicing
your large order into smaller pieces and trying to execute
trades close to the volume-weighted average price during
your desired time frame, while TWAP is aiming at
achieving time-weighted average execution price. There are
also many other similarly organized execution algos,
such as PVOL (percentage of volume), etc.
They are all relatively good at minimizing direct market
price impact but are much less so at hiding the
24. http://www.nasdaqomx.com/digitalAssets/95/95590_execution-algos-member-presentation-october-2014.pdf
21
seller/buyer intentions. By design, they have rigid
constraints that make them predictable, hence,
monetizable.
They also share a common inherent disadvantage that
leads to suboptimal results in terms of the total trading
costs – their execution is active, meaning they mostly act
as liquidity takers, not its providers. That means higher
direct trading costs (taker vs. maker fee) and indirect costs
(the bid-ask spread). That's a point of a percent on a
single trade but give it a large enough order size and/or
high position turnover and it starts to add up. To a lot.
CRYPTTO Intelligent Execution
Algorithms
Over the course of over a decade of high-frequency
trading in traditional asset classes we've only learned to
identify and predict traditional execution algos, but also
created a suite of proprietary execution algorithms that
do not have those disadvantages.
Our intelligent execution algorithms are, basically,
intraday high-frequency trading strategies in their own
right. They utilize machine learning and market-making
techniques to achieve passive liquidity as often as
possible, meaning that they aim to get your orders filled
passively rather than actively filling somebody else's
orders. While doing so, they randomize your orders sent
to market, making it virtually impossible for others to
discover your true intentions.
The result is a) lower information leakage = less
slippage/better execution prices and b) drastically lower
trading costs (up to 50%) due to lower maker fees and
capturing the bid-ask spread.
The full suite of our intelligent execution algorithms will
be available to the users of our platform.
Our execution algorithms not only provide direct value to
traders as a stand-alone product, they also power many
of our fully-automated strategies. Lower slippage and
lower trading costs that they provide mean more trading
opportunities that our strategies can take advantage of.
 PRODUCT 22

That increases our strategies' profitability and helps them

III. Trading Signals And Alerts.
to remain competitive.
CRYPTTO's main USP25, as we have stated earlier, is our
Our intelligent execution algorithms are an integral part fully-automated strategies and intelligent execution
of the competitive edge of our platform. algorithms. Their public availability is truly unique26 and
that's where we create the most value for our users.

A separate question is why the relatively-easy-to-take- However, we feel that we can create additional value by
advantage-of VWAP- and TWAP-type algorithms are also providing trading signals and alerts to our users.
so wildly used by the major institutions around the
A comprehensive set of screening tools, alerts and
world.
signals not only allows day traders to quickly get a feel
The answer lies in the distribution of the expected about what's going on in the market (what is happening,
algorithm results. They look something like this:
what is moving, and why it is moving), but can also be a
source of numerous profitable opportunities, especially,
when coupled with our execution platform.
VWAP and
TWAP-type Intelligent
exec. algos Our users will have an extensive choice of various
technical, news and sentiment-based, and on-chain data-
based signals, alerts, and indicators.

They will be able to execute trades manually or in a semi-

automated (gray box) mode in their accounts on all major
Intelligent execution algorithms have a higher average
crypto exchanges utilizing a wide set of our execution
expected profitability but also longer tails (i.e. wider
distribution of actual results vs. target), meaning that algorithms.
they have a higher probability of any single order
deviating from the mean. Despite the overall Technical signals and indicators
profitability being higher on all customer trades, an
execution broker does not want to put himself in a There exists a huge variety of technical signals and
position to have to explain to any of his customers indicators that are based on some form of analysis of the
(institutional money managers) that his
underlying price and volume data.
underperformance was caused by the known
statistical probability. That's usually a hard sell.
CRYPTTO platform will provide technical indicators of
four main types27:

1) Trend Indicators that are designed to show the trend

or direction of the asset (up/down/sideways). Mostly,
these are different types of moving averages: simple,
cumulative, weighted, exponential, MACD and others

2) Momentum Indicators that measure the speed at

which the price of an asset is moving in one direction.
Examples include relative strength index (RSI),
stochastic oscillator, commodity channel index (CCI)
among others

3) Volatility Indicators, measuring the relative rate at

which an asset's price is moving up or down. These
include Bollinger bands, average true range, volatility
channels and many others

25. https://en.wikipedia.org/wiki/Unique_selling_proposition
26. For the discussion of the competitive environment, please, see the next chapter
27. Kudos to quantshare.com for the robust classification framework
 PRODUCT 23

4) Volume Indicators that signal abnormal volume

surges/pullbacks: money flow index, ease of
movement, on-balance volume, etc.
Users will be able to act on a single signal or on any
combination of them by creating trading rules. It will also
be possible to combine several technical indicators and
momentum or on-chain data signals to increase the
probability of the profitable trades.
News and sentiment-based signals
News-based signals
These signals are an “extension” of our fully-automated
event-driven strategies. They utilize natural language
processing algorithms and machine learning, interpret a
news story, and issue a “buy” or a “sell” alert in a fraction
of a second after the news is published.
Sentiment-based signals and alerts
Our algorithms will be continuously monitoring various
media and social platforms (from Twitter and Telegram
to Reddit and Bitcointalk) to measure sentiment
regarding the particular crypto assets and crypto market
in general.
On-chain data-based signals
In addition to our fully-automated strategies, the analysis
of the on-chain data that we perform enables us to
provide a number of interesting signals and indicators.
There will be two main types of the on-chain data-based
indicators on our platform.
The first type explores different metrics of the on-chain
transactions and wallet creation (e.g. volume, speed,
dispersion) both in absolute and relative terms. This type
of indicators in many ways resembles and draws upon
the technical ones described above.
The second type looks at large transactions and known
wallets movements (aka “whale watching”) based on the
on-chain data mapping described previously. The “usual
suspects” are exchanges, ICOs, funds, pools, anonymous
whales, trustees, etc.
Our early testing (and common sense) shows that the on-
chain data-based indicators prove to be especially useful
when combined with the social sentiment data on the
particular asset – a distinct opportunity that our
platform will provide.

Our sentiment-based signals and indicators are based on

some measure of quantity (e.g. # of tweets), quality (i.e. +
or - sentiment) or velocity (i.e. quantity/time) of the
sentiment data or a combination thereof.

All data obtained from the social media “parsing” is first

cleaned from the noise and then compared to our ever-
growing historical data archive of the sentiment and its
influence on the asset prices, looking for predictive
patterns.

Users would be able to automatically open positions for

the signals where reaction speed is essential through our
semi-automated trading option.
 PRODUCT 24

CRYPTTO Platform Design Overview

Front-end
CRYPTTO trading platform will have 3 «levels»:
A(atto) Level F(femto) Level P(pico) Level
A (atto), F (femto), and P (pico). They will differ
in functionality and access requirements. Fully-automated strategies

The most prominent feature that will be Intelligent execution algorithms

available exclusively to the users of the A

Basic execution algorithms
(atto) level of our platform is our fully-
automated market-neutral trading strategies. Trading signals and alerts

This is where we create the most value for our Semi-automated execution
users.
Manual execution
Whereas other platform levels will be available
All major exchanges supported
to unlimited numbers of users, membership in
the top A (atto) level will be limited. We expect Number of users Limited ∞ ∞

a lot of demand and fierce competition for Access

28 Subscription + Subscription Subscription
dynamic staking + staking
those spots, that is why we will introduce
dynamic staking requirements of our TTO CRYPTTO platform levels comparison
tokens, i.e. access auctions.

Key features of the F (femto) level is the opportunity to

utilize our intelligent execution algorithms for your own
orders and semi-automated execution (automatic
position opening) for our trading signals and alerts.

Intelligent execution algorithms allow you to improve

execution prices and meaningfully reduce your cost of
trading. This feature will be especially useful for large
and/or frequent traders. Semi-automated execution
allows you to react competitively (i.e. very fast) to our
signals and alerts to capture the most value.

We plan to allow an unlimited number of users for this

level.

P (pico) level of our platform will provide full access to all

our trading signals and alerts with manual execution and
an ability to compare prices and post buy or sell orders
on all the major exchanges through a single interface. In
case you are buying an asset, our execution algorithms
could also automatically parse all the exchanges and
execute at the lowest price available among the
exchanges you have accounts on.

28. All access payments are done solely in our TTO tokens. For the full discussion of platform access requirements
and TTO tokenomics, please, check the Tokenomics chapter of the whitepaper
 PRODUCT 25

What's Under The Hood

Here is the high-level block diagram of our platform
internal design:

News and Strategies

sentiment & Signals
analysis engine development
environment
SECURITY LAYER

On-chain Platform
Simulation & System* Users
data recording back-testing

FULL RECORDING

SECURITY LAYER
and analysis parameters

ACCESS / PERMISSIONS LAYER

engine
module

Market data Strategies,

processing signals, alerts WEB
and storage production GUI
module

Risk Execution Orders

management module
module
Market Trading API
data permissions

Pre-trade risk
management Trading API
permissions

FULL RECORDING *Choice of strategies,

Buy/Sell signals, trading rules,
SECURITY LAYER orders limits, etc.

Crypto Exchanges

In many ways it is self-explanatory, however, several

things are still worth pointing out:

1) Security is at the heart of our system design. 3) Our strategies are meticulously back-tested before
All external communications of the platform being put into production and trade our own capital
(platform-users and platform-exchanges) are done for a while before becoming available to our users.
over encrypted channels and are fully recorded. There
Our comprehensive risk management system monitors
are in fact numerous security levels built into our
trading in real-time to prevent erroneous trades and to
platform, but we won't dive deeply into that here as it
flag any abnormal behavior of our platform or your own
is a very sensitive area.
exchange accounts. If any abnormal behavior is detected,
All our system's components are designed with
the trading is momentarily shut down to minimize
redundancy in mind, so that the system will continue
possible damage and our Risk Management team that
to function should some part of it fail;
monitors trading 24/7 will notify you promptly.
2) We never receive access to your exchange account
other that permissions to post buy and sell orders on
your behalf using the exchange API key that you
provide. You never transfer any funds to us, we do not
receive your account credentials (login/password),
and require that you disable the withdrawal via API
feature to minimize chances of your funds being at
risk;
 COMPETITION
Competitive Landscape
CRYPTTO, as a fintech company, will operate in three
distinct market segments:
1. Fully-automated short-term trading strategies;
2. Execution tools (i.e. execution algorithms and post-
trade data-driven analysis tools);
3. Trading signals;
Therefore, we will review the competitive landscape in
each segment independently.
I.Fully-automated trading strategies
It is important to understand that in this segment
CRYPTTO faces two kinds of competition and
competitive threats:
1) competition for profitable trading opportunities;
2) competition for customers/platform users.
At the core of our competitive strategy is our full focus on
the first kind of competition. Ultimately, customers of all
trading strategies and tools providers are looking for one
thing and one thing only – trading profits. Hence,
the only possible competitive advantage is the
consistent profitability of our products. There is
no other way to win this competition.
Competition for profitable trading
opportunities
The competition in crypto trading is increasing every day.
Long gone are the days of manual arbitrage between the
exchanges.
Though the public information about the key market
players is very limited, competition intensity can be easily
measured by observing the spreads of the most liquid
instruments and quantifiable price inefficiencies (e.g.
differences in BTC prices on different exchanges).
The bid-ask spreads of the most liquid instruments have
decreased rapidly in the last 6-9 months, so did the price
inefficiencies.
This means that more and more professional players are
entering the market and arbitraging away the
inefficiencies. This process is well under way but crypto
markets are still very far from the efficiency of the
26
traditional asset classes like equities, bonds, futures,
options, and FX.
Crypto markets still provide a wealth of trading
opportunities, but to continue to take advantage of them
now requires serious scientific and technological
prowess and those requirements will continuously
increase.
As the result, the competitive landscape of crypto trading
will change dramatically in the coming months and
years. The overarching trend will be the continuous
professionalization of the space, with most of the players
that enjoyed the early crypto markets benefits being
replaced by the professional trading firms with extensive
traditional markets experience and know-how.
Thus, our actual competitors are our “colleagues” – HFT
firms, hedge funds and market makers.
Most of the traditional markets' HFT firms and market
makers are either already present in the crypto markets
or are actively looking at entering this asset class in the
near future.
Their reasoning is clear: their expertise and technology
are directly applicable in crypto and the opportunities
that the crypto markets present have disappeared from
the traditional ones a long time ago. It's exactly the same
logic that got us into crypto.
Most of them operate in crypto markets on a much
smaller scale than they do in traditional asset classes.
Reasons holding them back include regulatory
uncertainty, security concerns, and counterparty risks
among others. However, as long as the potential returns
are high, laws of the market economy will drive their
continuous expansion.
This group represents our single biggest threat.
However, we have been successfully competing with
them in the traditional market for over a decade. Thus,
we have a high degree of confidence in our ability to
maintain our edge and to keep the suite of strategies we
offer competitive (i.e. profitable) for a long time to come.
We compete with them viciously for the available trading
opportunities, but we do not compete with them for the
platform users/customers as their strategies and trading
tools are not available to the general public.
 COMPETITION
Competition for customers
There are a lot of companies out there that use very
similar and often-confusing terms apparatus (e.g.
strategies, algorithms, arbitrage, etc.) in their marketing.
Thus, it is easy to form a false impression that what
those companies offer is identical to CRYPTTO. However,
as always, the devil is in the details.
Let's try to classify and describe types of companies that
offer automated trading tools:
1) Crypto algo / bot providers
The initial inefficiency of the crypto markets and, more
importantly, their lightning-fast growth in 2017 that
caused an inflow of unsophisticated “investors” gave rise
to numerous automated trading providers. Their tools are
often called “bots”, less often “algos” and are marketed as
some crypto magic wands.
The trading ideas behind such “bots” are never clearly
explained, their back-testing results rarely provided.
Aggressive marketing, including MLM-type schemes and
extensive buzzword usage, are common as many such
“providers” have moved into crypto from Forex and binary
options trading.
In the best-case scenario, these “bots” are very short-
lived directional strategies that only work if the market
goes up or simple arbitrage algorithms that are easily
competed away by fast and efficient professional players.
In the worst case, they are outright scams.
Having said that, some companies in the space are
genuinely trying to create something more serious and
take a more professional approach. Fortunately for us,
such teams are mostly “learning on the job”, developing
algorithms from scratch and without the technological
platform to support them.
Of course, given enough time and resources, they will
improve. Most probably, however, it will already be too
late and their product will be outcompeted in live trading
by the professional HFTs and market makers that are
pouring into the space.
29. For a short but insightful overview we suggest reading Chapter 6 of the Pitch the Perfect Investment by P. Sonkin and P. Johnson
30. https://www.bloomberg.com/news/articles/2017-04-06/first-pile-of-steven-cohen-cash-is-injected-into-quantopian-code
27
2) “Crowdsourced” strategies providers
Numerous companies in this sub-segment have popped
up recently. At first sight, it is perfectly understandable as
crypto and blockchain provide an ideal solution for the
efficient creation, IP protection and fair remuneration of
the creators of such strategies.
However, very often these ideas seem to be based on the
false pretenses: “crowdsourcing” is confused with the
“crowd wisdom”.
The wisdom of the crowds is a real and relatively well-
researched phenomenon29. Crowds (under several
qualifying conditions) are, in fact, very effective at
estimating unknowns. At least, at most times, more
effective than any individual member of the crowd
regardless of her domain knowledge.
However, having many people “have a go” at creating a
trading strategy in no way does create the “quality
multiplicator” effect found in the wisdom of the crowds.
Quantity in this case, does not translate into quality.
The companies in this space range from frankly amateur
ones aiming at creating simple graphic interfaces to very
professional, creating elaborate and complex products.
While we admire the technical excellence and the amount
of effort put into the development of some of those
products, we always look how it translates into profit
opportunities. Sadly, with crowdsourced strategies, it is
usually the “mountain gave birth to a mouse” type of
situations.
You do not have to take our word for it. You can look at
the track record of the world's best-known and, arguably,
most advanced quantitative strategies crowdsourcing
platform30. It is backed by the prominent investors, has
been in operation for over 6 years and has had some
120,000 users trying to come up with profitable
strategies, creating several hundred thousand of them.
Guess how many strategies were deemed worthy by the
platform backers to actually invest their money in?
Fifteen. Fifteen!
In six years of operation, the investors were able to
employ less than 10% of the funds they've initially
allocated to the platform. Enough said.
 COMPETITION 28

3) Co-trading / copy trading providers experience but so far, we seem to be the only one that
decided to move in this direction.
A number of such platforms are under development at
the moment. They are supposed to give users an
opportunity to copy trading strategies that have been
II.Competition in execution
profitable for some period of time and use them as their
algorithms
own, rewarding those strategies' creators. Traditionally, execution algorithms were provided by the
executing brokers, who would also offer access to
Such platforms are more open about what those
exchanges. In crypto markets, though, the exchange
strategies actually do and some of them do plan to
access is direct, hence, there are no broker-dealers.
provide back-testing or even live trading results.
There are numerous companies that offer execution
One, however, should be mindful of three things when
algorithms – from trading terminals/execution platforms
looking at those platforms.
to crypto exchanges themselves. However, these are
First, there must be a clear trading idea providing clear usually very basic algorithms - VWAP/TWAP-types at
causality for the strategy results to exclude a possibility best33.
of “pure chance” results that are abundant in any data
Intelligent execution algorithms of the kind offered by our
set. After all, “if you torture data long enough, it will
platform are, in fact, intraday high-frequency algorithms
confess to anything”31.
that are just several steps away from being fully-fledged
Second, you have to make sure that the conditions that profit-generating trading strategies.
enabled that strategy to be profitable are still present in
Crypto exchanges do not offer such algorithms since
the market, you cannot simply extrapolate them into the
there is a direct conflict of interests as exchanges are in
future32.
the business of making money from commissions, while
Third, you have to make sure that this strategy is not intelligent execution algorithms are aimed at reducing
susceptible to the ever-increasing competition from the them.
professional market players since you won't have their
Companies developing crypto trading terminals at the
trading platforms and technology stack for your
moment do not offer such algorithms as well as (at least,
execution. This condition leaves mostly the longer-term
we are not aware of any). Intelligent execution algorithms
quant strategies in the potential pool of profitable copy-
are very complex and require lengthy development and
trade strategies, ruling out most ultra-short-term non-
testing. Hence, our largest competitive threat in this sub-
directional trades.
segment, again, is from established players moving into
Even leaving aside the obvious conflict of interests that crypto from the traditional markets.
is inherent to such approach, we do not think copy
trading platforms will create a lot of the real profit III.Competition in trading signals
opportunities for their users. Though, we appreciate the
Competition in this segment is high, that is why we focus
elegance of the underlying idea.
on developing our fully-automated strategies and
Summing up, we are not aware of any company besides intelligent execution algorithms first and view trading
CRYPTTO that both has the experience and technology signals not as the core of our value proposition but,
to develop profitable fully-automated high-frequency rather, its enhancement.
trading strategies that are uncorrelated to the general
Companies that offer various trading signals are abound.
market direction and are future-proof (meaning that they
Many companies provide technical signals and select
won't be outcompeted into unprofitability soon) and is
few other signal types (e.g. sentiment-based, on-chain
planning to make them available to the general public.
data-based).
The only real threat in this regard can come from a
Let us describe each group of trading signals providers
professional HFT firm with extensive traditional markets
and their products more in detail:

31. https://en.wiktionary.org/wiki/if_you_torture_the_data_long_enough,_it_will_confess_to_anything
32. The dangers of extrapolation are perfectly illustrated by this comic https://xkcd.com/605/
33. For the description and a deeper discussion of execution algorithms, please, see previous chapter
 COMPETITION
1) Specialized trading signals providers
This group should not be mistaken for the numerous
types of generic/technical signal providers. There are
very few such companies in the crypto space. Most of
them are dealing with the sentiment analysis as it appears
to be the single major driver of the crypto market at the
moment by some margin.
These companies tend to be very professional. Most of
them are branching out from the traditional markets and
have a strong background and/or close ties in academia.
It is their main advantage but also their main weakness.
Such companies tend to be more focused on the science
and correct estimates than on the ways to turn their
achievements into actual profit-making opportunities.
They mostly leave it to guys like ourselves to figure it out
– and it requires a lot of trading, development, and NLP
algorithms expertise to act on it.
That is why, while being acutely aware of this group's
existence, we view them mostly not as our competitors,
but rather as our potential partners/input providers.
2) Technical signal providers
This is, arguably, the most “crowded” segment in the
space. And the most oversold.
Technical signals could be genuinely useful for a trader
as they give him a very good feel of what's going on in the
market at the moment. That's why you want to keep
them handy.
Their profit-generating potential, however, is a totally
different story. To better understand it, one should look
back at their origins.
Technical signals were, in a manner of speaking, world's
first quantitative trading strategies. If you look closer,
most of them were created in the 60s, 70s, and 80s by
the established “quants” of those periods.
Technical signals, in their essence, are looking for
trends/patterns within the price and volume data that
have predictive potential. That's exactly what modern
quantitative analysts do.
The difference is that the technical signals can be
produced with the basic computational devices, while
modern quantitative strategies are developed using
supercomputers and machine learning algorithms.
Technical signals might have had meaningful predictive
29
potential back at the times when they were actively
developed – a paper market with no or very basic
computers and algorithms and very, very low competition
for short-term trading opportunities.
Very low levels of competition were probably the main
reason why the technical signals might have worked in
the crypto markets for a while. We are even aware of a
number of “crypto hedge funds” that grew fond of them
and have heavily relied on basic technical signals in their
trading (at least were relying on as a couple of months
ago).
However, technical signals explore the most common
and most obvious patterns. And it is these patterns that
are competed away first. They still work in crypto, but we
can state with total confidence that in the very near
future there will be very, very few profit opportunities
generated through technical signals.
We are not dismissing them entirely, but there is a reason
why there is no professional trading firm in the traditional
markets that relies on technical signals as the main
source of profit opportunities.
3) News and analysis providers
Quality news and analysis is a valuable resource in the
crypto world and a segment that is still in its early stages
of development.
News and sentiment are by far the strongest drivers of
the crypto markets at the moment given how nascent the
markets are and the consequent absence of economic
fundamentals.
Probably that is why many of the crypto news and
analysis start-ups market themselves as some sort of
trading signals providers, which, in turn, is the reason we
analyze them within the scope of our whitepaper.
News indeed can provide alpha (profit opportunities), but
only if you can interpret them correctly and act on them
fast. “Manual” news interpretation and execution still
provide profitable trading opportunities at the moment,
but, as all other “obvious” trades, they will become highly
competitive algorithmic “speed tournaments” very soon.
Thus, without the interpretation and execution back-end,
crypto news is just a commodity product that in no way
is competing with us.
As an aside - a commodity product is generally a bad
business to be in since the cost of entry is low and the
 COMPETITION 30

future competition is high34. The only way to make a
killing in this business is to create a quasi-monopoly (like
Bloomberg did in traditional markets) but given the
nature of the crypto markets and the community, we do
not think it will ever going to happen.
To sum up, let us map all types of companies that we
compete with along two axes: expected profitability of
their “product” and its availability to an average trader:

high
Traditional HTF/
Value-added investment research, however, is a totally market-makers Direct
competitors
different case. It is still not a threat to us since it is only zone
useful for the longer-term investing but it is certainly

Threat level (profitability)

Specialized
signal providers
something the crypto markets are missing. Moreover, (sentiment)

this is where a business can develop a clear competitive «Crowdsourced» signals & strategies Crypto «bots» providers
«Co-trading» strategies Technical signals providers
advantage through research quality and reputation and Trading terminals News & analysis providers
“shield” itself from future competition. low Accessible to average trader high

A peculiar thing is that at the moment the soundest
investment research in the space is provided by the
crypto funds themselves. While in traditional markets
they are the main consumers of such reports and internal
fund research is highly classified.
The biggest problem that the crypto investment analysis
is mostly reduced to analyzing projects' intended designs
and tracking their development progress. No
fundamental analysis that requires cash flow projections
(even if through distant proxies, such as sales or
customers growth) is possible at the moment.
This is exactly the reason why the news and general
sentiment affect the markets so much.
This map clearly illustrates the thesis that we are trying
to ascertain throughout this chapter: while the
competition in crypto trading is fierce, our main
competitive threat comes not from the broadly-
advertised and outspoken companies, but rather from a
closed but highly professional cohort of HFT and market
making firms. It is those companies that possess similar
capabilities in terms of trading strategies development
and execution.
In the future, there might be others that will follow us, but
at the moment what we are doing is truly unique and we
do not have direct competitors (that we are aware of)
that provide the same value proposition as the CRYPTTO
platform.

34. We are again referring you to the excellent Competition Demystified by Bruce Greenwald
 TIMELINE
When We Will Deliver
We have started exploring crypto markets in Summer of
2017 – relatively late, but earlier than many of our
traditional market competitors. The focus of our analysis
was not the blockchain industry per se, though we have
spent considerable time understanding it and trying to
envision its transformative potential. The subject of our
initial interest was much narrower: whether the
cryptocurrencies market was already out of its birth
cradle or not.
We were trying to understand whether crypto markets
technology, security, and regulatory environment were
mature enough to allow for systematic scalable trading
strategies to be applied in an efficient manner. Another
thing we were closely tracking was liquidity as it's a quick
proxy for the amount of trading capital that can be put to
work through our strategies.
Crypto markets were developing at a lightning pace.
Thus, as a logical next step, in October 2017 we have
started analyzing market data and looking at how our
traditional markets experience and technology could be
applied to put us in a competitive position in the crypto
markets.
In January 2018 our first test trading algorithms loosely
based on our existing platform capabilities were
launched on several crypto exchanges.
Based on the successful test trading results we have
defined the value proposition of our future platform and
launched its development in February of 2018.
The cornerstone on which our platform's idea was
developed is the abundance of the high-frequency trading
opportunities in the crypto markets coupled with
blockchain and crypto enabling new business models in
professional trading based on a vast number of relatively
small participants by making the distribution and
compliance costs non-prohibitive.
The initial version of our website became live in late
March of 2018, we have collected market feedback,
tweaked our roadmap and priorities (i.e. focus on fully-
automated trading strategies development first) and
started strategic negotiations with partners and
investors.
35. To get more information on our Alpha Platform Preview, please, read our dedicated Medium
https://medium.com/cryptto-io/alpha-preview-of-the-cryptto-platform-1f05bb654b14
31
On the development side, our primary focus is to deliver
profitable and scalable fully-automated trading strategies
to our customers. The first batch of our strategies that
we prepare for the platform public launch includes
several structural arbitrage, statistical arbitrage, and
event-driven strategies.
In May 2018 we have launched our first two structural
arbitrage strategies in production mode on several
exchanges as part of our Alpha Platform Preview35.
These strategies are now being scaled across
instruments and exchanges.
We plan to launch our Beta Platform in August 2018. Our
Beta Platform will feature several fully-automated
strategies. It will include two or more structural arbitrage
strategies scaled across most liquid instruments and
major exchanges, at least one statistical arbitrage
strategy and, possibly, an event-driven strategy.
The strategies will be fully operational and the Beta
Platform will have UI and security features to allow on-
boarding of the first third-party users. We plan to provide
an exclusive access to our Beta Platform to our pre-sale
participants as our token of gratitude.
The public launch of our Platform is planned for
December 2018.
The CRYPTTO 1.0 platform will feature a set of fully-
automated market-neutral strategies that trade in users'
exchange accounts and a suite of intelligent execution
algorithms that improve execution prices and reduce
trading costs for large orders.
The next iterations of the platform will see numerous
trading signals and alerts added with a choice of semi-
automated or manual execution across all major crypto
exchanges.
We are consciously focusing on the development of the
most sophisticated part of our platform first, as it is
where we create the most value for our users and where
we have a unique competitive advantage.
 TIMELINE 32

We have got an ambitious development schedule with a
very early platform launch, but we are confident in our
ability to deliver. We also understand that every additional
day that we spend on development is a day “lost” to our
users. We want our platform operational, our tokens with
full utility, and our strategies and algorithms in the hands
of our users ASAP. That said, however, there is no way
we'd compromise our strategies testing or platform's
security in the slightest for the sake of an earlier platform
launch.
The ultimate goal of the efforts described above is to
ensure that our platform continuously stays competitive
and provides value to our users in form of profitable
trading opportunities for many years to come, despite the
ever-increasing competition, technological or market
regime changes.
We have the necessary vision and expertise, and our
development budget (hardcap) was set to make sure we
have the resources required to achieve it.

An important thing to understand is that with the 1.0

version launched, the development work on the platform
does not stop, it only intensifies.
Besides adding new features (signals and alerts, semi-
automated and manual execution), there will be a
constant development process focused on three things:
We have consciously chosen a non-graphical, textual
format to deliver our timeline info to you because we
want you not to just skim the milestones but read and
understand in detail our approach and our development
process. A simplified graphical timeline could be found
on our website.

1) Scaling the existing strategies across instruments

and exchanges.
Scaling opportunities are plentiful as new exchanges
rise constantly, new instruments with near-instant
liquidity are created (e.g. hardforks), and more and
more instruments become liquid enough for
systematic trading (e.g. new protocols).
We are also monitoring closely the decentralized
exchanges space as we feel it can also become a
fertile ground for our strategies in the near future.

2) Expanding our fully-automated strategies offering.

We have a development pipeline of strategies for at
least the next several years. And in terms of on-chain
data-based strategies, we are just scratching the
surface: our researchers explore available data sets
and they look very promising.

3) Optimizing and “upgrading” our strategies and

platform.
Development path of a trading strategy or a trading
platform is always a path of compromises in terms of
features and performance vs. time vs. money.
We strive to bring a competitive trading platform to
our users ASAP, but we also have a long list of
optimizations and upgrades that we plan to
implement both to our strategies (e.g. passive
liquidity) and the platform itself (connectivity and
technology).
Our key development criterion is the competitiveness
of our strategies and the platform in the current
market environment. As the competition increases,
we will “upgrade” our platform and strategies.
 USE OF FUNDS
What We Need To
Deliver / Use Of Funds
Our hardcap is USD 25,000,000 ³⁶
Our hardcap was chosen to allow us not only to develop
state-of-the-art trading platform and strategies and to
market them to a broad user base, but to develop them
fast and, even more importantly, to have the necessary
resources to expand and upgrade our platform to keep it
competitive and future-proof for the long time to come.
High-frequency trading is a very expensive business to
set up and operate competitively. There are sizable start-
up costs: infrastructure, networking, communications,
etc. Recurring fixed costs are very high - just the Twitter
firehose (full access API) will cost you tens of thousands
USD per month37.
Experienced developers and data scientists are anything
but cheap, while time to market is crucial for obvious
reasons. What a team of 5 scientists and 5 developers
can do in a year, can be done in 6 or even 3 months,
depending on the number of qualified man-hours that
went into it.
Furthermore, high-frequency trading is a non-
stop scientific and technological race. Once up
and running, you have to continuously work on
maintaining and improving your strategies, while
your engineers are upgrading your technology
stack to remain competitive.
A good trading platform is never finished – at ATTO we
have been developing our platform for basically 13 years
and still have a lot to do.
TECHNOLOGICAL
UPGRADE RESERVE:
$5.0MM
MARKETING &
25MM
OPERATIONS:
$3.0MM
NETWORKING &
COMMUNICATIONS:
$3.0MM
INFRASTRUCTURE: $4.0MM
36. 70% of the tokens are sold for USD 25mln. Full details of the tokenomics in the next chapter
37. Or even more, depending on your needs and how you use the data
38. We expect our platform to be profitable from the onset. However, we want to ensure that we can concentrate on delivering new profitable strategies to our
users as fast as possible rather than being budget-constrained
33
We plan to spend the funds collected on the following:
USD 10.0 mln will be spent on platform and strategies
development. We have planned a 3-year development
budget38 that implies an aggressive expansion of our
research and development team in order to shorten
strategies' and features' time to market as much as
possible. The bulk of the development costs is
compensation (both monetary and non-monetary). To
hire the talent we need in the timeframe we have, we'll
have to concentrate on expanding our New York office
and establishing new development offices in world's
other financial centers (Chicago, London, Singapore) -
talent acquisition costs in those place are through the
roof.
The planned costs of our platform deployment are
USD 4.0 mln for infrastructure and USD 3.0 mln for
networking and communications. We want to create as
much value for our users as we possibly can, and that
means having cutting-edge equipment and technology
and not settling for the second-best. We design
CRYPTTO to be one the fastest and the most secure
high-frequency trading platforms out there.
We plan to spend USD 3.0 mln on marketing and
operations – for the most part, these are Year 1 costs as
we plan CRYPTTO to become operationally profitable
during the first twelve months of operations. Our
marketing budget is relatively modest (though still
substantial) as we believe that once our platform is
operational the word-of-mouth will become our main
customer acquisition channel by far – our strategies'
trading results will speak for themselves. We are closely
monitoring marketing spend of our main competitors and
we have a very good idea of what is required for our
platform to take off.
DEVELOPMENT: A key item in our budget is the Technological
YEAR 1: $4.0MM Upgrade Reserve of USD 5 mln. Think of it as our
YEAR 2: $3.0MM “war chest” that is set up to ensure that our
YEAR 3: $3.0MM
platform remains competitive for many years to
come regardless of the technological and/or
market regime changes.
An important thing to understand is that we will be
moving ahead with the CRYPTTO platform creation
 USE OF FUNDS 34

regardless of our crowdsale results, even if the soft-cap is Our softcap is USD 5,000,000.
not reached. We have full confidence in our business
In the event we only reach our soft cap, our timeline won't
model and the value that we can create. That is why in
change but the scaling of our platform will be much
the unlikely case of the unsuccessful crowdsale we will
slower.
either look for other sources of financing or will finance it
ourselves. There still will be several basic structural and statistical
arbitrage strategies and intelligent execution algorithms
However, hitting our hardcap will enable us to
available at launch, and the initially-delivered strategies
significantly shorten our time to market and widen the
will be equally profitable. However, scaling of those
range of the strategies offered in the first years of the
strategies and the platform in general will go slower,
platform operations. Most importantly, reaching our
meaning that we will keep missing existing profit
hardcap will ensure our ability to prevent and timely
opportunities for longer. Also, keeping up with the
neutralize any competitive threats that might arise.
technological changes will be much harder in this case.
As an example, you could think of the traditional markets Thus, there is a chance that the strategies profitability
data transmission transitioning from copper wires to might suffer in the long run as the technological
fiber-optics to microwave towers to lasers that happened upgrades will be performed only from available funds
in a little over a decade. HFT platforms had to invest from operations.
millions and millions of dollars just to keep up. And long-
If we won't be able to reach our softcap, all collected
distance data transmission is just one dimension over
funds will be returned and we will proceed with the
which the high-frequency trading competition takes
platform creation on our own.
place.

We understand that there is a large difference

between our soft and hard caps. However, we do
not want to artificially increase our softcap. These
are supposed to be the minimal funds required to
launch the platform under development – and our
softcap of USD 5 mln represents exactly that. Our
hardcap can be decreased basically only by cutting
out the technological upgrade reserve but we do
not feel it is in the best interests of our platform and
its users.
 TOKENOMICS 35

Tokenomics
Our token name is TTO. TTO is issued on the Ethereum
network and is ERC-20 compliant.

Token utility Token metrics

TTO is the sole means of access to our platform: • Our softcap is USD 5,000,000;
• Our hardcap is USD 25,000,000;
1) It is used for subscription payments on all levels of
• There will be 100,000,000 TTO ever created (total
our platform;
supply);
2) It is used to fulfill staking requirements of the F • 70% of total supply (70,000,000 TTO) will be sold in
(femto) level of our platform; the crowdsale;
• 30% of total supply (30,000,000 TTO) will be retained
3) It is used to fulfill dynamic staking requirements of
by the team, our partners, and advisors;
the A (atto) level of our platform.
• All team tokens will be subject to vesting tied to
Regular subscription payments in TTO are a prerequisite platform and strategies development milestones
to access any level of our platform. Size of the
subscription payments increases with the platform's
In case we do not reach our softcap – all collected funds
level.
will be returned.
To access the F (femto) level of our platform that
If the softcap is passed but the hardcap not reached, all
provides semi-automated trading and intelligent
unsold tokens will either be burned (including a
execution algorithms, one would also need to stake a
proportional amount of the team's tokens) or allocated
fixed amount of the TTO tokens for the whole duration of
pro rata to all crowdsale participants.
the access. Those coins are returned to the user when
his subscription expires.

A (atto) level of our platform is the top level that provides

access to our fully-automated trading strategies.

The number of access spots to the A (atto) level

will be limited. Potential users will compete for
them on staking auctions.

Staking auctions will be held weekly. Actual and potential

users of the atto level will indicate the maximum amount
of TTO that they are prepared to stake to receive/prolong
access to our top platform level.

There are n access spots to that level, consequently,

n users with the most tokens staked will be allowed to
use our strategies during the next week.

The results of the staking auctions will be transparent so

that users will be able to devise their strategy for the next
week's auction.
 PROOF OF WORK
Proof Of Work
If anything, blockchain and crypto space are not lacking
grand and disruptive projects. What is lacking, contrary to
blockchain's transparent underpinnings, is information
and trust.
Most research efforts of the people looking at crypto
projects are concentrated on finding bits of information
that will answer whether the team can actually deliver
what they promise. The best and, in fact, the only proof of
that is the actual product as there is usually a long way
between the disruptive idea and its implementation.
At CRYPTTO, we have an experienced team and a clear
vision of what needs to be done to deliver our product
and how we are going to do it. That is why, even before
our whitepaper was ready, we have made two releases
that reflect our vision and our development capabilities.
The first release is a real-time normalized market data
feed from major crypto exchanges. It is worth noting that
some companies have built an entire business around
such a product. We have created it as a by-product of our
platform development and offer it free of charge.
Our second release is the Alpha Preview of our platform.
In late May, as per our Roadmap, we have launched two
structural arbitrage strategies in production mode (i.e.
live trading). These strategies are previewed in that
release.
Real-Time Normalized Market Data
Feed
Our consolidated feed provides real-time normalized
trade data from major crypto exchanges for free. We do
not aggregate or conflate trade data in any way, only
normalize the protocols and publish the trade data to
subscribers. At the moment we provide access to real-
time trade information for all pairs listed on Bitstamp,
Bitfinex, Poloniex, Quoinex, GDAX, and Gemini. Bitmex,
OKEX, and Binance are to be added soon with others to
follow.
39. To get a more detailed description, please, check our original Medium post
https://medium.com/cryptto-io/alpha-preview-of-the-cryptto-platform-1f05bb654b14
36
The market data feed is being delivered via our C++
based low-latency market data handler capable of
maintaining connections and processing all data (trades
and quotes) from all crypto exchanges on a single
commodity server.
You can check a preview of the feed on our website
https://cryptto.io/#tools
Working online example of the data feed and a feed
viewer written in JavaScript can be found here
https://cryptto-io.github.io/market-data-feed/feed-
viewer/. You'd need to create a profile on our website and
request an API key to access it.
For the detailed description and set-up instructions,
please, visit our GitHub repository at
https://github.com/cryptto-io/market-data-feed.
Alpha Platform Preview 39
During the last week of May, as per our Roadmap, we
have launched in production mode two fully-automated
structural arbitrage strategies. Currently, they are trading
our own capital.
Our inter-exchange arbitrage strategy was designed to
take advantage of differences in the price of a single
asset pair on several exchanges. It is currently trading
BTC/USD on GDAX and Bitfinex but will be scaled to all
liquid instruments and major exchanges.
Our intra-exchange triangular arbitrage strategy is
exploiting price discrepancies of three instruments on a
single exchange. At the moment it is trading
BTC/ETH/USD on GDAX but will be scaled to all liquid
instruments and major exchanges in the near future as
well.
Simulation results of both strategies are very
encouraging, to say the least. See for yourself.
 PROOF OF WORK 37

Inter-exchange arbitrage strategy simulation results:

12000

10000
PnL, USD

8000

6000

4000

2000

0
2018-04-01 2018-04-11 2018-04-21 2018-05-01 2018-05-14
PnL by date
1400

1200

1000
PnL, USD

800

600

400

200

0
2018-04-01

2018-04-02

2018-04-03

2018-04-04

2018-04-05

2018-04-06

2018-04-07

2018-04-08

2018-04-09

2018-04-10

2018-04-11

2018-04-12

2018-04-13

2018-04-14

2018-04-15

2018-04-16

2018-04-17

2018-04-18

2018-04-19

2018-04-20

2018-04-21

2018-04-22

2018-04-23

2018-04-24

2018-04-25

2018-04-26

2018-04-27

2018-04-28

2018-04-29

2018-04-30

2018-05-01

2018-05-02

2018-05-03

2018-05-05

2018-05-07

2018-05-09

2018-05-10

2018-05-11

2018-05-12

2018-05-13

2018-05-14

2018-05-15

2018-05-16

2018-05-17

2018-05-18

2018-05-19

2018-05-20

2018-05-21

2018-05-22
Net cumulative exposure
2.00

1.75

1.50

1.25
BTC

1.00

0.75

0.50

0.25

0.00

This strategy would have returned USD 12,116 on your In case you are wondering, where is the “high-frequency”
2 BTC (~USD 15,400) of trading capital in 49 days. That's in all that — it is not in the duration of the trades (the time
78% in 49 days. With no profits reinvestment. between entering and exiting the position), it is in the
speed with which our algorithm is able to execute trading
Moreover, it did not have any losing days during that
opportunities. The speed of execution allows us to
period, so it'd never test your nerves with a lot of red ink
minimize slippage (the difference between the price that
on the screen.
was desired and was actually paid) and achieve real-time
On average, it would have returned USD 247 per day, results that are very close to the simulation.
making a bit more than 10 trades daily and holding
positions open between 6 seconds and 24 hours.
Intra-exchange triangular arbitrage strategy simulation
results:
 PROOF OF WORK
This strategy would have earned you a USD 2,662 return
on your USD 2,000 of trading capital in 48 days. That's
133% in 48 days. With no profits reinvestment.
It did not have any losing days during that period as
well — 75% of the winning days just means that 25% of
the time the strategy was not able to identify available
trading opportunities.
This strategy is more of a “rapid fire” type — when the
opportunities arise, the positions are open and closed
several times per second. To get a visual of this process,
please, check the video we recorded
https://www.youtube.com/watch?v=9WSi8b7Ymrg
Early live trading performance confirms the simulation
results — strategies in the production mode behave as
expected. Now we will start scaling them across
instruments and exchanges, while continuously
optimizing their performance as more actual trading data
comes in.
The next steps on the strategy development side are to
further enhance existing strategies by adding passive
position entry capabilities, finalize the production testing
of our first statistical arbitrage strategy, and begin
prototyping our news-driven strategies.
Passive position entry materially reduces trading costs
and allows to capture the spread, significantly widening
trading opportunities set of our strategies and increasing
their profitability. Passive position entry is powered by our
Notice the difference between the January-March and
the April-May periods?
Trading opportunities are not gone-gone — that flat part
of the graph, in fact, represents a 40% monthly return
(481% annual) — they just became heavily competed for,
as is already the case in traditional markets for many
38
intelligent execution algorithms that will also be available
as a separate product suite on our platform.
Our first StatArb strategy is already running in the
production mode and will be available to our pre-sale
participants in August as part of our Beta platform.
An important thing to remember is that our strategies
are designed to trade in your crypto exchange accounts,
we never get access to your coins, so there is no
additional counterparty risk for you.
The more accounts on different exchanges you have, the
more and better trading opportunities our strategies will
let you take advantage of. Moreover, this relation is not
linear, it's accelerating — twice number of exchange
accounts expands the opportunities set more than twice.
Another important thing to keep in mind is that while the
two strategies presented above may sound simple to
some of you, there is more there than meets the eye. The
reason they are able to deliver those returns now and will
remain competitive and profitable is our deep expertise in
operating and optimizing high-frequency trading
strategies and our full-stack ultra-low latency trading
platform running in the background.
All “easy” trading opportunities that were abundant in the
crypto markets just several months ago are already gone.
Just look at the simulation of our triangular arbitrage
strategy returns from the beginning of 2018:
years. Similar strategies are alive and well in traditional
asset classes. It's just that most of the people reading
this have no way of profiting from them since it requires
access to very advanced and sophisticated trading tools.
In the crypto markets, going forward, one would need our
level of expertise and technology to continue to take
advantage of such opportunities.
 LEGAL
Risks And Legal
Disclaimers
PLEASE, READ THIS SECTION AND THE FOLLOWING
SECTIONS ENTITLED “DISCLAIMER OF LIABILITY", “NO
REPRESENTATIONS AND WARRANTIES",
“REPRESENTATIONS AND WARRANTIES BY YOU",
“CAUTIONARY NOTE ON FORWARD-LOOKING
STATEMENTS", “NO ADVICE", “RESTRICTIONS ON
DISTRIBUTION AND DISSEMINATION", “NO OFFER OF
SECURITIES OR REGISTRATION" AND “RISKS AND
UNCERTAINTIES" CAREFULLY. IF YOU ARE IN ANY
DOUBT AS TO THE ACTION YOU SHOULD TAKE, YOU
SHOULD CONSULT YOUR LEGAL, FINANCIAL, TAX OR
OTHER PROFESSIONAL ADVISOR(S).
The TTO Tokens (as defined in this White Paper) are
consumptive use product permitting access to the
products provided on the CRYPTTO platform and are not
intended to constitute securities in any jurisdiction.
CRYPTTO and its Legal Advisors to the best of their
knowledge and understanding will seek incorporation in
the jurisdiction in which a clear regulatory opinion on the
utility of TTO tokens could be obtained before conducting
any token sale or distribution. This Whitepaper does not
constitute a prospectus or offer document of any sort
and is not intended to constitute an offer of securities or
a solicitation for investment in securities in any
jurisdiction.
Blockchain, cryptocurrencies and other aspects of our
technology and the underlying markets are in their
infancy and will be subject to many challenges,
competition, and a changing environment. We will make
our best efforts to update our community as things grow
and change but undertake no obligation to do so.
This Whitepaper does not constitute or form part of any
opinion on any advice to sell, or any solicitation of any
offer by CRYPTTO of the TTO Tokens to purchase any
TTO Tokens nor shall it or any part of it nor the fact of its
presentation form the basis of, or be relied upon in
connection with, any contract or investment decision.
CRYPTTO will deploy all proceeds of the sale of the TTO
Tokens to fund CRYPTTO's businesses and operations,
including continued development and marketing of the
CRYPTTO platform. No person is bound to enter into any
contract or binding legal commitment in relation to the
sale and purchase of the TTO Tokens and no
cryptocurrency or other form of payment is to be
accepted on the basis of this Whitepaper.
39
Any agreement as between CRYPTTO and you as a
purchaser, and in relation to any sale and purchase, of
TTO Tokens is to be governed by only a separate
document setting out the terms and conditions (the
“T&Cs") of such agreement.
In the event of any inconsistencies between the T&Cs
and this Whitepaper, the former shall prevail.
You are not eligible to purchase any TTO Tokens in the
CRYPTTO's Token Generating Event, or “TGE” (as referred
to in this Whitepaper) if you are a citizen, resident (tax or
otherwise) or green card holder of the United States of
America unless you qualify as an accredited investor.
Accredited US investors MUST purchase tokens in the
SAFT offering described herein.
No regulatory authority has examined or approved of any
of the information set out in this Whitepaper. No such
action has been or is planned to be taken under the laws,
regulatory requirements or rules of any jurisdiction. The
publication, distribution or dissemination of this White
Paper does not imply that the applicable laws, regulatory
requirements or rules have been complied with.
There are risks and uncertainties associated with
CRYPTTO and its business and operations, the TTO
Tokens, and the TGE. This Whitepaper describes the
current vision for the CRYPTTO platform. While we intend
to attempt to realize this vision, please recognize that it is
dependent on a variety of factors and subject to a
number of risks. It is entirely possible that the CRYPTTO
platform will never be implemented or adopted, or that
only a portion of the platform will be realized.
Interested parties acknowledge that the CRYPTTO
platform, as described herein, may never, in fact, operate
as intended. TTO Tokens are not for speculative
investment and there is no promise of future
performance. TTO Tokens do not represent participation
or hold any rights in any legal entity related to CRYPTTO.
TTO Tokens are sold as a functional good and all
proceeds received by CRYPTTO are the sole property of
CRYPTTO. The purchase of TTO Tokens is intended for
experts in dealing with cryptographic and blockchain-
based software systems.
This Whitepaper, any part thereof and any copy thereof
must not be taken or transmitted to any country where
distribution or dissemination of this Whitepaper is
prohibited or restricted.
No part of this Whitepaper is to be reproduced,
distributed or disseminated without including this section
 LEGAL
and the following sections entitled “Disclaimer of
Liability", “No Representations and Warranties",
“Representations and Warranties By You", “Cautionary
Note On Forward-Looking Statements", “No Advice",
“Restrictions On Distribution and Dissemination", “No
Offer of Securities Or Registration" and “Risks and
Uncertainties".
Disclaimer Of Liability
To the maximum extent permitted by the applicable laws,
regulations, and rules, CRYPTTO shall not be liable for
any indirect, special, incidental, consequential or other
losses of any kind, in tort, contract or otherwise
(including but not limited to loss of revenue, income or
profits, and loss of use or data), arising out of or in
connection with any acceptance of or reliance on this
Whitepaper or any part thereof by you.
No Representations And Warranties
CRYPTTO does not make or purport to make, and hereby
disclaims, any representation, warranty or undertaking in
any form whatsoever to any entity or person, including
any representation, warranty or undertaking in relation to
the truth, accuracy, and completeness of any of the
information set out in this Whitepaper.
Representations and Warranties
by You
By accessing and/or accepting possession of any
information in this Whitepaper or such part thereof (as
the case may be), you represent and warrant to
CRYPTTO as follows:
1. you agree and acknowledge that the TTO Tokens do
not constitute securities in any form in any jurisdiction;
2. you agree and acknowledge that this Whitepaper does
not constitute a prospectus or offer document of any
sort and is not intended to constitute an offer of
securities in any jurisdiction or a solicitation for
investment in securities and you are not bound to enter
into any contract or binding legal commitment and no
cryptocurrency or other form of payment is to be
accepted on the basis of this Whitepaper;
3. you agree and acknowledge that no regulatory
authority has examined or approved of the information
set out in this Whitepaper, no action has been or will be
taken under the laws, regulatory requirements or rules of
any jurisdiction and the publication, distribution or
40
dissemination of this Whitepaper to you does not imply
that the applicable laws, regulatory requirements or rules
have been complied with;
4. you agree and acknowledge that this Whitepaper, the
undertaking and/or the completion of the TGE, or future
trading of the TTO Tokens on any third-party
cryptocurrency exchange, shall not be construed,
interpreted or deemed by you as an indication of the
merits of CRYPTTO, the TTO Tokens, and the TGE;
5. the distribution or dissemination of this Whitepaper,
any part thereof or any copy thereof, or acceptance of the
same by you, is not prohibited or restricted by the
applicable laws, regulations or rules in your jurisdiction,
and where any restrictions in relation to possession are
applicable, you have observed and complied with all such
restrictions at your own expense and without liability to
CRYPTTO;
6. you agree and acknowledge that in the case where you
wish to purchase any TTO Tokens, the TTO Tokens are
NOT to be construed, interpreted, classified or treated as:
a. any kind of currency other than cryptocurrency;
b. (i) debentures, stocks or shares issued by any person
or entity (including, without limitation, CRYPTTO); (ii)
rights, options or derivatives in respect of such
debentures, stocks or shares; (iii) units in a collective
investment scheme; (iv) units in a business trust; (v)
derivatives of units in a business trust; or (vi) any other
security or class of securities.
7. you are fully aware of and understand that you are
NOT eligible to purchase any TTO Tokens if you are a
citizen, resident (tax or otherwise) or green card holder of
the United States of America and are NOT an accredited
investor;
8. you have a basic degree of understanding of
cryptocurrencies, blockchain-based software systems,
cryptocurrency wallets or other related token storage
mechanisms, blockchain technology and smart contracts
technology;
9. you are fully aware and understand that in the case
where you wish to purchase any TTO Tokens, there are
risks associated with CRYPTTO and its business and
operations, the TTO Tokens, and the TGE;
10. you agree and acknowledge that CRYPTTO is not
liable for any indirect, special, incidental, consequential or
other losses of any kind, in tort, contract or otherwise
(including but not limited to loss of revenue, income or
 LEGAL
profits, and loss of use or data), arising out of or in
connection with any acceptance of or reliance on this
Whitepaper or any part thereof by you; and rights under a
contract for differences or under any other contract the
purpose or pretended purpose of which is to secure a
profit or avoid a loss;
11. all of the above representations and warranties are
true, complete, accurate and non-misleading from the
time of your access to and/or acceptance of possession
this Whitepaper or such part thereof (as the case may
be).
Cautionary Note On Forward-
looking Statements
This Whitepaper may contain certain forward-looking
statements including, but not limited to, statements as to
future operating results and plans that involve risks and
uncertainties. We use words such as "expects",
"anticipates", "believes", "estimates", the negative of these
terms and similar expressions to identify forward-looking
statements. Such forward-looking statements involve
known and unknown risks, uncertainties and other
factors which may cause the actual results, performance
or achievements of CRYPTTO to differ materially from
any future results, performance or achievements
expressed or implied by those projected in the forward-
looking statements for any reason.
No Advice
No information in this Whitepaper should be considered
to be business, legal, financial or tax advice regarding
CRYPTTO, the TTO Tokens, and the TGE. You should
consult your own legal, financial, tax or other professional
adviser regarding CRYPTTO and its business and
operations and the TGE. You should be aware that you
may be required to bear the financial risk of any purchase
of TTO Tokens for an indefinite period of time.
Restrictions on Distribution and
Dissemination
The distribution or dissemination of this Whitepaper or
any part thereof may be prohibited or restricted by the
laws, regulatory requirements and rules of any
jurisdiction. In the case where any restriction applies, you
are to inform yourself about, and to observe, any
restrictions which are applicable to your possession of
this Whitepaper or such part thereof (as the case may be)
at your own expense and without liability to CRYPTTO.
41
Persons to whom a copy of this Whitepaper has been
distributed or disseminated, provided access to or who
otherwise have the Whitepaper in their possession shall
not circulate it to any other persons, reproduce or
otherwise distribute this Whitepaper or any information
contained herein for any purpose whatsoever nor permit
or cause the same to occur.
No Offer of Securities or
Registration
This Whitepaper does not constitute a prospectus or
offer document of any sort and is not intended to
constitute an offer of securities or a solicitation for
investment in securities in any jurisdiction. No person is
bound to enter into any contract or binding legal
commitment and no cryptocurrency or other form of
payment is to be accepted on the basis of this
Whitepaper. Any agreement in relation to any sale and
purchase of TTO Tokens (as referred to in this
Whitepaper) is to be governed by only the T&Cs of such
agreement and no other document. In the event of any
inconsistencies between the T&Cs and this Whitepaper,
the former shall prevail.
You are not eligible to purchase any TTO Tokens in the
TGE if you are a citizen, resident (tax or otherwise) or
green card holder of the United States of America. No
regulatory authority has examined or approved of any of
the information set out in this Whitepaper. No such
action has been or will be taken under the laws,
regulatory requirements or rules of any jurisdiction. The
publication, distribution or dissemination of this
Whitepaper does not imply that the applicable laws,
regulatory requirements or rules have been complied
with.
Risks and Uncertainties
Prospective purchasers of TTO Tokens should carefully
consider and evaluate all risks and uncertainties
associated with CRYPTTO, its businesses and operations,
the TTO Tokens, and the TGE, all information set out in
this Whitepaper and the T&Cs prior to any purchase of
TTO Tokens. If any of such risks and uncertainties
develop into actual events, the business, financial
condition, results of operations and prospects of
CRYPTTO could be materially and adversely affected. In
such cases, you may lose all or part of the value of the
TTO Tokens.