Yeah, I read those parts as well. I just think you're explaining the mining and "expectation of profits" incorrectly regarding STEEM. There is no "issuer" of tokens - de facto or otherwise. And there is no expectation of profits from any central issuer of the tokens, partly because there's no issuer.

I think your interpretation is based on what you believe was an "insider" mining scheme, but it can be demonstrated that the mining was in fact opened publicly, even though the pool was small.

I think it would also be hard to prove that any "issuance" took place since the selling of the tokens was via exchanges - not through an explicit ICO process by the creators of the token.

It would really be a stretch to include STEEM in this rule. I'm not saying the state couldn't or wouldn't do it, but they would really need to take the broadest interpretation of the rules in order to do so - if not create additional rules entirely.