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That's a tough one to answer. In a way, yes it is because it's the token to pay for services on the ecosystem. But since EOS, much like Ethereum or other platforms, have such a wide scale of dApps building on top of them I would consider this to be a better investment than to invest in one particular dApp token on top of EOS.

But EOS is a difficult call, because of their 1 year long ICO. Most ICO's are said to become securities, and it was a big surprise to see the authorities say that ETH was not a security since it also had an ICO. The reasoning for this was that the Ethereum network was decentralized and no one party could be said to be in charge of providing profits. With EOS there's Block One of course, and some may say it's a similar situation as with Ethereum and the Ethereum foundation, but others might argue that EOS is not as decentralized as Ethereum.

It's going to be up to the regulators, really, to decide

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