The court also rejected Coinbase's objections the SEC's had failed to provide "fair notice" that it would employ its powers in this way toward crypto, supposedly contrary to due process and the requirements of the Administrative Procedure Act. It held that "the broader timeline of the SEC's positions regarding crypto-assets"—going back to the SEC's 2017 "DAO Report" and its numerous enforcement actions since then—"reveals that the SEC provided Coinbase (and similarly situated actors) fair notice—through written guidance, litigation, and other actions—that the sale or offering of certain crypto-assets could prompt an enforcement action by the SEC." It also noted that Coinbase itself had conducted risk assessments and engaged in other activities showing an appreciation of the potential issue it might face.