Question
Provide a concise narrative that clearly states each of (a)–(e) below.
Response
Existing fantasy sports platforms fail to combine real monetary stakes with persistent, skill-based competition. Season-long games like Fantasy Premier League offer engagement but no real financial rewards for skill. Daily fantasy platforms like DraftKings offer money but no long-term portfolio building. Prediction markets like Polymarket lack sports fandom and community. Sport.Fun solves this by creating the first onchain competitive sports market game where users buy, sell, and hold fractional shares of real-world athletes, with share values driven by market demand and real sporting performance. Users with genuine sports knowledge and analytical skill are rewarded over time through a dynamic, player-owned marketplace.
Sport.Fun generates recurring revenue through transaction fees on marketplace activity (base 3% fee on buy/sell transactions). Revenue is allocated across functions: supporting player market liquidity, returning value to players via FUN staking, and operational expenses including development, marketing, and platform growth. The platform achieved profitability prior to the $FUN token generation event and expects to sustain ongoing development through transaction fee revenue as the user base and trading volume grow across multiple sports verticals (football/soccer, NFL, with NBA and additional sports planned). The team raised via two private rounds, led by 6MV; as well as conducting a successful ICO. The team has enough runway to develop the project through the end of 2030.
Sport.Fun is a competitive fantasy sports market game built on the Base blockchain (Ethereum L2). Each real-world athlete is tokenized into tradable shares with a maximum supply of 25 million per athlete. Users deposit USDC, which they use to buy and sell athlete shares on the platform’s proprietary AMM. Athlete share prices move based on user trading activity and market demand. Users compete in recurring tournaments where their squad’s real-world match performance determines Tournament Point (TP) rewards, which are used to acquire randomized player packs. The platform operates across multiple sports with shared accounts and shared token economy. All game logic — asset ownership, trading, and reward allocation — is managed by smart contracts on Base.
Current utility of $FUN: (i) Trading fee rebates — users who hold $FUN in their in-game wallet receive tiered discounts on platform trading fees. Planned utility: (ii) Scouting & Player Discovery — $FUN staking will be required to participate in the Scouting system, where users propose and back new athletes to be added to the platform; (iii) Governance — $FUN holders will progressively gain voting rights over ecosystem decisions, including player additions, feature prioritization, and rule parameters; (iv) Premium features & access — advanced analytics, enhanced data tools, and premium gameplay features gated by $FUN holdings or spend. Value accrual is additionally driven by programmatic buybacks: 40% of platform revenue is allocated to open-market $FUN buybacks, 40% to athlete-market liquidity, and 20% to growth and product development.
Governance is centralized at launch, with the core team retaining decision-making authority to ensure coherent execution during early growth. The governance roadmap envisions a progressive transition toward token-based participation as the ecosystem matures. Planned milestones include a Scouting system giving $FUN holders direct influence over platform expansion (athlete curation), and potential community input on fee parameters and new sport launches. The pace and scope of decentralization will gradually increase over time.
Question
For each existing entity: Labs/DevCo (e.g., Founder, CEO, CTO, COO), Foundation (e.g., President, Executive Director, CFO, COO), and DAO / onchain governance leadership (if applicable) list the: (a) full names, (b) official titles, (c) and prior experience of key team members. For any non-existent entity, explicitly mention it does not exist. External links may be included but they will not factor into the score.
Response
Full Name | Entity | Official Title | Prior Experience |
|---|---|---|---|
Adam McIntee | Labs | Founder & CEO | Crypto founder with multiple startups, including Spark (acquired by Portal Coin, 2024). Built Sorare Academy with FantasyFootballScout.co.uk. Previously led production for a fantasy mobile game and delivered digital programs for UK HM Government. LinkedIn: linkedin.com/in/adam-mcintee-31459a209 | X: @AdamFDF_ |
AJ Romero | Labs | CFO | Former Portfolio Manager at Sfermion (liquid crypto and venture). Early Carvana hire (scaled through IPO); FP&A at Dell; data science at Amazon; co-founder of Blackpool DAO, one of the earliest onchain gaming guilds. LinkedIn: linkedin.com/in/ajromero3 | X: @adotjdott |
n/a | Foundation | ||
n/a | DAO |
Question
Provide a structured description of the DAO's governance, powers, and economic rights. If a DAO does not exist, state so. Address the lettered items below. Even if there is no DAO, there must be an answer to (d).
Response
No DAO. Protocol IP (smart contracts, trademarks/brand, product code) is held by Sport.Fun Ltd (BVI) as the operating DevCo, ultimately owned by Sport.Fun Panama Foundation.
No DAO-executor authority. Upgrade, pause, and parameter-change authorities are held by a 3-of-5 Safe multisig at base: 0x5b2a3d19bbc6dd2f1666352a0b95d47780a8a576 administered by DevCo personnel.
No locking/staking mechanism confers additional governance rights at launch. “Soft staking” of $FUN in the in-game wallet provides tiered trading-fee rebates only; it does not confer voting rights or additional protocol rights.
Tokenholders do not have direct claims on treasury or revenue. Value accrual is programmatic: 40% of platform revenue is used to conduct open-market $FUN buybacks, 40% is used to deepen athlete-market USDC liquidity, and 20% funds growth and product development. Buybacks are executed on an ongoing, price-agnostic basis.
No DAO exists to be dissolved. Wind-up of the legal wrappers (Sport.Fun Panama Foundation and Sport.Fun Ltd BVI) would proceed under their respective constitutional documents and the applicable Panama and BVI corporate statutes.
Blockworks note: No DAO currently exists. Sport.Fun is not governed by an on-chain DAO at TGE. The items below address the required disclosures.
Question
For the Primary Foundation do the following independently. If an entity does not exist, state that explicitly. Items (a)–(f) apply only if that entity exists; state explicitly that the entity doesn't exist.
Definitions: The primary Foundation and DevCo can be explained as those entities which are directly involved in the issuance of the native token at launch.
Response
Fundación de Interés Privado (private-interest foundation), organized in the Republic of Panama. Incorporated 16 June 2025. Public Registry No. 25061744.
Ultimate parent entity. Majority owner of Sport.Fun Panama Corp (the primary DevCo / platform operator) and 100% owner of Sport.Fun Ltd (BVI) (the $FUN token issuer, which handles TGE/ICO). Holds brand/trademark rights for Sport.Fun and Football.fun. Licenses code/IP operationally to Sport.Fun Panama Corp for platform operation.
No DAO. The Foundation is the ultimate steward of the ecosystem and can authorize strategic treasury actions by Foundation Council resolution. Day-to-day treasury execution is delegated to the 3-of-5 Safe multisig (base: 0x5b2a3d19bbc6dd2f1666352a0b95d47780a8a576).
Foundation is the majority owner of Sport.Fun Panama Corp and Sport.Fun Ltd (BVI), so has direct influence over strategic decisions at both subsidiaries. Neither subsidiary controls the Foundation; UBO and control person of the Foundation is Adam McIntee.
Same 3-of-5 Safe multisig as above. Majority threshold (3/5) required for any upgrade, pause, or treasury execution.
Receives 3% of total supply (30,000,000 $FUN, unlocked at TGE) as the Foundation allocation. No other governance-approved distributions to equityholders or members currently exist. No dividends, repurchases, or programmatic distributions to Foundation officers have been formally adopted.
Blockworks note: Primary Foundation: Sport.Fun Panama Foundation
Question
For the Primary DevCo do the following independently. If an entity does not exist, state that explicitly. Items (a)–(f) apply only if that entity exists; state explicitly that the entity doesn't exist.
Definitions: The primary Foundation and DevCo can be explained as those entities which are directly involved in the issuance of the native token at launch.
Response
Panamanian sociedad anónima (corporation), organized in the Republic of Panama. Incorporated 16 June 2025. This entity develops and operates the Sport.Fun/Football.fun fantasy sports platform.
Operates the Sport.Fun/Football.fun platform. Holds the platform source code and smart-contract code for in-game athlete markets, trading, and reward logic. Trademark/brand rights roll up to the Foundation (licensed to the Corp for operational use). Wholly-owned subsidiary of Sport.Fun Panama Foundation. Does NOT hold the $FUN token contract — that is issued by Sport.Fun Ltd (BVI), the affiliated token issuer (see below).
No DAO. As the operating entity, the Corp executes day-to-day platform operations, commercial partnerships, employment, and product development. Protocol parameter changes, upgrades, and treasury execution flow through the 3-of-5 Safe multisig above. The Corp does not directly administer the $FUN token contract (that authority sits with the BVI token issuer, acting under Foundation direction).
Corp does not have direct governance influence over the Foundation; the Foundation is the Corp's sole equityholder and can direct or replace Corp leadership. Corp also has no control over the BVI token issuer (which is the Foundation's other subsidiary).
Same 3-of-5 Safe multisig. Signers: base: 0xde6498edf495bd317d9Cdbc2a89536ca256e2E0F, base: 0xae25F42Adc0390A3e3A4ba3d8e20E409A75558A1, base: 0x5aE1eAb9ccDe73B4Ef86d9cdcc47f8f1a0e50dF9 (and two additional signers).
Corp is funded by prior equity/token fundraising (see Section 9) and by platform revenue. No governance-approved programmatic distributions to equityholders currently exist. Buybacks using 40% of revenue accrue to $FUN holders generally, not to Corp equityholders specifically.
Blockworks note: Primary DevCo: Sport.Fun Panama Corp
Affiliated Token Issuer: Sport.Fun Ltd (BVI) For completeness: the $FUN token is issued by Sport.Fun Ltd (BVI) (BVI Business Company, British Virgin Islands; incorporated 1 July 2025; Registration No. 2180591). This BVI entity is scoped narrowly to $FUN token-issuance activity — ICO, TGE, and token administration — and does NOT operate the platform. It is a wholly-owned subsidiary of Sport.Fun Panama Foundation (a sister entity to Sport.Fun Panama Corp, the primary DevCo). Token-contract administration (pause, upgrade, parameter change) flows through the same 3-of-5 Safe multisig as the Foundation and Corp.
Question
Disclose launch and initial supply details in a single initial allocation schedule covering the token's launch.
Response
Blockworks note: ### (a) Launch supply totals
Genesis total supply: 1,000,000,000 $FUN (fixed). TGE date: 31 January 2026. Total unlocked at TGE (initial circulating supply): 181,222,508 $FUN (≈18.12% of total supply). Reported circulating supply at TGE: 178,000,000 $FUN (≈17.80%). Total locked at TGE: 818,777,492 $FUN (≈81.88%).
Public Sale price: $0.06 per $FUN (implied $60,000,000 fully diluted valuation at 1B supply), conducted via Legion + Kraken Launch using World Liberty Financial's USD1 stablecoin. No market-making-determined bootstrap mechanism is used.
$FUN
Fixed maximum supply of 1,000,000,000 $FUN. No inflation. No burn mechanism at the token-contract level.
(summary):
Question
Address each of the following sub-items based on the project's airdrop status. If a sub-item does not apply to the project's situation, state that explicitly.
Response
Segments — paying users of Football.fun/Sport.Fun who have transacted on the platform (i.e. paid trading fees in USDC). Non-paying Free-to-Play users are excluded. Allocation method: a discretionary “FUN Score” that weights (i) lifetime fees paid, (ii) account age, (iii) net on-platform cashflow, (iv) referrals, (v) skill/performance in tournaments, and (vi) rewards won. The scoring is designed to bias allocations toward long-term, net-positive paying users rather than one-time or farming activity.
Question
Projects must disclose all material terms of market-making arrangements that affect token liquidity. If the project has no agreements or deals with market makers, state that explicitly; doing so earns full credit. For each market maker, include in a table:
If the project has no agreements or deals with market makers, state that explicitly; doing so earns full credit. If no native tokens were loaned or allocated to market makers, state that explicitly; cash/fiat retainers or fees are not required for this item.
Response
Blockworks note: Sport.Fun has engaged three market makers: GSR, Amber, and Tophash. A portion of the Treasury — Liquidity Ops bucket (5% / 50,000,000 $FUN) is reserved to support MM operations and DEX liquidity.
Question
Projects must disclose all material terms of centralized or decentralized exchange listings that affect token liquidity. For each listing, include in a table:
If the project has no agreements or deals with CEX or DEX, state that explicitly; doing so earns full credit; cash/fiat fee amounts are not required for this item.
Response
Question
Disclose all prior token sales by the Project — including fundraising rounds, any material OTC sales to investors, and any discounted market-maker sales. For each sale, provide:
If no prior sales occurred, state that explicitly (e.g., "No prior fundraising, OTC, or discounted MM sales have occurred.").
Response
Question
If any, list prior exploits or incidents that directly affected the token, token supply, tokenholder balances, token contract, minting controls, burn mechanics, or custody of token supply. This question is not asking about general protocol, application, or smart contract exploits unless the incident directly affected the native token itself.
If no prior incidents, state this explicitly (e.g., "No exploits affecting tokenholders or protocol funds as of YYYY-MM-DD").
Response
Blockworks note: No exploits affecting tokenholders or protocol funds as of 2026-04-22.
Question
Describe material risk factors across the three categories below. Each category includes prompts to address at a minimum.
(a) Regulatory, Legal & Tax Risks — Describe how evolving laws and regulations could affect the project by answering, at a minimum, questions like:
Impact of Regulatory Change on TGE and Listings: (If applicable) How could evolving or conflicting laws and regulations affect your ability to complete the TGE, deliver tokens to purchasers, and list or maintain the token on trading venues in key jurisdictions?
Entity-Level Regulatory Impact: (If applicable) How could regulatory or legal changes impact your core entities (Foundation, DevCo, DAO, affiliated service providers), including enforcement actions, licensing requirements, or forced changes to structure or operations?
Tokenholder Tax Treatment: (If applicable) What uncertainties exist around how tokenholders may be taxed, and make clear that tokenholders are responsible for understanding their own tax obligations?
Jurisdictional & User Access Restrictions: (If applicable) If the project restricts access for certain jurisdictions or user types (e.g., U.S. persons, sanctioned countries, retail vs. professional), what are those restrictions and what risks do they create for users and for the project?
(b) Protocol, Technology & Security Risks — Describe risks to network and contract reliability, correctness, and safety by answering, at a minimum, questions like:
Bugs and Design Flaws: (If applicable) What bugs, design flaws, or implementation errors could exist in your core protocol code, smart contracts, and any bridges, rollups, or oracles that you depend on, and how could these lead to loss of funds or disruption of the protocol?
Security Measures & Their Limitations: (If applicable) What security measures have you taken (audits, formal verification, bug bounties), and what types of failures might these measures still fail to detect or prevent?
(c) Token Economics, Unlocks & Incentive Risks — Describe how the token's economic design and supply schedule could affect holders by answering, at a minimum, questions like:
Critical Economic Assumptions: (If applicable) Which economic assumptions (e.g., staking yields, fee revenue, liquidity incentives, MEV capture, demand for blockspace) are critical for protocol security, utility, and governance, and what happens if those assumptions fail?
Question
Identify to the best of your ability the token's current deployments across chains, including project-issued deployments, project-endorsed representations, and, if possible, documented third-party wrapped or bridged representations.
For each entry, provide:
Multiple entries on the same chain are permitted.
Definition: A protocol-level asset is an asset whose balances and transfers are handled directly by the blockchain's core rules, rather than by a token smart contract. For protocol-level assets without a token contract address, enter "No contract address" and identify the asset and chain.
Response
This Token Transparency Filing is provided for general informational purposes only. Blockworks reviews completeness only and does not verify or warrant the accuracy of individual answers. Sport.fun is solely responsible for the content, accuracy, and legality of its disclosures.
Governance Control over Monetary Policy & Rewards: (If applicable) To what extent can governance change monetary policy, fee parameters, or reward allocations (e.g., inflation rate, treasury flows, incentive programs), and how could such changes adversely affect tokenholders?
Response
Impact of Regulatory Change on TGE and Listings: Fantasy-sports regulation varies significantly by jurisdiction. Certain jurisdictions (e.g. the United Kingdom) apply a stricter characterization of fantasy sports; Sport.Fun has obtained legal opinions supporting its position that the platform is a skill-based game rather than gambling, and preemptively geo-blocks such jurisdictions to eliminate ambiguity. Entity-Level Regulatory Impact: Core entities — Sport.Fun Panama Foundation (Panama) and Sport.Fun Ltd (BVI) — operate under Panamanian and BVI law. Changes to Panama foundation law, BVI Business Companies Act, or applicable AML/CFT and token-issuance regimes could necessitate structural changes, additional licensing, or relocation of activities. Enforcement actions in any downstream jurisdiction (e.g. where users reside) could require operational changes, additional geo-blocking, or venue-level restrictions. Tokenholder Tax Treatment: Tax treatment of $FUN (including airdrops, staking-like fee-rebate benefits, and capital gains on secondary trading) is uncertain and varies by jurisdiction. Sport.Fun does not provide tax advice. Tokenholders are solely responsible for determining their own tax obligations and compliance, including reporting and withholding where applicable, and for consulting qualified tax advisors. Jurisdictional & User Access Restrictions: Sport.Fun geo-blocks users resident in sanctioned or high-risk jurisdictions and in jurisdictions where fantasy-sports regulation makes participation legally ambiguous (including, without limitation, certain U.S. states and the United Kingdom).
Bugs and Design Flaws: Sport.Fun's protocol is live on Base (Ethereum L2) and relies on smart contracts for athlete-share issuance, trading (AMM, xyk-style), reward allocation, and fee management. Contract bugs, design flaws in the AMM or reward logic, or errors in upgrade scripts could result in mispriced trades, incorrect reward distribution, or loss of user funds. Dependencies on Base (L1/L2 sequencer liveness, gas conditions), sports-data oracles (for match results and player performance scoring), and RPC providers introduce additional failure modes; oracle inaccuracies or feed outages could cause incorrect tournament-point settlement or temporary trading disruption. Security Measures & Their Limitations: The platform has undergone multiple independent security reviews: a Sherlock audit and a Cantina Collaborative Audit (October 29 – November 3, 2025) covering the core player, pack, and exchange contracts — producing 0 High, 1 Medium, and 3 Low/Info findings, all addressed or acknowledged. Additional controls include: a 3-of-5 Safe multisig for privileged operations; redundant RPC and data-provider setups; and progressive upgrade rollouts. These measures reduce, but do not eliminate, the risk of novel vulnerabilities, oracle manipulation, governance-key compromise, or supply-chain attacks on off-chain infrastructure.
Critical Economic Assumptions: The $FUN economic model depends on (i) sustained platform trading volume and fee revenue, which funds the 40% programmatic buyback of $FUN and the 40% fee rebates; (ii) user growth across multiple sports (football, NFL, and planned NBA/cricket/F1/golf/tennis expansions) to broaden the revenue base; (iii) continued willingness of paying users to hold $FUN for fee-rebate tiers. If trading volume materially declines, or if a dominant share of volume shifts to unfunded incentive channels, buyback volume contracts, potentially weakening price support and reducing incentive efficacy. Pack-sale revenue is expected to decline as a share of total revenue over time; the thesis requires trading-fee revenue to scale correspondingly. Governance Control over Monetary Policy & Rewards: At launch, the Foundation and DevCo (via the 3-of-5 multisig) retain the ability to adjust platform fee parameters, revenue-allocation splits, and incentive programs. Total supply is fixed at 1,000,000,000 $FUN and is not subject to inflation. However, changes to the revenue-allocation mix (e.g. the 40/40/20 buybacks/liquidity/growth split), fee tiers, emission of Community Incentives, or pace of Treasury deployment could adversely affect $FUN demand dynamics, circulating supply growth, and fee-rebate economics for holders. As governance progressively decentralizes (see Section 3(e)), tokenholder voting may in future influence these parameters, introducing governance-risk concentration among large holders.