Zora
Networks+2 · NFT Launchpad+1Token Transparency Filing
Project & Team
Description of Project
Provide a concise narrative that clearly states each of (a)–(e) below.
- (a) Problem the project solves — The problem the project is solving.
- (b) Operational priorities — Provide a high-level description of how the project expects to support ongoing development and operations over time.
- (c) High-level project overview — How the project works at a high level.
- (d) Primary token functions — The primary functions of the token (e.g. gov participation).
- (e) Control surface reliance — If any, briefly describe the anticipated or possible evolution of the protocol's governance/control model.
(a) Problem the project solves
Zora Labs, Inc. has developed an onchain social network and protocol for creating, discovering, and exchanging blockchain assets. The Zora Protocol enables users to create, buy, sell, and curate onchain digital media content, and it turns content posted on the network into tradable coins so creators earn directly from trading activity around their work.
(Source: MiCAR white paper, Understanding Creator Coins)
(b) Operational priorities
Zora Labs, Inc. funds operations and growth with raised capital and receives a portion of gas fees for transactions executed on the Zora Network. Zora Labs, Inc. operates the Creator Rewards program, under which the transaction cost paid by the collector is shared with creators.
(Source: MiCAR white paper)
(c) High-level project overview
Zora Labs, Inc.'s primary offerings are the Zora web and mobile application platform and the Zora Protocol, which is open-source smart contract infrastructure. The Zora Protocol supports a decentralized and permissionless model and allows third-party developers and organizations to build customized platforms and experiences. Every Zora account has its own Creator Coin with a fixed supply of 1 billion coins, 50% of which is available to the open market and 50% of which vests linearly to the creator over 5 years. Content coins created from posts are paired with the poster's Creator Coin, and Creator Coins are paired with $ZORA.
(Source: MiCAR white paper, Understanding Creator Coins, Zora coin rewards documentation)
(d) Primary token functions
$ZORA is designed for entertainment and social engagement purposes and to incentivize activities on the Zora Protocol. The Zora Protocol uses $ZORA as the default reward token for creator and platform rewards and as liquidity for newly issued creator markets. On V4 coins, the protocol collects trading fees on every swap, converts them through multi-hop swaps, and distributes rewards to recipients in $ZORA. $ZORA carries no governance rights and no claim on equity ownership in Zora or its products.
(Source: MiCAR white paper, Zora coin rewards documentation, The Ticker is $ZORA)
(e) Control surface reliance
$ZORA is immutable. No party, including the issuer, can modify the token contract, and the token launched without upgradable proxies or centralized control. Zora Labs, Inc. retains sole discretion to implement, modify, or cancel product features on the Zora web and mobile applications that use $ZORA, without prior notice.
(Source: MiCAR white paper)
Known Project Team
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.
Full Name | Entity | Official Title | Prior Experience |
|---|---|---|---|
Jacob Horne | Labs | Chief Executive Officer | Jacob Horne co-founded Zora in 2020 after working at Coinbase from January 2017 to March 2020 as a Product Manager focused on Consumer Core and new initiatives, where he worked on USDC, Paradex, and Coinbase Ventures (The Org, TechCrunch, MiCAR white paper). |
LaDarius “Dee” Goens | Labs | Chief Operating Officer | Dee Goens co-founded Zora in 2020. At Coinbase he served as Marketing Manager for Brand Partnerships, where he launched brand partnerships and influencer marketing programs, and earlier as Technology Program Manager for Operations. Before Coinbase he was an Emerging Technology Risk Senior Associate at KPMG US specializing in blockchain and distributed ledger technology, and he previously worked at Merrill Lynch (ZoomInfo, TechCrunch, MiCAR white paper). |
Tyson Battistella | Labs | Chief Technology Officer | Tyson Battistella co-founded Zora in 2020 and leads engineering. He previously worked at Coinbase as a Software Engineer, where he was responsible for creating Coinbase Commerce. He attended the University of Victoria (Crunchbase, RootData, MiCAR white paper). |
The project does not operate a foundation entity. Zora Labs, Inc. is the sole entity identified in the project's public legal disclosures. (Source: MiCAR white paper) | Foundation | ||
The project does not have a DAO or onchain governance mechanism, and $ZORA does not entitle holders to governance rights. (Source: Claim FAQ, The Ticker is $ZORA) | DAO |
DAO Structure
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).
- (a) IP ownership & control — State what IP the DAO owns or controls (e.g., codebases/repos, trademarks/brands). Note any license if relevant.
- (b) Contract/admin powers — List onchain or administrative authorities and limits: pause/upgrade roles (e.g., multisig pause), governance-executor authorities, and the method of authority for each (e.g., veto, majority, super-majority).
- (c) Locked-token rights (conditional) — If locking/staking for additional rights exists, explain the additional rights and what tokenholders can and cannot decide. If no locking mechanism exists, leave absent.
- (d) Value accrual & holder rights — If any, describe the current rights of tokenholders over revenue distribution and the treasury.
- (e) Dissolution authority — State who can dissolve/wind up the DAO and by what mechanism (e.g., onchain vote threshold, board resolution of a legal wrapper).
(a) IP ownership & control
No DAO exists, so no DAO owns or controls project IP. Zora Labs, Inc. develops and maintains the open-source Zora Protocol codebase, which is published in the ourzora GitHub organization.
(Source: MiCAR white paper, Zora Protocol repository)
(b) Contract/admin powers
The $ZORA token contract is immutable. Once deployed, the token contract code cannot be altered, upgraded, paused, or otherwise modified by Zora or any other party. The official Zora token contracts repository identifies Zora.sol as the main Zora token contract. BaseScan shows the ZORA token contract source code as verified and identifies the contract name as Zora. BaseScan shows the community-claim contract at 0x0000000002ba96C69b95E32CAAB8fc38bAB8B3F8 as source-code verified and identifies the verified Solidity contract as ZoraTokenCommunityClaim. The ZoraTokenCommunityClaim contract stores immutable allocationSetter and admin addresses and uses allocationSetupComplete and claimStart state for claim setup and opening. The official Base address manifest sets ZORA_TOKEN to 0x1111111111166b7FE7bd91427724B487980aFc69 and ZORA_TOKEN_COMMUNITY_CLAIM to 0x0000000002ba96C69b95E32CAAB8fc38bAB8B3F8. The official Base claim configuration identifies admin as 0x078362961fCF3E48Cdc850F9cBCa335d0b47d968 and allocationSetter as 0xe847eBff4d1B7ae3691f238c5Cd5Cf691Fd1F413.
(Source: Token launch details, Claim FAQ, Zora token repository, BaseScan token page, BaseScan claim contract, Base address manifest, Base claim configuration)
(c) Locked-token rights (conditional)
No locking or staking mechanism exists that grants $ZORA holders additional rights. $ZORA does not entitle holders to governance rights.
(Source: Claim FAQ)
(d) Value accrual & holder rights
Holders of $ZORA hold no rights over revenue distribution or the treasury. Holders of $ZORA do not acquire contractual rights or obligations from the issuer, and $ZORA does not entitle holders to any claim on equity ownership in Zora or its products.
(Source: MiCAR white paper, Zora is Live blog)
(e) Dissolution authority
No DAO exists, so no dissolution authority or wind-up mechanism for a DAO exists.
(Source: Claim FAQ)
Blockworks note: The project does not have a DAO or onchain governance mechanism.
(Source: Claim FAQ)
Primary Foundation
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.
- (a) Entity — Type and jurisdiction.
- (b) IP ownership & control — What IP the entity owns/controls (repos/code, trademarks/brand; license optional) and an explanation of any subsidiary entities.
- (c) Powers over DAO, treasury, protocol-controlled resources, and token administration — If any, describe the current powers over DAO governance, treasury actions, protocol-controlled resources (e.g. revenue), token administration, or reward parameters, and the method/threshold for each.
- (d) Powers over DevCo — Explain whether the foundation can exert direct or indirect influence over decision-making of the DevCo.
- (e) Contract/admin powers — Pause/upgrade/governance-executor authorities and the method/threshold for each (e.g., veto/majority/super-majority; "3/5 multisig").
- (f) Current economic arrangements and distribution policies — Describe any current governance-approved, contractual, or programmatic mechanisms, if any, by which protocol-controlled resources, treasury assets, fees, revenue, rewards, or token distributions may be directed to this entity, its equityholders, contributors, or other participants. If no such mechanism currently exists, state that explicitly. Do not discuss hypothetical future dividends, repurchases, or distributions unless formally adopted.
(a) Entity
The project does not operate a foundation entity.
(b) IP ownership & control
The project does not operate a foundation entity.
(c) Powers over DAO, treasury, protocol-controlled resources, and token administration
The project does not operate a foundation entity.
(d) Powers over DevCo
The project does not operate a foundation entity.
(e) Contract/admin powers
The project does not operate a foundation entity.
(f) Current economic arrangements and distribution policies
The project does not operate a foundation entity.
Blockworks note: The project does not operate a foundation entity. Zora Labs, Inc., a Delaware corporation, is the entity that prepared and filed the MiCAR white paper and the entity directly involved in the issuance of $ZORA. Items (a) through (f) do not apply because no foundation exists.
(Source: MiCAR white paper)
Primary Dev Co
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.
- (a) Entity — Type and jurisdiction.
- (b) IP ownership & control — What IP the entity owns/controls (repos/code, trademarks/brand; license optional) and an explanation of any subsidiary entities.
- (c) Powers over DAO, treasury, protocol-controlled resources, and token administration — If any, describe the current powers over DAO governance, treasury actions, protocol-controlled resources (e.g. revenue), token administration, or reward parameters, and the method/threshold for each.
- (d) Powers over Foundation — Explain whether the DevCo can exert direct or indirect influence over decision-making of the Foundation.
- (e) Contract/admin powers — Pause/upgrade/governance-executor authorities and the method/threshold for each (e.g., veto/majority/super-majority; "3/5 multisig").
- (f) Current economic arrangements and distribution policies — Describe any current governance-approved, contractual, or programmatic mechanisms, if any, by which protocol-controlled resources, treasury assets, fees, revenue, rewards, or token distributions may be directed to this entity, its equityholders, contributors, or other participants. If no such mechanism currently exists, state that explicitly. Do not discuss hypothetical future dividends, repurchases, or distributions unless formally adopted.
(a) Entity
Zora Labs, Inc. is a Delaware corporation. It is a privately held technology company founded in 2020 that specializes in blockchain-based application platforms and software.
(Source: MiCAR white paper)
(b) IP ownership & control
Zora Labs, Inc. is the developer and primary maintainer of the Zora Protocol, which is open-source smart contract infrastructure published as a monorepo in the ourzora GitHub organization. Zora Labs, Inc. operates the Zora web and mobile applications, and the Zora application terms are entered into between Zora Labs, Inc. and the user or represented legal entity. The application terms define the Services as one method for accessing the Zora Protocol and state that the defined term "Services" does not include the Zora Protocol. The company has not publicly disclosed any subsidiary entities.
(Source: MiCAR white paper, Zora Protocol repository, Zora application terms)
(c) Powers over DAO, treasury, protocol-controlled resources, and token administration
No DAO exists for Zora Labs, Inc. to hold powers over. Zora Labs, Inc. controls the treasury allocation of 2,000,000,000 $ZORA, which unlocks monthly over 48 months starting six months after TGE, and Zora Labs, Inc. determines the distribution of the incentives allocation over time. Zora Labs, Inc. holds no token administration powers over the deployed $ZORA contract because the contract is immutable and cannot be altered, upgraded, paused, or modified by any party. Zora Labs, Inc. does not maintain custody of holders' $ZORA.
(Source: Tokenomics, Token launch details, MiCAR white paper)
(d) Powers over Foundation
The project does not operate a foundation entity, so no foundation exists for Zora Labs, Inc. to influence.
(Source: MiCAR white paper)
(e) Contract/admin powers
Zora Labs, Inc. holds no pause, upgrade, or governance-executor authority over the $ZORA token contract, which is immutable. The claim infrastructure identifies an admin at 0x078362961fCF3E48Cdc850F9cBCa335d0b47d968 and an allocationSetter at 0xe847eBff4d1B7ae3691f238c5Cd5Cf691Fd1F413, both stored as immutable addresses in the ZoraTokenCommunityClaim contract. Zora states in its application terms that it is not a wallet provider, exchange, broker, dealer, financial institution, payments processor, money services business, or creditor, and that it does not have custody or control over tokens or blockchains users interact with.
(Source: Token launch details, Base claim configuration, BaseScan claim contract, Zora application terms)
(f) Current economic arrangements and distribution policies
Zora Labs, Inc. receives a portion of gas fees for transactions executed on the Zora Network, and the platform retains a share of coin trading fees under the protocol's reward split. The treasury allocation of 20% of supply and the team allocation of 18.9% of supply vest to Zora Labs, Inc. and its team members under the schedules disclosed in the tokenomics documentation. The company has not publicly disclosed any mechanism directing protocol-controlled resources, treasury assets, fees, revenue, rewards, or token distributions to its equityholders.
(Source: MiCAR white paper, Tokenomics, Zora coin rewards documentation)
Token Supply & Allocations
Initial Allocation
Disclose launch and initial supply details in a single initial allocation schedule covering the token's launch.
- (a) Launch supply totals — The total number of tokens issued at launch, the total number of tokens locked at launch or the total number of tokens unlocked at launch.
- (b) Recipient categories & use of funds — The recipient categories with brief explanations as to how the category will use the tokens so an auditor can distinguish each bucket.
- (c) Initial price per token (if applicable) — The initial price per token at TGE. If the token launched via a liquidity bootstrapping mechanism, auction, or other price-discovery process rather than a fixed offering price, describe that mechanism and the final market set price instead. If no fixed price was set, state so.
- (d) Ticker / market symbol — The ticker/market symbol.
- (e) Total supply & supply regime — The total supply and whether the supply is fixed (if not explain inflation rate or deflation rate).
- (f) Initial vesting / release schedules — The initial vesting/release schedules (identify which categories/recipients are subject to vesting and the high-level timing logic).
(a) Launch supply totals
$ZORA launched with a total supply of 10,000,000,000 tokens on Base. The airdrop, community incentives, and community liquidity categories, together 35% of supply or 3,500,000,000 tokens, launched without lockup restrictions. The treasury, team, and investor categories, together 65% of supply or 6,500,000,000 tokens, launched locked under vesting schedules. As of August 2026, approximately 4,470,000,000 $ZORA, 44.7% of total supply, is circulating.
(b) Recipient categories & use of funds
Six categories received the launch supply. Investors and strategic contributors received 26.1% (2,610,000,000 ZORA), allocated to the advisors and backers who guided Zora′s development. Community incentives received 20 ZORA), allocated to the advisors and backers who guided Zora's development. Community incentives received 20% (2,000,000,000 ZORA), allocated to the advisors and backers who guided Zora′s development. Community incentives received 20 ZORA) for future community initiatives, with distribution determined by the team over time. Treasury received 20% (2,000,000,000 $ZORA). Team received 18.9% (1,890,000,000 $ZORA), allocated to current and future team members. The retroactive airdrop received 10% (1,000,000,000 $ZORA), distributed to historical users of Zora including creators, collectors, and developers. Community liquidity received 5% (500,000,000 $ZORA) for liquidity provisioning as needed with exchanges and market makers.
(c) Initial price per token (if applicable)
Zora did not set a fixed offering price at TGE. Price discovery occurred through spot listings on centralized exchanges and through Uniswap liquidity pools beginning April 23, 2025. KuCoin opened trading with a call auction from 12:00 to 13:00 UTC on April 23, 2025, and Zora seeded the ZORA-USDC pool on Uniswap v3 with $11 million of Treasury liquidity across single-side positions of $10 million of ZORA and $1 million of USDC.
(d) Ticker / market symbol
The ticker is $ZORA.
(e) Total supply & supply regime
$ZORA has a fixed total supply of 10,000,000,000 tokens and no continuous minting mechanism beyond the initial token logic. The official deployment configuration lists an initial mint amount of 10,000,000,000 for zora to 0x078362961fCF3E48Cdc850F9cBCa335d0b47d968. The official Base contract address is 0x1111111111166b7fe7bd91427724b487980afc69, and BaseScan shows the token contract with 18 decimals, verified source code, and a max total supply of 10,000,000,000 ZORA.
(f) Initial vesting / release schedules
The token contract was deployed on Base on March 11, 2025, and the public launch, exchange trading, and airdrop claims began on April 23, 2025, the issuance date stated in the MiCAR white paper. Treasury tokens unlock monthly over 48 months starting six months after TGE. Team and investor tokens unlock monthly over 36 months starting six months after TGE. The airdrop, community incentives, and community liquidity categories are not subject to lockup restrictions.
Blockworks note: Two of the six recipient categories carry no published use-of-funds detail beyond the category label itself. Treasury is disclosed as an allocation to treasury without a stated spending mandate, and investors is disclosed as an allocation to investors and strategic contributors without further description. Community incentive distribution is explicitly left to team discretion over time rather than committed to a published program.
(Source: The Ticker is $ZORA, $ZORA is live, Zora Help Centre: Tokenomics, $ZORA MiCAR Whitepaper, What is the $ZORA Contract Address?, Adding liquidity on $ZORA, KuCoin listing announcement, BaseScan: ZORA token page, CoinGecko: Zora (ZORA), Tokenomist: Zora)
Airdrop Process
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.
- (a) Planned but not yet executed airdrop — If the project has planned but not yet airdropped, commit to publishing a recipient wallet list in a public channel and provide it to Blockworks quarterly until the initial TGE airdrop is fully completed. Additionally, generally state the possible target user segments (e.g., "stakers of X," "Aave users") and the allocation method (e.g., proportional to ve-balance or net position).
- (b) Executed airdrop — If the project has already airdropped, point to a per-address source such as CSV/TSV/JSON files, a Dune table, a full Merkle dump, GitHub repo files embedding per-address allocations, or RPC endpoints that expose claim/amount data; explorer links alone do not count. Additionally, clearly state covered user segments (e.g., "stakers of X," "Aave users") and the allocation method (e.g., proportional to ve-balance or net position).
- (c) No airdrop planned or conducted — If the project does not plan to conduct an airdrop for TGE and has never conducted one, state so plainly (e.g., "We have never conducted an airdrop to date and do not plan to execute one").
-
Planned but not yet executed airdrop: Not applicable. Zora's TGE airdrop has been executed. Unclaimed allocations remain claimable indefinitely with no deadline, but no planned-but-unexecuted airdrop exists.
-
Executed airdrop: Per-address source: The airdrop allocated 1,000,000,000 $ZORA to 2,415,024 unique addresses. The official eligibility article links to per-address source data published on Dune under zora-airdrop-source-data. Unclaimed allocations have no claim deadline and remain in the claims contract at 0x0000000002ba96c69b95e32caab8fc38bab8b3f8 indefinitely. (Source: Airdrop eligibility article, Claim FAQ)
Covered user segments and allocation method: The airdrop covered historical users of Zora across two snapshots. Snapshot 1 covered activity from 00:00:00 UTC January 1, 2020 until 14:00:00 UTC March 3, 2025, and Snapshot 2 covered activity from 14:00:00 UTC March 3, 2025 until 00:00:00 UTC April 20, 2025. Allocation was calculated based on activity on Zora and engagement with the current protocol and legacy versions. Eligible activity included posting, minting, trading, or referring on Zora, and only ERC-721, ERC-1155, and ERC-20 contracts created by official Zora factories were considered for allocation. Personal and work-related wallets of past and present Zora employees were excluded, and addresses flagged as high-risk by Elliptic were not eligible. (Source: Airdrop eligibility article)
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No airdrop planned or conducted: Not applicable. Zora has conducted an airdrop.
Transactions & Market Structures
Market Maker Agreements & Deals
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:
- (a) Market maker's name — the market maker's name;
- (b) Token allocation or loaned amount — the token allocation or loaned amount as a percentage of total supply;
- (c) Duration/term of agreement — the duration/term of the agreement; and, where applicable,
- (d) Name of agreement structure — label the financial vehicle being used in the agreement (i.e. loan, option/call, retainer model) without describing trading strategy or expected outcomes.
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.
Blockworks note: Zora has not publicly disclosed any market maker agreements, market maker names, committed token amounts, terms, or agreement structures. The tokenomics documentation allocates the 5% liquidity category for liquidity provisioning as needed with exchanges and market makers without identifying counterparties or terms. Zora publicly disclosed its own liquidity provisioning on Uniswap v3. It added $11 million of liquidity from the Treasury to the ZORA-USDC pool through two single-side positions of $10 million of ZORA and $1 million of USDC, stated that it was not actively managing those positions and was not looking to profit from the pools, and committed to keep all liquidity and generated fees from the three positions in the ZORA-USDC pool for at least 3.888 million blocks, a period of approximately three months. Under the protocol's coin mechanics, Zora deploys initial Uniswap markets when coins are created, Creator Coins and Pairs carry a 1% trading fee on all trades, and the LP Contribution share of fees is used to add single-sided liquidity outside the current trading range as permanent liquidity.
(Source: Tokenomics, Adding Liquidity blog, Creator coin rewards article)
CEX / DEX Agreements & Deals
Projects must disclose all material terms of centralized or decentralized exchange listings that affect token liquidity. For each listing, include in a table:
- (a) Exchange name / DEX pool — the exchange name (and, for DEX, the specific pool/pair);
- (b) Token allocation for listing — the token allocation supplied or committed for listing as a percentage of total supply;
- (c) Term Duration — the duration/term of any listing lockups, liquidity, or incentive programs; and, where applicable,
- (d) Native-token listing fees — whether any listing fees were paid in native tokens, with amounts (tokens or % of supply), recipients, and any vesting or lock terms tied to the partnership.
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.
Blockworks note: Zora announced that $ZORA would be available on Coinbase, Bybit, Bitget, Kraken, Binance Alpha, KuCoin, Bithumb, and Gate starting on the April 23, 2025 launch date. The MiCAR white paper listed Payward Global Solutions Limited trading as Kraken, Bitstamp Europe S.A., Bitvavo B.V., and potentially Coinbase Luxembourg S.A. as trading venues. Bitget listed ZORA in its Innovation, NFT and Public Chain Zone with ZORA/USDT as the spot pair, opened trading on April 23, 2025 at 13:00 UTC, and opened withdrawals on April 24, 2025 at 14:00 UTC. KuCoin listed ZORA/USDT on its spot platform with a call auction from 12:00 to 13:00 UTC on April 23, 2025 and opened withdrawals on April 24, 2025 at 10:00 UTC. Kraken's MiCA white paper states that Kraken sought admission to trading of ZORA to make secondary trading available to consumers on the Kraken Trading platform in compliance with MiCA, with a starting date of April 23, 2025. Uniswap users can swap and provide liquidity on Zora Network through the Uniswap interface via Uniswap v2 and Uniswap v3, and Zora collects fees from its Uniswap v3 Treasury positions every 14 days for redeployment into a full-range position. Zora has not publicly disclosed any exchange-specific token allocations, listing term durations, or native-token listing fees tied to the listed venues.
(Source: Zora is Live blog, MiCAR white paper, Bitget listing announcement, KuCoin listing announcement, Kraken MiCA white paper, Uniswap blog, Adding Liquidity blog)
Financial Disclosures & Risks
Prior Token Sales & Fundraising
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:
- (a) Series Name
- (b) Early-Stage Investment Instrument used (i.e. SAFT, STAMP, SAFE, SAFE+Token Warrant, etc.)
- (c) Date of sale (at least month & year)
- (d) Number of tokens sold (or % of total supply)
- (e) Vesting schedule
If no prior sales occurred, state that explicitly (e.g., "No prior fundraising, OTC, or discounted MM sales have occurred.").
- Series Name: Preferred share rounds
- Investment Vehicle: Equity
- Date Of Sale: Since March 2020, with the most recent round completed in 2022 (MiCAR white paper)
- Number of tokens sold: Zero tokens sold. Zora Labs, Inc. raised $60 million over four preferred share rounds (MiCAR white paper).
- Vesting Schedule: Not applicable. The rounds were equity sales, not token sales (MiCAR white paper).
- Series Name: Seed
- Investment Vehicle: Equity
- Date Of Sale: October 2020 announcement, $2 million led by Kindred Ventures with participation from Coinbase Ventures, Trevor McFedries, Alice Lloyd George, and Jeff Staple (TechCrunch)
- Number of tokens sold: Zero tokens sold (MiCAR white paper).
- Vesting Schedule: Not applicable. The round was an equity sale (MiCAR white paper).
- Series Name: Series A
- Investment Vehicle: Equity
- Date Of Sale: May 2022, $50 million led by Haun Ventures at a $600 million valuation with participation from Coinbase Ventures and Kindred Ventures (TechCrunch)
- Number of tokens sold: Zero tokens sold (MiCAR white paper).
- Vesting Schedule: Not applicable. The round was an equity sale (MiCAR white paper).
- Series Name: SEC Form D equity offering
- Investment Vehicle: Equity
- Date Of Sale: First sale April 7, 2022 (SEC Form D 2022)
- Number of tokens sold: Zero tokens sold. The Form D lists a $50,000,000 total offering amount and $41,755,736 total amount sold in equity securities (SEC Form D 2022).
- Vesting Schedule: Not applicable. The offering was an equity sale (SEC Form D 2022).
- Series Name: SEC Form D equity offering
- Investment Vehicle: Equity
- Date Of Sale: First sale May 1, 2024 (SEC Form D 2024)
- Number of tokens sold: Zero tokens sold. The Form D lists a $2,624,584 total offering amount and $2,624,584 total amount sold in equity securities (SEC Form D 2024).
- Vesting Schedule: Not applicable. The offering was an equity sale (SEC Form D 2024).
Blockworks note: Zora Labs, Inc. has not conducted any token sales. The MiCAR white paper states that the issuance of $ZORA was not part of any fundraising efforts of Zora Labs, Inc. All prior fundraising was conducted through equity instruments at the corporate level, and the 26.1% investor allocation of $ZORA vests monthly over 36 months starting six months after TGE.
(Source: MiCAR white paper, Tokenomics)
Previous Exploits Affecting The Native Token
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").
- (a) Date & component affected — Date (YYYY-MM or YYYY-MM-DD), chain(s)/component affected.
- (b) Exploit vector summary — Plain-language summary of the exploit vector (what the hack was).
- (c) Quantified impact — Quantified impact (assets/tokens affected or a clear "no loss of funds" statement).
- (d) Remediation/response taken — Remediation/response taken (patches, upgrades, governance actions, compensation).
- (e) Current status — Current status (resolved, in litigation, under investigation, refunded, etc.).
- (f) References (optional) — References (optional): link(s) to post-mortem/advisory/PR.
(a) Date & component affected
On April 24, 2025, one day after the public launch, an attacker extracted funds through an interaction between the ZoraTokenCommunityClaim contract at 0x0000000002ba96C69b95E32CAAB8fc38bAB8B3F8 on Base and the permissionless 0x Settler contract.
(Source: Blockaid post-mortem, Three Sigma analysis)
(b) Exploit vector summary
Blockaid characterized the incident as a composability attack in which independently secure systems interacted unexpectedly. No ZORA or 0x contracts were compromised. Zora's airdrop process assigned $ZORA tokens to the permissionless 0x Settler contract, and the attacker used the Settler to execute the claim for that allocation.
(Source: Blockaid post-mortem)
(c) Quantified impact
The claim transferred 5,500,777 $ZORA, and the incident extracted $128,000 in assets. The affected tokens were airdrop tokens assigned to the 0x Settler contract address, and no user wallets or protocol contracts were compromised.
(Source: Blockaid post-mortem)
(d) Remediation/response taken
Zora Labs, Inc. has not published a formal public post-mortem or patch announcement for the incident. Three Sigma confirmed the absence of a formal public post-mortem or patch announcement as of its April 29, 2025 analysis.
(Source: Three Sigma analysis)
(e) Current status
The extracted funds have not been recovered, and Zora Labs, Inc. has not publicly disclosed any subsequent recovery, compensation, or enforcement action related to the incident.
(Source: Three Sigma analysis, Blockaid post-mortem)
(f) References (optional)
(Source: Blockaid post-mortem, Three Sigma analysis)
Material Risk Factors (Regulation, Technology, Token Economics)
Describe material risk factors across the three categories below. Each category includes prompts to address at a minimum.
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(a) Regulatory, Legal & Tax Risks — Describe how evolving laws and regulations could affect the project by answering, at a minimum, questions like:
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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?
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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?
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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?
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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?
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(b) Protocol, Technology & Security Risks — Describe risks to network and contract reliability, correctness, and safety by answering, at a minimum, questions like:
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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?
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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?
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(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:
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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?
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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?
(a) Regulatory, Legal & Tax Risks
The MiCAR white paper identifies the risk that evolving legal and compliance frameworks impose new restrictions on $ZORA trading or use in software applications, and the risk that Zora Labs, Inc. fails to secure required licenses, permits, or authorizations in some jurisdictions. Zora Labs, Inc. monitors the evolving legal and regulatory landscape in key jurisdictions and reserves the right to restrict availability of $ZORA where required by law or deemed prudent. Zora's airdrop FAQ identifies airdrop receipt as taxable income in many jurisdictions and places responsibility on tokenholders for understanding their own tax obligations. The airdrop was not intended for audiences residing in the UK or the EU or any jurisdiction where it is not permitted by applicable law. Zora prohibits use of its services by users located in, incorporated in, or accessing the platform from a jurisdiction subject to comprehensive U.S. sanctions. Kraken Canada performed due diligence on ZORA before listing it and determined that ZORA is unlikely to be a security or derivative under Canadian securities legislation.
(Source: MiCAR white paper, Claim FAQ, Token launch details, Kraken Canada statement)
(b) Protocol, Technology & Security Risks
The token contract is immutable. Once deployed, its code cannot be altered, upgraded, paused, or otherwise modified by Zora or any other party, and any issues or vulnerabilities discovered post-deployment cannot be remediated by Zora. Zellic conducted a Zora Token smart-contract security assessment from March 10, 2025 to March 11, 2025 covering the Zora and ZoraTokenCommunityClaim programs. Zellic discovered one finding in the scoped Zora Token contracts and classified it as informational, with zero critical, high, medium, or low findings in the impact breakdown. 0xMacro published a Zora A-1 security audit dated September 6, 2024 that listed 2 Medium issues, 1 Low issue, 1 Code Quality issue, and 1 Gas Optimization issue for the audited Zora Solidity-contract scope. The 0xMacro assessment showed that 1 of the 2 Medium issues was acknowledged and 1 was addressed, and the report stated that Zora was quick to respond to the issues. Zora's bug bounty program lists Zora Protocol smart contracts as in scope with rewards up to $40,000, and reports must be sent to security@zora.co. The Zora Protocol repository links to the bug bounty program for reporting security vulnerabilities. Blockaid characterized the April 24, 2025 claim-contract and 0x Settler incident as a composability attack in which independently secure systems interacted unexpectedly without any compromised contracts. Zora warns that malicious actors impersonate Zora accounts and affiliates, states that Zora never asks for private keys, seed phrases, or passwords, and states that official employee email addresses end in @zora.co, @zora.com, or @ourzora.com. Zora's application terms permit interruption of access to the Services for equipment malfunction, updating, maintenance, repair, geographic restrictions, potential Terms violations, or other actions Zora elects to take in its sole discretion. The application terms also state that Zora does not have custody, possession, or control over user wallet contents or crypto assets and that the user is solely responsible for maintaining wallet security. The MiCAR white paper identifies malware, denial-of-service attacks, consensus-based attacks, Sybil attacks, spoofing, governance attacks, and exploitable code as vulnerabilities of the underlying network. Kraken Canada identified general ZORA risks including short history risk, volatility risk, liquidity risk, demand risk, forking risk, code defects, cryptography risk, regulatory risk, concentration risk, electronic trading risk, and cyber security risk.
(Source: Token launch details, Zellic audit report, 0xMacro audit, Bug bounty program, Zora Protocol repository, Blockaid post-mortem, Scam awareness article, Zora application terms, MiCAR white paper, Kraken Canada statement)
(c) Token Economics, Unlocks & Incentive Risks
$ZORA has a fixed total supply of 10,000,000,000 tokens and no continuous minting mechanism beyond the initial token logic. As of August 2026, approximately 4,470,000,000 $ZORA, 44.7% of total supply, has been unlocked, and the remaining locked supply releases under the disclosed vesting schedules. Treasury tokens unlock monthly over 48 months starting six months after TGE, and team and investor tokens unlock monthly over 36 months starting six months after TGE, so 65% of total supply enters circulation progressively through the vesting period. The distribution of the 20% incentives allocation is determined over time by the team. Zora added $11 million of Treasury liquidity to the ZORA-USDC pool on Uniswap v3 and committed to keep that liquidity and generated fees in the pool for at least 3.888 million blocks, approximately three months. Creator Coins and Pairs carry a 1% trading fee on all trades, and the LP Contribution share of fees adds single-sided liquidity outside the current trading range as permanent liquidity. $ZORA does not entitle holders to governance rights, so holders hold no mechanism to direct treasury spending, incentive distribution, or protocol parameters. Zora Labs, Inc. retains sole discretion to implement, modify, or cancel product features that use $ZORA without prior notice, so the token's utility within the Zora applications depends on decisions of Zora Labs, Inc.
(Source: MiCAR white paper, Tokenomics, Tokenomist, CoinGecko, Adding Liquidity blog, Creator coin rewards article, Claim FAQ)
This Token Transparency Filing is provided for general informational purposes only and does not verify or warrant the accuracy of individual answers.
