S2 • E2 Nov 18, 2025 60 min

The Crypto ICO Comeback Nobody Saw Coming

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ICOs are back… and the chaos is real. We brought in Matty, founder of Legion, to explain why projects are suddenly rushing to raise again, what regulators might do next, and how NFTs somehow ended up in the conversation. If you think the last cycle was wild, this episode might change how you see the next one.

Key takeaways

  • Matt O'Connor, a former machine learning data scientist in TradFi, got into crypto through the 2017 ICO boom and later worked on token design for protocols including Stacks and Status.
  • He founded Legion to replace VC-only access and airdrop farming with merit-based token sales for real users.
  • Legion Score combines sub-scores for clout, development, chain interaction and endorsement, and projects choose which criteria matter for their sale.
  • Legion is MiCA-compliant and requires KYC, which Matt dislikes but sees as necessary to attract top-tier projects.
  • It acts like an IPO underwriter for ICOs, helping with retail distribution, exchange listings such as Kraken, market makers and post-TGE buyers.
  • Matt expects future market cycles to concentrate gains in tokens with real revenue and value accrual rather than broad altcoin seasons.

Rethinking who gets access to token sales

Recorded in Hodl Up's studio with Matt joining remotely, this is the hosts' first conversation with Matt O'Connor, co-founder of Legion, which they revisited later in Part 2. Legion runs regulated, merit-based token sales, a rare compliance-first model in a space the hosts describe as the Wild West.

The conversation covers Matt's origin story, why he built Legion, InfoFi and airdrops, MiCA and KYC, how Legion Score works, what projects and investors get, tokenomics lessons from his book, and where the market is heading.

From machine learning to token design

Matt worked in traditional finance as a machine learning data scientist and engineer. The 2017 ICO craze caught his attention: projects could raise hundreds of millions permissionlessly overnight. He entered crypto through parameter optimization and token design, working with projects like Stacks and Status.

Watching founders repeat the same distribution mistakes pushed him to start Legion. In Web2, companies carefully model each customer's value. "In Web3, teams were handing out tens of millions of dollars of incentives and just hoping for the best." His goal was to move beyond VCs and airdrop farmers to "a more incentive-aligned, data-driven kind of distribution."

InfoFi, airdrops and skin in the game

Matt said incentives shape behavior. Rewarding quantity leads to spam, as happened with Steemit. InfoFi done well should resemble good points programs: AI suggests quality posts, and humans on the team decide rewards.

He prefers sales to airdrops. In an Almanak sale with Cookie, users qualified for a discounted tier by posting about the project and depositing TVL. "There's a big psychological difference between getting something with a zero cost basis and something you paid for."

MiCA, KYC and privacy

Matt was candid: "I still don't like KYC personally." But top projects' lawyers will not sell tokens to unknown buyers, so compliance is needed to bring the best deals to retail. He hopes rules will eventually allow zero-knowledge identity, since KYC creates data honeypots and fake documents are easy to buy.

He explained MiCA's three token types: e-money tokens (stablecoins), asset-referenced tokens and "other tokens," which covers utility and gas tokens. Legion mainly operates in that third category.

How Legion Score works

Legion Score blends sub-scores for clout, development, chain interaction and endorsement, weighting the most Sybil-resistant signals more heavily. Projects choose their own criteria, so allocations do not always go to the same people. Founders can see who dumped tokens from previous sales, and an endorsement sub-score lets them flag great supporters or poor ones.

The table below summarizes how a Legion sale works as Matt described it.

StepWhat happens
VettingLegion meets the team; not a permissionless platform
SetupKYB and services agreement
PlanningSale mechanism, date and partners such as Kraken
DepositsUsers contribute on Legion or a partner front end
AllocationProject reviews applicants using Legion Score data
RefundsUnfilled portions returned
TGETokens deposited into the contract and claimed with vesting

For investors, the draw is access to quality deals. Matt pointed to Yield Basis, from Curve's founder, which was 100x oversubscribed. "Even if you're not rich enough to be an accredited investor, even if you didn't go to some fancy school, you can still get access."

Lessons from tokenomics

Matt wrote a free, open-source book on token design. A key lesson: do not launch a token before product-market fit, because "you almost have two products." Another, learned through Legion, is that fundamentals are not everything. Even well-designed tokens can stumble on market makers, listings and other go-to-market steps.

He would avoid gaming tokens and is most interested in prediction markets built for Web2 audiences. "A token is not a match. It doesn't start the fire, but it's gasoline."

Where the market is heading

Matt expects Bitcoin to keep a more permanent bid from ETFs, with volatility replacing the classic four-year cycle. Beyond Bitcoin, gains will concentrate in tokens with revenue, growth and mindshare. "There won't be what there used to be in other cycles, an altcoin season where literally everything goes up 20x or more."

FAQ

Frequently asked questions

What is Legion?

Legion is a regulated platform for merit-based token sales. Projects choose which investors receive allocations using Legion Score data, and Legion helps with distribution, exchange listings and market makers, acting similarly to an IPO underwriter for ICOs.

How does Legion Score work?

Legion Score combines sub-scores for clout, development, chain interaction and endorsement, weighting the most Sybil-resistant signals more heavily. Projects pick the criteria that matter to them, and past behavior, such as dumping tokens from earlier sales, is visible to future projects.

What are the three token types under MiCA?

MiCA separates e-money tokens, which are essentially stablecoins, asset-referenced tokens that track other assets, and a catch-all category of other tokens that includes utility and gas tokens. Legion mainly supports sales in that third category.

Can bots game Legion Score?

Not easily. Matt O'Connor says bots can never be fully eliminated, but combining GitHub activity, social accounts and long on-chain wallet histories makes large-scale Sybil attacks far more expensive, giving real users a fairer chance at allocations.

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