Good question. We definitely believe our token won't fail the howey test because we are not offering "to invest" into an asset versus "money".

First about the "to invest" statement: DTC will be provided through first an Airdrop to EXISTING users, i.e we won't ask to join a telegram group, to create an account or require any other whatsoever marketing actions to boost DTube popularity in return for receiving DTC.

Second, about the "money" statement.
DTC is a utility token. Through the common run of the network, DTC works as a digital intangible asset as it can be UTILIZED to boost content popularity on the platform, to reward other users by voting and to access premium features or unlock specific in-app gaming features (exp. 2020). It basically follows the same principles of a free to play gaming model with in-app purchases (like candy crush for example).

The SEC considers most cryptocurrency tokens as being securities but why?

• First, because a vast majority of the use made from crypto today is by issuing ETH ERC-20 tokens as a mean to raise funding to develop a project.
  It used to be done via ICOs without many rules, and has now evolved to a more regulated version through Security Token Offerings (STO) under the Reg. A filing (the PROPS network has been granted of such this week -after a 2 year evaluation from the SEC...).
  I actually like STOs, it is one of the rare use cases where the blockchain adds SIMPLICITY to an existing concept by easing investor onboarding through the sale of company shares held in a token and where shareholder's agreement is executed by a smart contract => this is much easier than having to go to a notary each time the company onboards a new investor. And it is dematerialised, no paperwork needed anymore.
• Secondly, most announced tokenized business models bears no real utility in reality. There are very few blockchain projects that currently have developed real utility tokens.

DTube Coins are one of the first real utility tokens based on a sound economic cycle. Authorities and governments are going to understand this better in the future, DTube is leading the way.
Note that the SEC is one of the few regulators in the western world to consider by default all crypto tokens as securities (unlike in the EU, switzerland, singapore, etc.)