NYXPrivate by Nature

Cost is not the constraint. Trading intensity is.

Unit economics and cost structure for a self-custody, multi-chain mobile wallet with an integrated trading terminal — benchmarked against Phantom, MetaMask, Trust Wallet, Fomo and Trojan. Cost figures are derived from the operating codebase; revenue figures from published comparables.

Prepared 9 August 2026 All figures in US dollars Trading fee 0.50% — verified in code Referral programme excluded
The complete picture

At one million monthly active users

Every dollar of cost and profit, per month. "Monthly active users" means people who open and use the app at least once in a given month. All figures are the base case, which assumes NYX earns the same revenue per user as Fomo does today — a directly comparable app charging the identical fee.

Revenue — 0.5% fee on trades$5,940,000
Costs of running the servicePer month
Blockchain data and node access$13,910
Computing, hosting and data storage$1,710
Security and independent app review$23,910
Legal and compliance$6,520
Operations, support tooling and monitoring$3,260
Artificial intelligence and market analysis$4,890
Total cost of running the service$54,200
…as a share of revenue0.9%
Gross profit
Revenue less cost of running the service$5,885,800  ·  99.1%
Discretionary investmentPer month
Marketing — funding 15% monthly user growth$1,027,000
Team — 6 people (from the founder alone at launch)$66,700
Operating profit$4,792,100
…as a share of revenue80.7%
Revenue, annualised
$71.3 M
Operating profit, annualised
$57.5 M
Where every $100 of revenue goes
At one million monthly active users, base case.
Of every $100 of revenue: $0.91 cost of running the service, $1.12 team, $17.29 marketing, $80.68 operating profit Cost of running the service — $0.91 of every $100 (0.91%) Team — $1.12 of every $100 (1.12%) Marketing — $17.29 of every $100 (17.29%) Operating profit — $80.68 of every $100 (80.68%) $80.68 profit $0 $50 $100 of revenue
Running the service $0.91 Team $1.12 Marketing $17.29 Operating profit $80.68
What this shows

Running the service costs less than one dollar out of every hundred earned. The two large outflows — marketing and team — are discretionary and can be reduced within a single quarter. The business therefore has no structural cost problem at scale; it has a growth-investment decision.

01

Summary at every size

The same picture at four sizes of business. Throughout this document, users means monthly active users — people who open and use the app at least once in a given month.

Per month, US dollars10,000 users50,000 users100,000 users1,000,000 users
Revenue59,400297,000594,0005,940,000
Cost of running the service4,8509,55016,72054,200
Gross profit54,550287,450577,2805,885,800
Gross profit margin91.8%96.8%97.2%99.1%
Marketing9,80048,90097,8001,027,000
Team founder only at 10,000 users20,83030,00039,20066,700
Operating profit23,920208,550440,2804,792,100
Operating profit margin40.3%70.2%74.1%80.7%
Cost of running the service, per user$0.485$0.191$0.167$0.054

One hundred times the users costs eleven times as much to serve. The cost of serving each individual user falls by a factor of nearly nine between ten thousand and one million users, because most of the cost base is fixed rather than growing with the user count.

The central risk

The principal risk is neither cost nor scale — it is how much users actually trade, which is cyclical and largely outside the company's control. Section 11 models the downside. NYX stays gross-profit positive at every size even if users trade as lightly as they do in an ordinary crypto wallet, because marketing and team — the only large discretionary items — can be reduced within a quarter.

02

How NYX earns money, and what it charges

The revenue mechanism. NYX takes a flat 0.5% fee on every completed trade. The fee is deducted from the trade itself and settled to the company treasury across three routes: a direct transfer for Solana trades, and a collect-then-convert route for trades on Ethereum-compatible chains, TON and SUI. This is verified in the codebase and has been proven working on-chain.

Why the cost base is unusually small. NYX is non-custodial and runs on the user's device. Each user's phone connects directly to public blockchain infrastructure, so the services that limit usage per internet address — blockchain node access, price feeds, market data, push notifications — cost nothing at all, at any number of users, because the load is spread across a million individual phones instead of concentrating on company servers. There is no central server that every user flows through. This is a property of the architecture, not an optimisation that can erode over time.

ProductCategoryFee per tradeNote
MetaMaskGeneral Ethereum wallet0.875%Also applies to bridging between chains
PhantomSolana-first wallet0.85%1.5% flat on fee-free mobile swaps
Trust WalletGeneral mobile wallet0%By choice; currently subsidising transaction fees
Trojan · GMGN · Photon · BullXTrading terminals1.00%Axiom discounts to 0.75% at its top tier
FomoMobile social trading app0.50%Plus a $0.95 minimum charge per trade
NYXMobile wallet with trading terminal0.50%No minimum — the cheapest in its category

Fomo's $0.95 minimum means a $50 trade costs a Fomo user 1.9%. The same trade on NYX costs 0.5%. This is a real advantage when acquiring smaller and first-time traders — and a deliberate revenue trade-off.

Pricing headroom

The entire cost of running the service at one million users — $54,200 per month — amounts to less than half of one basis point of trading volume: 0.46 of NYX's 50. Raising the fee to 0.75% would still undercut every competitor except Fomo and would roughly double gross profit. This headroom is not assumed anywhere in the model.

03

Benchmarking against comparable products

The central modelling question is how much revenue each user generates per month. Published data across five comparable products produces a wide band that separates cleanly into two product classes roughly forty times apart.

Revenue per user per month, by comparable product
Derived from published user counts and reported revenue. Trojan is excluded from the chart because it reports per active user, a different and much smaller denominator.
Revenue per user per month: Trust Wallet $0.00; MetaMask $0.12; Phantom $1.09; Fomo $5.30; NYX base case $5.94 $0 $1.50 $3.00 $4.50 $6.00 Trust Wallet — $0.00 per user per month; charges no platform fee on swaps Trust Wallet 0.00 MetaMask — $0.12 per user per month · 30 million users · 0.875% fee MetaMask 0.12 Phantom — $0.58 to $1.59 per user per month, midpoint $1.09 · 15 to 17 million users · 0.85% fee Phantom 1.09 Fomo — $4.40 to $6.20 per user per month, midpoint $5.30 · 500 to 625 thousand traders · 0.50% fee Fomo 5.30 NYX base case — $5.94 per user per month, anchored to Fomo steady-state at NYX's identical 0.50% fee NYX — base case 5.94
General wallet Trading app (Fomo) NYX modelled base case
Sources: DefiLlama (MetaMask, Fomo), Phantom company blog and third-party trackers, Trust Wallet 2025 year-end report. Phantom and Fomo shown at range midpoints; full ranges in the table below.
ProductUsersFeeReported revenueRevenue per user, per month
MetaMask30 million flat for three years0.875%$41.6M annualised DefiLlama$0.12
Phantom15–17 million0.85%$105M–326M in 2025 sources conflict$0.58–1.59
Trust Wallet15–60 million estimates conflict fourfold0%no swap-fee revenue~$0
Fomo500–625 thousand traders0.50%Q1-2026 $9.23M · Q2-2026 $7.24M$4.40–6.20
Trojan20k active / 145k registered1.00%$28M daily volume~$420 per active user

Why Fomo is the right comparison

NYX is a trading product in a wallet's clothing — a self-custody mobile wallet whose actual product surface (price charts, a trading cockpit, copy-trading, new-token analysis, multi-chain discovery) is a trading terminal. That is precisely Fomo's shape, and Fomo charges the identical fee.

DimensionFomoNYX
Who holds the keysThe userThe user
Form factorMobile-firstMobile-first
Fee0.50% plus $0.95 minimum0.50%, no minimum
Chains supportedSolana, Base, BNB, MonadSolana, Ethereum-compatible, TON, SUI, XRP
Social and copy-tradingCore featureBuilt
Sign-upNo seed phrase requiredNo seed phrase required
Proof the category works

Fomo: over $4 billion in cumulative trading volume in roughly twelve months · 625,000+ traders, growing by about 3,500 per day · revenue rising from $1.63M in the third quarter of 2025 to a single record week of $2.64M in August 2026 · trailing weekly revenue 86% above Phantom's · overtook Axiom as Solana's leading daily trading venue by volume · $75M Series B at a $550M valuation led by Index Ventures, with Union Square Ventures and Benchmark.

A mobile, self-custody trading app charging 0.5% can reach a $29M+ annualised revenue run rate on roughly 625,000 users. That is the category NYX competes in.

04

Revenue model

Three scenarios, each anchored to a named, published comparable rather than an internal assumption.

ScenarioWhat it assumesTrading volume per user, per monthRevenue per user, per month
DownsideUsers trade as lightly as they do in an ordinary Phantom-style wallet — most hold rather than trade~$130$0.65
BaseNYX reaches Fomo's ordinary, non-record monetisation (first- and second-quarter 2026 average)~$1,188$5.94
UpsideFomo's record weeks — full trading-terminal intensity~$3,600$18.00

The downside case applies Phantom's trading volume at NYX's lower fee — it assumes NYX both fails to attract more trading than a general-purpose wallet and charges 41% less than Phantom does for it. It is a genuinely pessimistic floor, not a mild haircut.

UsersDownside — $0.65Base — $5.94Upside — $18.00
10,0006,50059,400180,000
50,00032,500297,000900,000
100,00065,000594,0001,800,000
1,000,000650,0005,940,00018,000,000

At one million users the base case implies $71.3 million in annual revenue — against Fomo's $29 million annualised run rate on 625,000 users. The model assumes NYX reaches Fomo's per-user monetisation, not that it exceeds it.

Excluded — the referral programme

Excluded at management's instruction. NYX has a built and tested referral system that pays a share of the fee to whoever introduced the user. Users who arrived without a referrer still yield the full fee. At high referral take-up the company's share of gross fees would fall to roughly 71%. These revenue figures must not have referral revenue added on top without applying that reduction.

05

What a customer costs, and what a customer is worth

Cost to acquire a customer. Industry benchmarks for 2026: a crypto wallet user costs roughly $25 to acquire through general advertising; the best-performing campaigns reach $6–8, the worst $44. Targeting people who already hold crypto cuts this by 50–70%. Paying individual crypto influencers a flat fee has collapsed as a channel — Forbes documented a $30,000 payment that produced a single sign-up — with budgets moving to short-form video clipping at a fraction of the cost. Planning figure: $13 per user.

How long a user stays. Deliberately conservative at six months. Retention in this market is poor: the average holding period for a speculative token is around 100 seconds, and 96.6% of Solana wallet addresses that trade once disappear within a day. A twelve-month assumption would not be defensible.

DownsideBaseUpside
Revenue per user, per month$0.65$5.94$18.00
Total revenue per user over six months$3.90$35.64$108.00
Cost to acquire that user$13.00$13.00$13.00
Ratio of user value to acquisition cost0.30×2.74×8.31×
Time to earn back the acquisition costnever2.2 months0.7 months
Conventional healthy threshold3.0×3.0×3.0×

Reading this honestly. The base case sits just below the conventional 3.0× threshold when measured on an average user — but earns the acquisition cost back in 2.2 months, which is strong. Two factors materially improve on the average:

Valuation comparables — for context, not a valuation

CompanyValuationUsersPer userMultiple of revenue
Fomo$550M after its June 2026 round625,000 traders~$880~18.8×
Phantom~$3 billion15 million~$200—
Consensys / MetaMask$7–12 billion reported listing range30 million~$233–400—
06

Cost structure

Costs are derived from the operating codebase, not from vendor price lists.

A · Blockchain data and node access

This is the market-data layer: live prices, price charts and token information. The server caches results so that many users viewing the same token produce a single request to the data provider rather than one per user. Cost therefore grows with the number of distinct tokens being viewed, not with the number of users — which is why it grows only elevenfold as users grow a hundredfold.

UsersPeak simultaneousDistinct tokens viewedPeak requests per second
10,000175~61112
50,000875~302553
100,0001,750~5981,094
1,000,00017,500~4,8008,779

$0 at every size — spread across user devices: Ethereum-compatible node access · Jupiter · DexScreener · GeckoTerminal · SUI · push notifications · self-hosted analytics.

B · Computing, hosting and storage

One server at ten thousand users, rising to six to ten servers across two data centres at one million. The same capacity rented from Amazon or Google would cost $16,000–43,000 per month; dedicated hardware is a ten- to twenty-fold saving.

Data storage grows from about 70 gigabytes at ten thousand users to 5–10 terabytes at one million, and costs 0.1–0.4% of the total at every size — it sits on disks already paid for in the server fleet.

The figure that actually matters is data transfer, not storage

At one million users, roughly 2 gigabytes per user per month means about 2 petabytes of data leaving the servers every month. Delivered from Amazon or Google at $0.05–0.09 per gigabyte, that alone would cost $100,000–180,000 per month. Delivered from Cloudflare, which charges nothing for outbound data, plus unmetered dedicated servers, it costs nothing. This single architectural decision is worth more than every other line in this document combined, and it is already in place.

C · Security and independent app review

Independent security review is treated as a fixed, non-negotiable cost from about ten thousand users onward. This is deliberate and material: because NYX never holds customer funds, it carries no custody risk — but a compromised app release or a poisoned software dependency would affect every user at once. The potential damage is wide even though the company holds nothing.

ComponentWhat it isCostPer month
Pre-launch security auditIndependent firm reviews the wallet, key handling and cryptography line by line. Firms of the class of Hacken, BlockApex, Trail of Bits, Cure53.$16–54k once—
Annual re-auditRepeat review as the code changes$43–76k / year3,600–6,300
Mobile penetration testing, twice a yearSpecialists actively attempt to break the iPhone app, Android app and the interfaces behind them$27–43k / year2,300–3,600
App hardeningAnti-tampering, detection of modified phones, code obfuscation, screenshot blocking$12–41k / year980–3,700
Bug bounty reservePaying independent researchers who report vulnerabilities, via Immunefireserve3,300–8,700
Attack filtering and monitoringWeb firewall, denial-of-service protection, intrusion monitoring, scanning of third-party software dependencies—470–6,400
Breach-response retainer and cyber insuranceSpecialists on standby, plus cover—1,500–5,200

D · Legal and compliance

The scoping question is the single largest legal variable, and it is unresolved until counsel opines. It is addressed in full in Section 8.

ScenarioBasisYear-one cashOngoing / month
Base — no licence requiredPure non-custodial software: no custody, no order matching, no handling of customer money. Cost = scope opinion, company formation, terms of service and privacy documentation, trademarks, ongoing counsel.$30–79k$870–6,520
Contingency — licence requiredOnly if the copy-trading service is left holding customer keys. Legal file $43–217k · application fees $5.4–27k · regulatory capital $54–163k · local director ~$37k/year · compliance officer and local hires $109–272k · 9–15 month timeline.$272–652k$11–27k

E · Marketing

Shown as growth investment rather than as a cost of running the service, so that gross profit is not obscured by discretionary spending.

UsersLean — organic and referral-ledGrowth — 15% more users each monthAggressive — 30% more each month
10,0002,2009,80027,200
50,0006,50048,900137,000
100,00013,00097,800274,000
1,000,00065,2001,027,0003,196,000

Total cost of running the service

Block10,00050,000100,0001,000,000
A · Blockchain data and node access1,3602,6204,66013,910
B · Computing, hosting and storage1803006401,710
C · Security and independent app review1,6303,8006,52023,910
D · Legal and compliance8701,6302,7206,520
E · Operations, support tooling and monitoring1604409803,260
F · Artificial intelligence and market analysis6507601,2004,890
Total per month4,8509,55016,72054,200
Per user, per month$0.485$0.191$0.167$0.054
Cost of running the service, as a share of revenue
Base case revenue. The cost base becomes immaterial as the user base grows.
Cost as share of revenue: 10 thousand users 8.2%; 50 thousand 3.2%; 100 thousand 2.8%; 1 million 0.9% 0%3% 6%9% 10,000 users — $4,850 cost is 8.2% of $59,400 revenue 8.2% 10,000 50,000 users — $9,550 cost is 3.2% of $297,000 revenue 3.2% 50,000 100,000 users — $16,720 cost is 2.8% of $594,000 revenue 2.8% 100,000 1,000,000 users — $54,200 cost is 0.9% of $5,940,000 revenue 0.9% 1,000,000 Monthly active users
Excludes marketing and team, which are discretionary and shown separately in Section 10.
What the cost is actually spent on
Share of the total cost of running the service. Security and legal dominate at every size; infrastructure never does.
Cost composition: security and app review is the largest block at every size, rising from 33.6% at ten thousand users to 44.1% at one million 10,000 Blockchain data and node access — $1,360, 28.0% Computing, hosting and storage — $180, 3.7% Security and independent app review — $1,630, 33.6% Legal and compliance — $870, 17.9% Operations and artificial intelligence — $810, 16.8% $4,850 50,000 Blockchain data and node access — $2,620, 27.4% Computing, hosting and storage — $300, 3.1% Security and independent app review — $3,800, 39.8% Legal and compliance — $1,630, 17.1% Operations and artificial intelligence — $1,200, 12.5% $9,550 100,000 Blockchain data and node access — $4,660, 27.9% Computing, hosting and storage — $640, 3.8% Security and independent app review — $6,520, 39.0% Legal and compliance — $2,720, 16.3% Operations and artificial intelligence — $2,180, 13.0% $16,720 1,000,000 Blockchain data and node access — $13,910, 25.7% Computing, hosting and storage — $1,710, 3.1% Security and independent app review — $23,910, 44.1% Legal and compliance — $6,520, 12.0% Operations and artificial intelligence — $8,150, 15.0% $54,200 0% 50% 100% of the cost
Blockchain data and node access Computing, hosting and storage Security and independent app review Legal and compliance Operations and artificial intelligence
Totals shown at right. Security and independent app review is the largest single block at every size — 33.6% at ten thousand users, rising to 44.1% at one million.
07

How the system is put together

Four layers, drawn from the source tree rather than from marketing material. The arrangement below is what keeps the company outside the scope of a financial licence — the argument set out in Section 8.

NYX system architecture in four layers The user's device holds the keys, builds and signs every transaction, and sends it directly to the blockchain, bypassing NYX servers entirely. NYX servers carry only cached market data flowing one way toward the device. Third-party services provide market data, non-custodial routing and fiat on-ramps. The one exception is the copy-trading service, which currently holds user keys on the server. 01 · The user's device Self-custody boundary Private keys Created and stored here. Never transmitted. Transaction assembled Built on the phone from a public route Signed and broadcast By the user's own key, from the phone 02 · NYX servers No order path Market-data relay Cached prices, charts and token information Fee sweeper Moves the company's own revenue only Wallet-alert service Notifications only. Holds no key, places no order. 03 · Third-party services Non-custodial, except the stop-loss vault (see note) Market data Birdeye · DexScreener GeckoTerminal · CoinGecko RugCheck · Blockscout Read-only. Reaches the device through the cached relay. Routing & liquidity — non-custodial Jupiter · KyberSwap · pump.fun NOXA-DEX (Robinhood) · STON.fi DeDust · Aftermath · XRPL DEX Relay · ChangeNOW · Jupiter Trigger The pool is the counterparty, not NYX. Fiat on-ramps MoonPay · Transak Coinbase Pay · Ramp Onramper Licensed providers run the identity checks, not NYX. 04 · Public blockchains Solana · Ethereum · Base · BNB Chain · Robinhood Chain · TON · SUI · XRP Ledger · Bitcoin Signed transaction Device → blockchain, direct Market data only One way, read-only, cached Buying with cash Lands straight in the user's wallet The green path runs outside the NYX box. That gap is the whole legal argument.
Signed transaction — device straight to the blockchain Market data and wallet alerts — one way, toward the device Buying crypto with cash — provider to user's wallet
Every element verified against the operating source tree on 9 August 2026.
What layer 1 proves

The company cannot touch customer funds

Keys are generated and stored on the user's phone and are never transmitted. There is no mechanism — technical or administrative — by which NYX could move a user's assets.

What layer 2 proves

Our servers carry data, not orders

The only server in the trading path caches prices and charts. It contains no order-handling code at all, so there is no order for NYX to receive, hold, route or forward.

What layer 2 also proves

Copy-trading is alerts, not execution

Wallet tracking now notifies rather than trades: a blockchain webhook arrives, the server forwards a push notification, and the user decides. No key reaches the server and no order is placed for anyone.

Which third parties are actually integrated

Verified by reference count in the source tree, so this reflects what is built rather than what is planned.

CategoryProvidersWhy it matters legally
Trade routing and liquidityJupiter (Solana) · KyberSwap (Ethereum-compatible chains) · pump.fun · NOXA-DEX (Robinhood Chain) · STON.fi and DeDust (TON) · Aftermath (SUI) · the XRP Ledger's own order books and market maker · Relay and ChangeNOW (cross-chain)All non-custodial. The liquidity pool is the counterparty to each trade — never NYX.
Robinhood ChainTokens launched through the NOXA launchpad trade in pools that no external aggregator indexes, so NYX calls those pool contracts directly — quoting, buying and selling on-chain.Direct contract calls from the device. No intermediary holds anything.
XRP LedgerThe ledger performs its own routing, so no aggregator exists. NYX builds a payment routed through the ledger's order books and automated market maker, plus the trust line a first purchase requires.Signed locally with the user's own key. NYX never holds the key or the asset.
Sell strategy — take-profitJupiter Trigger V1. Each tier becomes an on-chain limit order: "sell N tokens for at least M". The user signs once on the device; Jupiter's permissionless keeper network fills it even with the app closed. The app calls Jupiter directly, not through any NYX server.Non-custodial. Coins stay in the user's wallet. No key on any server.
Sell strategy — stop-lossJupiter Trigger V2. A stop-loss cannot sit on-chain unattended, so it needs a watcher. Jupiter's V2 deposits the tokens into a Jupiter-managed vault and its keeper signs the fill.Custodial — by Jupiter, not NYX. Disclosed in-app before the feature can be enabled.
Market dataBirdeye · DexScreener · GeckoTerminal · CoinGecko · RugCheck · BlockscoutRead-only information. No customer funds or orders involved.
Buying crypto with cashMoonPay · Transak · Coinbase Pay · Ramp · OnramperEach is a licensed payment provider running its own identity checks, delivering funds straight to the user's own wallet address. NYX never handles the money.
Blockchain accessHelius and public community nodesStandard infrastructure, treated as a shared public resource rather than an outsourcing relationship.
08

Does NYX need a European financial licence?

Assessment: most likely no. The one exception has been designed out and ships in build 204.

Europe's crypto regulation, known as MiCA, requires a licence — a "crypto-asset service provider" authorisation — from firms that provide certain defined services. The transitional period for existing firms ended on 1 July 2026, so this question is live rather than hypothetical.

The decisive principle is that MiCA regulates services, not software. The licence is triggered by holding customers' assets, running a trading venue, acting as the counterparty to a trade, or handling customers' orders on their behalf. Taking each in turn:

Regulated serviceDoes NYX do this?Assessment
Holding customer assetsNo. Keys are created and stored on the user's own phone. NYX has no access to them and cannot move a user's funds under any circumstances.Outside scope
Running a trading venueNo. NYX matches no orders and operates no marketplace.Outside scope
Acting as counterparty to tradesNo. The other side of every trade is a public liquidity pool, never NYX.Outside scope
Executing orders for customersNo. The user's own device signs and submits every transaction.Outside scope
Receiving and passing on customer ordersThe one genuinely arguable category — examined below.The live question

The one arguable category — and why NYX answers it well

Under guidance from the European securities regulator (ESMA, question-and-answer 2653), this category is triggered where a firm forwards a customer's order to a third party which then completes the trade. Importantly, that guidance states the assessment must follow the operational reality of what the firm does, not how the firm describes itself.

NYX's operational reality, verified in the codebase:

This is a materially stronger position than a typical decentralised-exchange website, which normally routes orders through its own backend infrastructure. NYX does not have an order path to regulate.

Technical exhibit

Section 7 shows this visually: the green path — the signed transaction — runs outside the NYX server box entirely. That diagram is drawn from the source tree rather than from marketing material, and is intended as the technical exhibit accompanying a legal scope opinion.

The one former exception — now closed by design

Copy-trading previously stored users' signing keys on the NYX server and placed buy and sell orders on their behalf. That was the one component capable of pulling the company into licensing scope, and it has been redesigned to alerts only: a blockchain webhook reaches the server, the server forwards a push notification, and the user decides and signs on their own device. The server holds no key and places no order.

The decision layer is built and tested — suppressing dust, collapsing repeat buys, capping any one wallet's share of the feed, and marking stale trades rather than hiding them. Alert wording is constrained by test to report what happened and never to instruct, because instruction is advice and advice is regulated.

Status: the decision layer and its tests are complete; the final removal of the key-passing line from the client, and the webhook-to-push server piece, land in build 204. Until that build ships, the legacy path remains present in the codebase.

What remains genuinely uncertain

Conclusion for budgeting

The base case — no licence required, $870 to $6,520 per month in ordinary legal costs — is the reasonable planning assumption for the core wallet. Policymakers have signalled that self-custody stays outside the regulatory perimeter, and major self-custody wallets are not licensed as service providers.

With copy-trading redesigned to alerts, none of the six triggers is met and the $272,000–652,000 authorisation figure in Section 9 is a remote contingency rather than a live exposure. A written legal opinion costing $16,000–43,000 converts this from an open question into a documented position — and is worth commissioning before fundraising, since it removes a several-hundred-thousand-dollar uncertainty from the diligence conversation.

This section is a commercial assessment of publicly available regulatory guidance. It is not legal advice and does not substitute for a formal opinion from qualified counsel. European legal and regulatory costs are incurred in euro and converted here at the rate stated in the assumptions.

09

Year-one one-time costs

Outside the monthly running costs.

ItemWhat it coversUS dollars
Pre-launch security auditIndependent review of the wallet, key handling and cryptography16,000–54,000
Legal opinion on licensing scopeFormally documents the position set out in Section 816,000–43,000
Company formation and corporate workIncorporation, share structure, contracts5,400–16,000
Terms of service, privacy policy, app-store documentationAcross the jurisdictions where the app is distributed5,400–10,900
Trademark registrationNYX name and logo, EU trademark office plus key markets3,300–8,700
Settlement contract deploymentOne-off on-chain deployment cost~650
Apple and Google developer accounts$99 per year plus $25 once~135
Total year-one one-time cost47,500–134,500
Contingency — licence applicationOnly if copy-trading is left custodial and the legal opinion places NYX in scope (Section 8). Excludes $54,000–163,000 of regulatory capital, which is held on the balance sheet rather than spent.272,000–652,000
10

Profit and loss — base case

Per month, US dollars10,000 users50,000100,0001,000,000
Revenue — 0.5% fee on trades59,400297,000594,0005,940,000
− Blockchain data and node access−1,360−2,620−4,660−13,910
− Computing, hosting and storage−180−300−640−1,710
− Security and independent app review−1,630−3,800−6,520−23,910
− Legal and compliance−870−1,630−2,720−6,520
− Operations and support tooling−160−440−980−3,260
− Artificial intelligence and market analysis−650−760−1,200−4,890
= Gross profit54,550287,450577,2805,885,800
Gross profit margin91.8%96.8%97.2%99.1%
− Marketing, funding 15% monthly growth−9,800−48,900−97,800−1,027,000
= Profit after marketing44,750238,550479,4804,858,800
− Team 1 person → 6−20,830−30,000−39,200−66,700
= Operating profit23,920208,550440,2804,792,100
Operating profit margin40.3%70.2%74.1%80.7%
Team line — indicative, to be refined

The team line begins with the founder alone, at $250,000 per year fully loaded (salary, employer contributions, equipment and workspace) — roughly $20,830 per month — and grows from there: about two people at fifty thousand users, three at one hundred thousand, and six at one million, with later hires costed at a lower average than the founder. The count is deliberately lean because the non-custodial architecture removes the heaviest support burdens — there are no account recoveries, frozen balances or withdrawal tickets, because the company never holds customer funds.

This is a placeholder for planning, not a hiring plan. Hiring pace, seniority mix, location and the split between employees and contractors would each move it materially. It is the least developed line in this model and should be rebuilt against an actual org plan before it is relied upon.

11

Sensitivity — what if users trade far less?

Revenue per user versus cost per user, at one million users
Per month, US dollars. The cost of serving a user is immaterial against revenue in every scenario, including the pessimistic floor.
At one million users, serving a user costs $0.054 per month against revenue of $0.65 downside, $5.94 base, $18.00 upside $0$5 $10$15 $20 Cost of serving one user — $0.054 per month at one million users Cost to serve a user $0.05 Downside — users trade like ordinary wallet holders; $0.65 per user per month, still twelve times the cost to serve them Downside — wallet-like trading $0.65 Base case — Fomo's ordinary monetisation; $5.94 per user per month, 110 times the cost to serve them Base — Fomo-like trading $5.94 Upside — full trading-terminal intensity; $18.00 per user per month, 333 times the cost to serve them Upside — heavy trading $18.00
Cost to serve a user Downside revenue Base revenue Upside revenue
Even the pessimistic floor produces twelve times the cost of serving the user. The base case produces 110 times.

Operating profit in each scenario

After the cost of running the service, marketing and team:

UsersDownsideBaseUpside
10,000−28,980+23,920+144,520
50,000−55,950+208,550+811,550
100,000−88,720+440,280+1,646,280
1,000,000−497,900+4,792,100+16,852,100
The key resilience property

The downside case loses money only because it is modelled with full marketing spend and a full team. Removing the discretionary marketing budget returns it to profit at every size:

UsersDownside revenue− cost of running the serviceGross profitMargin
10,0006,500−4,850+1,65025.4%
50,00032,500−9,550+22,95070.6%
100,00065,000−16,720+48,28074.3%
1,000,000650,000−54,200+595,80091.7%

The cost base is small enough that even wallet-like trading levels cover it at a 25–92% gross margin. Marketing and team are discretionary and can be reduced inside one quarter. The company does not have a structural cost problem in any scenario — it has a growth-investment decision.

12

Risks

RiskAssessmentMitigation
How much users trade is cyclicalThe primary risk. Revenue varies twenty-eightfold between the downside and upside scenarios while cost barely moves. Speculative-token trading recently fell below 5% of Solana's total trading volume, the lowest share since 2023.The cost base is small and largely fixed; marketing can be reduced within a quarter. Supporting several blockchains reduces dependence on any single ecosystem.
Copy-trading designFormerly the one feature that could require a European licence. Redesigned to alerts only — the server holds no key and places no order. The final client change ships in build 204.Once shipped, none of the six licensing triggers is met, and the $272,000–652,000 contingency becomes remote rather than live.
Wide security exposureHolding no customer funds removes custody risk, but a compromised app release or poisoned software dependency would affect every user at once.The largest cost block at every size — independent audit, twice-yearly penetration testing, app hardening, bug bounty, dependency scanning. Budgeted from ten thousand users.
Three known engineering ceilingsCopy-trade tracking saturates at around sixty tracked wallets; the market-data cache runs on a single server; there is no database yet. All are well below one million users; two are immediate.Two fixes are a few hours of work. The remainder is a single six- to ten-week engineering project, to begin before fifty thousand users.
Users do not staySpeculative-token traders churn quickly — around a 100-second average holding period. Even the six-month assumption may be generous.Modelled conservatively. Wallet features — multi-chain custody, offline payments — give reasons to stay that pure trading terminals lack.
CompetitionFomo, Axiom, Trojan, Photon and GMGN, plus Phantom moving into trading.Cheapest fee in the category; differentiated on self-custody, chain coverage and offline capability.
Revenue concentrationA small group of heavy traders generates most of the revenue.Known and modelled; drives the segment-based acquisition strategy in Section 5.
13

Assumptions, sources and data quality

Model assumptions
AssumptionValueBasis
Share of monthly users active on a given day25%Trading-app engagement norm
Share of daily users online simultaneously at peak7%Standard mobile usage curve
Share of simultaneous users viewing a price chart35%Product judgement
Number of distinct tokens actively traded12,000Estimate — measurable from the company's own systems
Trading fee0.5% flatVerified in the codebase
How long a user stays6 monthsConservative against observed market retention
Cost to acquire a user$132026 benchmark for crypto-native targeting, mid-range
Growth rate in the marketing case15% per monthManagement scenario, half of it paid
Team size and cost1 → 6 peopleFounder only at launch, $250,000/year fully loaded, growing from there. Indicative — the least developed line in this model.
Exchange rate for euro-denominated costs1 EUR = 1.087 USDEuropean legal, hosting and some security costs are incurred in euro

Excluded from the model: referral payouts (Section 4), token or points programmes, revenue share from buying crypto with a card, derivatives revenue, and paid subscription tiers. Several represent upside not reflected here — Fomo, for example, earns additional revenue from derivatives routing.

Glossary
Monthly active users
People who open and use the app at least once in a given month.
Non-custodial / self-custody
The user's keys stay on their own device. The company cannot access or move customer funds.
Gross profit margin
Revenue less the cost of running the service, before marketing and team.
Operating profit
What remains after all costs including marketing and team.
Blockchain node access
Paid connections to blockchain networks, needed to read balances and submit transactions.
Liquidity pool
The pooled funds on a decentralised exchange that sit on the other side of each trade.
Penetration testing
Security specialists actively attempting to break into the app, under contract.
Bug bounty
Paying independent researchers who responsibly report security flaws.
MiCA
Markets in Crypto-Assets — the European Union's crypto regulation, fully in force since 1 July 2026.
Basis point
One hundredth of a percent. NYX's 0.5% fee is 50 basis points.
Sources

Comparable companies

Costs and regulation

Data quality — stated explicitly
  • Comparable revenue figures conflict materially between sources. Phantom's 2025 revenue is reported anywhere between $79 million and $326 million depending on method. Trojan's lifetime volume is reported as both $2.2 billion and $24.2 billion. Trust Wallet user estimates range from 15 to 60 million. Ranges are used throughout rather than single figures.
  • Much comparable data is published by vendors or affiliates, not audited. On-chain fee data from DefiLlama is the most reliable class of source used here and is preferred wherever available.
  • Solana trading volumes are contaminated by artificial trading. Bitquery documented one token where 233 wallets executed 40,523 trades at a $13 average, with 96% of those wallets both buying and selling. The upside scenario should be read as a market-peak artefact, not a plan.
  • The single largest input — how much each user trades — is the one figure still estimated rather than measured. It is directly measurable from NYX's own systems, and doing so would remove most of the remaining uncertainty in this document.