Okay, but in fairness, I don't think Coinbase is disputing that,

a) "You can make a plausible legal argument for why Lend is a security."

Their frustration, rather, is that:

b) "The SEC is not doing the same thing for near-identical offerings like Gemini Earn." and

c) "The SEC won't actually tell us what basis they're appealing to or how this relevantly differs from the others."