The App Coins are a way of determining royalty payouts for now. The only way to earn them is by participating in building the product, and effectively joining the product's partnership. This would be similar to how a law firm partnership is structured and is why these are not securities.
Assembly App Coins can't be purchased by outside investors and Assembly App Coins can't be transferred to other individuals not in the "partnership".
I have no doubt it is possible to design a system that navigates the treacherous landscape of the securities laws, and perhaps you have done that. I just note that securities laws are one of the design constraints you'll need to account for. It sounds like you've made an effort to do that. I would certainly encourage you to get some expert help in this area when it’s the right time to make that investment.
Good luck!