CFDA Team – Transparency on Allocator Applications, Organizational Connections, and Enterprise Deal Operations

[beatyman]

CFDA Team – Transparency on Allocator Applications, Organizational Connections, and Enterprise Deal Operations

Purpose

This discussion provides transparency on the Filecoin Plus (Fil+) Datacap Allocator applications submitted under issue numbers #914, #943, #972, #973, #1011, #1012, #1058, and #1061, listing the disclosed points of contact (humans) between organizations.

Allocator Application Clarification

Multiple Application Issue

Our organization inadvertently submitted multiple Allocator applications under a single GitHub account due to a misunderstanding of the application guidelines and inadequate internal coordination. This was an error in process, not a malicious act.

Corrective Actions

To address the issue and ensure compliance, we have implemented the following measures:

• Withdrawn Redundant Applications: All duplicate applications have been retracted to comply with governance rules.
• Full Disclosure: All related applications have been fully disclosed to maintain transparency.
• Corporate Email Transition: Transitioned to a verified corporate email address for all submissions.
• Separated KYC Identities: Assigned unique KYC identities to each applicant entity to eliminate potential conflicts of interest.
• Revised KPIs: Adjusted unrealistic KPI targets to reflect operational capacity, with updated projections to be submitted promptly.
• Governance Commitment: Committed to actively participating in bi-monthly governance calls to align with protocol expectations.

Commitment to Compliance

We are dedicated to building a strong reputation within the ecosystem by ensuring full compliance with governance requirements, enhancing internal processes, and engaging actively in community governance.

Submitted Allocator Applications

1. Chimsen Fil+ Datacap Allocator (CFDA) #914
   • Organization: Tech Chimsen
   • Address: f2f3skvqnphoapuvkbd7kolezyx5sksjod34gipgi
   • Audit Type: Public Open
   • GitHub Username: beatyman
   • GitHub Repo: ChimsenCorp/Open-Data-Bookkeeping
   • Allocator PR Link: #914
   • KYC User: Yin Feng
   • KYC Email: [email protected]
   • status: closed
2. FiL-Sinde #943
   • Organization: FiL-Sinde
   • Address: f23dvj3jsuuqwirviqm4xn3ast5tnlbukv6ab7lwq
   • Audit Type: Public Open
   • GitHub Username: sofregaz
   • GitHub Repo: sofregaz/FiL-Sinde-bookingkeeping
   • Allocator PR Link: #943
   • KYC User: Zhang YouShu
   • KYC Email: [email protected]
   • status: closed
3. onestech #972
   • Organization: onestech
   • Address: f2zpx2anrfrqhednvzghrwxv6y4wleuik6ptnvlai
   • Audit Type: Public Open
   • GitHub Username: onestech-cn
   • GitHub Repo: onestech-cn/filplus-onestech
   • Allocator PR Link: #972
   • KYC User: Zhang YouShu
   • KYC Email: [email protected]
   • status: closed
4. chimsen #973
   • Organization: chimsen
   • Address: f2g6nfx52jb2o743mikkrtkboio5t4h5qxah6glca
   • Audit Type: Enterprise Data
   • GitHub Username: LM-1207
   • GitHub Repo: LM-1207/filplus-chimsen
   • Allocator PR Link: #973
   • KYC User: Liu Ming
   • KYC Email: [email protected]
   • status: closed
5. OpenLedger Open Data PathWay #1011
   • Organization: OpenLedger
   • Address: f2abticfsmadgxh567htprvlmo4tgsi6ggxq2s7si
   • Audit Type: Public Open
   • GitHub Username: beatyman
   • GitHub Repo: jupiter-dao/Open-Data-Bookkeeping
   • Allocator PR Link: #1011
   • KYC User: Zhang Xin
   • KYC Email: [email protected]
   • status: closed
6. OpenLedger Enterprise Data PathWay #1012
   • Organization: OpenLedger
   • Address: f23dvj3jsuuqwirviqm4xn3ast5tnlbukv6ab7lwq
   • Audit Type: Enterprise Data
   • GitHub Username: beatyman
   • GitHub Repo: jupiter-dao/Enterprise-Data-Bookkeeping
   • Allocator PR Link: #1012
   • KYC User: Zhang Xin
   • KYC Email: [email protected]
   • status: closed
7. CFDA #1058
   • Organization: Chengxin Technology Co., Ltd.
   • Address: f25lhveiq4tnpnafhzw5wz3kbe7lzskqdeqwtmsoy
   • Audit Type: Enterprise Data
   • GitHub Username: LM-1207
   • GitHub Repo: LM-1207/CFDA-bookkeeping
   • Allocator PR Link: #1058
   • KYC User: Liu Ming
   • KYC Email: [email protected]
   • status: open , not kyc
8. SWST FIL+ #1061
   • Organization: Shenzhen Wanxin Science and Technology Co., Ltd.
   • Address: f2y7lcn4xcjrr3evfaw3zcckevxq5qllpkctqgfma
   • Audit Type: Enterprise Data
   • GitHub Username: onestech-cn
   • GitHub Repo: onestech-cn/SWST-Bookkeeping
   • Allocator PR Link: #1061
   • KYC User: Zhang Xin
   • KYC Email: [email protected]
   • status: open

Points of Contact Between Organizations (Humans)

The following individuals are listed as KYC users or personnel across the organizations, indicating explicit points of contact:

• Yin Feng

  • Applications:
    • CFDA #914 (KYC User, [email protected])
  • Organizations: Tech Chimsen (Chengxin Technology Co., Ltd.)
  • Role: CEO and Legal Representative of Chimsen

• Zhang YouShu

  • Applications:
    • FiL-Sinde #943 (KYC User, [email protected])
    • onestech #972 (KYC User, [email protected])
  • Organizations: FiL-Sinde, onestech (Shenzhen Wanxin Science and Technology Co., Ltd.), Chimsen (technical staff)
  • Role: Technical staff at Chimsen and onestech

• Zhang Xin

  • Applications:
    • OpenLedger Open Data PathWay #1011 (KYC User, [email protected])
    • OpenLedger Enterprise Data PathWay #1012 (KYC User, [email protected])
    • SWST FIL+ #1061 (KYC User, [email protected])
  • Organizations: OpenLedger, Shenzhen Wanxin Science and Technology Co., Ltd. (onestech), Ruilanit (Wuhan Ruilan Maotong Shangmao Co., Ltd.), Chimsen (technical staff)
  • Role: Legal Representative of Ruilanit, technical staff at Chimsen

• Liu Ming

  • Applications:
    • chimsen #973 (KYC User, [email protected])
    • CFDA #1058 (KYC User, [email protected])
  • Organizations: chimsen (Chengxin Technology Co., Ltd.)
  • Role: Technical staff at Chimsen

Disclosed Connections

The following connections are explicitly noted in the provided data:

1. Chimsen (Chengxin Technology Co., Ltd.):

   • Associated with applications #914, #973, and #1058.
   • Personnel: Yin Feng (CEO), Zhang YouShu (technical staff), Liu Ming (technical staff), Zhang Xin (technical staff).

2. onestech (Shenzhen Wanxin Science and Technology Co., Ltd.):

   • Associated with applications #972 and #1061.
   • Personnel: Zhang YouShu (technical staff), Zhang Xin (KYC user for #1061).

3. Ruilanit (Wuhan Ruilan Maotong Shangmao Co., Ltd.):

   • Associated with applications #1011 and #1012 (via Zhang Xin’s KYC).
   • Personnel: Zhang Xin (Legal Representative).
   • Explicit Note: No corporate linkages with Chimsen or onestech.

4. OpenLedger and FiL-Sinde:

   • Shared address: f23dvj3jsuuqwirviqm4xn3ast5tnlbukv6ab7lwq (#943, #1012).

Operation of Enterprise Deals in Filecoin Plus

Enterprise deals in the Filecoin Plus (Fil+) program facilitate the secure storage of private, sensitive, or proprietary datasets, such as business-critical or enterprise data, with stringent verification and compliance requirements. Below is a detailed explanation of how Enterprise deals operate, including a case study for Haplox, a client requesting 5 PiB of genomic sequencing data storage.

General Enterprise Deal Process

1. Purpose and Pathway:

   • Enterprise deals operate under the Enterprise and Encrypted Data Pathway, designed for private datasets requiring high security and compliance, unlike public open datasets.
   • Clients undergo rigorous Know Your Customer (KYC) and Know Your Business (KYB) verification to ensure legitimacy, data ownership, and compliance with legal standards.

2. Application and Verification:

   • Allocators apply via the Filecoin Governance Repository, specifying the Enterprise Data pathway, diligence processes, and expected DataCap needs.
   • Clients submit:
     • Business registration documents, business name, incorporation details, and executive team information.
     • A signed authorization letter from the CEO/directors with a company stamp.
     • A project overview (e.g., website, white paper, GitHub repo).
     • A 20% dataset sample (via CIDs or links) to verify content and ownership.
     • Proof of Filecoin ecosystem presence (e.g., prior deals, website).
   • Verification tools (e.g., Toggle) are used for KYC/KYB, ensuring 90% of clients pass, with 80% passing on first submission.

3. DataCap Allocation:

   • Root Key Holders (RKHs) grant DataCap to approved allocators via multisig wallets in tranches (e.g., 100 TiB to 5 PiB).
   • Allocators distribute DataCap to clients’ on-chain wallets, adhering to limits (50 TiB min, 500 TiB max per client).
   • Smart contracts enable withdrawal of unused or misused DataCap, ensuring compliance.

4. Storage Deal Execution:

   • Clients use DataCap to make deals with at least five Storage Providers (SPs), each handling ≤0.5 PiB, across ≥3 countries, ensuring 90% of deals span multiple regions.
   • SPs receive a 10x quality-adjusted power boost, incentivizing deal acceptance.
   • Deals require ≥5 verified replicas, with 75% retrievability and no data loss, monitored via tools like CID Check Bot and SPARK.

5. Compliance and Monitoring:

   • Weekly audits track SP distribution, retrievability (RSR >75%, no SP <50% for two weeks), and replica health using datacapstats.io, CID Check Bot, and AC Bot.
   • Reports are submitted to repositories like CFDA-bookkeeping.
   • Sybil attack mitigation includes one allocation per legal entity, rate limits (one application per 30 days), and IP/submission metadata monitoring.

6. Governance and Audit:

   • All diligence records (KYC/KYB, data samples, deal logs) are stored securely and available for community audit.
   • Large dataset applications (>100 TiB) undergo community review during governance calls, ensuring alignment with Fil+ goals.

Case Study: Haplox (5 PiB Genomic Sequencing Data)

Client Overview:

• Company: Shenzhen Haplox Biotechnology Co., Ltd. (haplox.cn)
• Profile: A national high-tech enterprise specializing in tumor liquid biopsy, genomic big data, and life sciences, recognized as a “Little Giant” for innovation. Haplox operates a leading genomic sequencing platform, certified by CAP, CLIA, EMQN, NCCL, and PQCC, serving hundreds of top-tier hospitals, research institutes, and government entities in China.
• Data: 5 PiB of genomic sequencing data, critical for tumor management, genetic disease screening, and infectious disease testing, requiring high reliability and availability.

Enterprise Deal Process for Haplox:

1. Client Verification and Initial Trust Establishment:

   • KYC/KYB: Haplox submits:
     • Business registration certificate and incorporation details (established in Shenzhen).
     • Signed authorization letter from the CEO with company stamp.
     • Executive team details and contact information.
     • Public website (haplox.cn) and proof of ecosystem presence (e.g., prior Filecoin deals or partnerships).
     • Verification of ≥20% equity holders (Ultimate Beneficial Owners) via Toggle or similar tools.
   • Outcome: Haplox’s CAP/CLIA certifications and business reputation ensure 90% likelihood of passing KYB on first submission.

2. Project Scope Validation:

   • Haplox provides:
     • Dataset description: 5 PiB of genomic sequencing data (FASTQ, BAM files) for medical research and diagnostics.
     • Project overview: Use case for tumor management and genetic screening, aligned with Fil+ goals of storing valuable scientific data.
     • 20% data sample (1 PiB) via CIDs or secure download links, verified for format and content consistency.
   • Verification: Data sample checked using Lassie/Boost for content matching (no filler or duplicates).

3. Data Ownership Verification:

   • Haplox submits:
     • Signed letter confirming ownership of genomic data, sourced from their certified laboratories.
     • Documentation of data generation processes (e.g., sequencing platform outputs).
   • Cross-Check: Public certifications (CAP, CLIA) and client contracts with hospitals validate data legitimacy.

4. Legal and Regional Compliance:

   • Compliance: Haplox adheres to China’s Personal Information Protection Law (PIPL) and Data Security Law, submitting a self-assessment and exemption certificates for medical data.
   • Verification: Legal documents reviewed to ensure compliance with regional regulations.

5. SP Distribution and Data Retrievability:

   • Allocation: 5 PiB distributed across ≥5 SPs, each handling ≤0.5 PiB, in ≥3 countries
   • Goals:
     • 90% of deals span ≥3 countries.
     • Average RSR >75%, no SP <50% for two consecutive weeks.
     • ≥5 verified replicas per pieceCID, 95% retrievable.
   • Monitoring:
     • Weekly audits via CID Check Bot, SPARK, and datacapstats.io.
     • Bi-monthly RSR reports submitted to CFDA-bookkeeping.
     • SPs flagged for low RSR are reviewed, with potential DataCap reallocation.

6. Auditable Proof:

   • Records include:
     • KYB documents, authorization letter, and data sample CIDs.
     • On-chain proof: pieceCIDs, dealIDs, SP IDs, file sizes.
     • Lotus logs and file hashes for content verification.
     • Compliance reports tracking Haplox’s allocation (within 50–500 TiB per tranche).

Proving No Conflict of Interest, Disclosing Relationships of Interest (Chimsen and LDN Data Company)

To ensure transparency and community trust, Chimsen (Chengxin Technology Co., Ltd.) can prove no conflict of interest with an LDN data company through the following auditable measures:

1. Financial Transparency:

   • Payment Records: Chimsen submits bank statements, invoices, or payment receipts for all transactions related to Haplox’s 5 PiB storage deal, showing payments are made directly by Haplox to SPs or Chimsen (as allocator) without intermediaries or LDN data company involvement.
   • Contractual Agreements: Provide signed contracts between Chimsen and Haplox, specifying Chimsen’s role as an allocator and not as a data provider or LDN entity. Contracts include clauses confirming no financial or equity ties with LDN data companies.
   • Audit Trail: All financial records are logged in a secure, auditable repository CFDA-bookkeeping, accessible to the Filecoin governance community.

2. Business Separation Documentation:

   • KYB Records: Chimsen submits its business registration certificate, ownership structure, and executive team details, confirming no shared ownership or board members with any LDN data company.
   • Affidavit: A signed and stamped affidavit from Chimsen’s CEO (Yin Feng) attesting to no financial, operational, or corporate relationship with LDN data companies.
   • Third-Party Verification: Use a trusted third-party auditor (e.g., Toggle) to verify Chimsen’s corporate structure and confirm no affiliations with LDN entities.

3. Operational Transparency:

   • Allocator Role Clarity: Chimsen documents its role as a Fil+ allocator, focusing on KYC/KYB, DataCap distribution, and SP coordination, not data generation or storage. This is detailed in application PRs and governance reports.
   • Data Handling: For Haplox’s data, Chimsen provides logs showing it only facilitates DataCap allocation and deal coordination, with no access to or control over the genomic data itself, which remains with Haplox and SPs.
   • SP Selection: Chimsen discloses the selection process for SPs (e.g., based on RSR, geographic distribution), ensuring no preferential treatment or ties to LDN-affiliated SPs.

4. Community-Auditable Evidence:

   • Public Repository: All documentation (invoices, contracts, KYB records, affidavits) is uploaded to CFDA-bookkeeping or a dedicated audit folder, with access controls for sensitive data (e.g., redacted financial details).
   • On-Chain Proof: Deal records (pieceCIDs, dealIDs, SP IDs) are published on-chain and linked in governance reports, showing transparent allocation from Chimsen to Haplox and SPs.
   • Third-Party Audit: Invite community or Filecoin Foundation auditors to review financial and operational records during governance calls.
   • Governance Submission: Chimsen submits a quarterly transparency report to the Filecoin Notary Governance Repository, detailing client interactions, DataCap allocations, and SP distributions, with a section explicitly addressing LDN independence.

5. Additional Measures:

   • Client Statement: Haplox provides a signed letter confirming it engaged Chimsen solely as an allocator, with no LDN data company involvement in the deal.
   • IP and Metadata Checks: Chimsen uses tools to monitor submission IP addresses and metadata, ensuring no overlap with LDN entities, as part of Sybil attack mitigation.
   • Community Q&A: Chimsen commits to addressing community questions during governance calls, providing real-time clarification on its operations and relationships.

Next Steps

• Request community feedback on the listed applications and identified points of contact.
• Discuss any governance implications of shared personnel or addresses across applications.

[beatyman]

@Kevin-FF-USA @galen-mcandrew please review and give guidance ,ths

[Kevin-FF-USA]

Hi @beatyman,

Thanks for sharing this update and for documenting the pathway operations.

We’ve received it and added it to our review queue. This resubmission relates to a previous allocator application that was and asked to reapply:
🔗 #405

We expect the audit and review process to take place after we finish the onboarding of the other pathways. Will keep you updated as they progress.

Appreciate your support on this.