The Phylos Affair

The cannabis science community addresses Phylos Biosciences’s plans to start commercial breeding.

PART I – The Announcement

It has been two weeks since Phylos Bioscience unsettled the cannabis breeder and cultivator community with an official announcement via Instagram that it has started a “plant breeding program launching in spring 2019.”  The post contains a video clip of Phylos CEO Mowgli Holmes claiming, “We’re working with breeders and growers all around the world now to make outrageous new weed,” and written comments stating, ‘We believe breeders should always get fair credit and compensation for their work. We’re currently working with long time Oregon breeders to negotiate fair licensing contracts for seeds, clones, and other germplasm that will serve as the foundation for our breeding program.”

Immediate reaction was mostly scathing as posters flooded the thread with accusations the company had directly betrayed its promise not to compete against breeders who had submitted plant samples to them.

“So, you stole the genetics I paid you to test?” posted @mzjillgrower. “You told me this wasn’t true!”

Those sentiments are shared by others who see this episode as being the breeder community’s greatest fear realized. “This is kind of everybody’s doomsday scenario, so right now we’re all panicking and angry and the feelings are running high,” said Trevor Wittke, aka @sungrownmidz, a farmer, breeder, and the executive director of the Calaveras Cannabis Alliance. “No one is going to trust a lab that does genomics ever again unless they have some pretty powerful mechanisms for protecting themselves,” he added.

Still, Wittke said he was not surprised by the announcement. “I’ve known this was happening,” he said. “I could see what they were doing all along. That’s why I was quick to call them out.”

Other posters were surprised by the news and a few were supportive of Phylos, but the company clearly had misjudged how the community in general would react. Within a day, Phylos VP of Marketing Paige Hewlett tried to stem the bleeding with posts explaining what the company was and wasn’t doing with people’s data.  

hi there,” began one such post. “A couple points: 1. We are working to acquire seeds and plants (partial and full collections) from breeders in Oregon. We’ll be sharing those details as deals are finalized. 2. If you look at the galaxy, you’ll see a registered trove of data and the proof of why we couldn’t do the things you’re talking about (it’s all public) 3. If we were willing and able to use the genetic data people sent in, we wouldn’t need a breeding program and we wouldn’t need to do the work in characterizing the seeds we do acquire, going through breeding projects, and could just come to market with plants.”

Holmes also attempted to quell criticism in a message posted to IG April 19 in which he once again stated, “We’re not using the data about your plants to help us breed. The genotype test data is not valuable to a breeding program because it’s not paired with phenotype data. You have to generate that kind of data from living plants, on a much bigger scale.”

Posters in support of Phylos also intimated that not much of value could be derived from the “dry” plant samples submitted to Phylos, and Holmes doubled-down on the claim to Willamette Week. “We can’t steal their actual plants,” Holmes said. “We wouldn’t do that. It would be illegal to do that. And, scientifically, if you have a piece of dead [plant] material, you can’t bring it back to life. That would be like bringing a person back from a fingernail.” More on this claim below.

The story was also picked up by Cannabis Now, which included in its recital of the case against Phylos a video of Holmes’s presentation this February at the Benzinga Cannabis Capital Conference, during which he explained Phylos’s breeding program and, as noted by writer Jimi Devine, specifically mentioned the company’s ability to use “DNA sequencing to identify genetic trait markers.” Devine then used the contents of the half-hour presentation to drive home the fact that Phylos Bioscience always had one destiny.

“While many had always thought of Phylos as a data company,” wrote Devine, “Holmes essentially admitted in his Benzinga speech that the breeding program has always been the plan. The company was designed in such a way to make it a target for acquisition by Big Agriculture.”

During another part of his presentation, Holmes in fact offers a compelling narrative of the company’s original, current, and future strategies, in which he explains the nexus between the roots of Phylos, its business model, the structure of the company to enable that business model, its methods of data acquisition, including the Phylos Galaxy, and the new breeding program.

“We’re building our own plant breeding facilities in California, Oregon, and Canada and we’ve just formed an entity and registered genetics in Colombia,” he said. “Our core business is plant breeding, and we had to build two businesses to support that. It takes an incredible amount of plant data to do advanced genomics, so we had to build an entire testing business to create all that data. It’s also difficult monetizing new cannabis varieties in this fragmented market; that’s actually not something anyone has figured out how to do yet. So, we built a joint venture to bring our plants to market as tissue culture clones.

“The [Phylos] testing business began as a collaboration with the American Museum of Natural History,” he continued. “We collected cannabis DNA from all around the world and sequenced it and made this giant map showing how all the different varieties are related. It’s called the Phylos Galaxy. It’s online; you can play with it; it’s kind of fun. It is actually the most advanced population genetics data visualization for any species, and it is the foundation for our breeding program.”

He further enticed the crowd with the promise of better cannabis to come, courtesy of Phylos, while predicting the demise of current cultivars. “All the cannabis around now will be replaced by varieties that are optimized and specialized, and we’re going to be the company that makes those. We have really huge barriers to entry protecting us. I think the main ones are that it would be impossible for anyone else to collect this data set at this point, especially since we have the Illumina gene typing array. We are fully integrated in the cannabis industry and I think we have more trust in the cannabis industry than any other science company. We have more scientific backing than any other cannabis company, and cultivators can’t really do their own breeding.”

The video went over like a lead balloon with the same breeder community that fed the Phylos Galaxy so abundantly that it could become the foundation of Phylos’s breeding program. But Phylos’s issues were not limited to alleged misrepresentation to breeders supplying it with free plant samples, and breeders were not the only critics of the company. Increasingly, scientists and genetics specialists working in the space, most of whom know one another as either colleagues and/or competitors in what is a tightknit community, have stepped forward to express their opinions about Phylos’s actions and claims both before and after it announced its plan to breed.

PART II – Peer Review

“The concern that a lot of people are advancing [on Instagram] is that they mistakenly think that their genetics have been stolen, and that’s not what is going on. I think it’s worse,” said Michael Backes shortly after the Phylos announcement hit. “They’ve basically charged people to genetically fingerprint their cultivars, and they’re mining that data to find markers to form the basis of a breeding program so that they can compete against the people who paid them to sequence their genetics. It’s like a leech operating a blood bank.”

Backes, author of Cannabis Pharmacy: The Practical Guide to Medical Marijuana and the co-inventor of a handful of Biotech Institute-assigned cannabis patents, one of which spurred the creation of the Open Cannabis Project in the first place, flatly dismissed as irrelevant the claim that Phylos would never patent anyone else’s plants. “In other words, they’re saying what they’re not doing, which nobody really expected they were doing,” he said. “But what they were doing is that they were putting themselves out there like they were Consumer Reports, and now they’ve decided to get into the home appliance business. It’s the reason that all testing labs should be prohibited from engaging in any other commercial cannabis activity, because they have a fundamental conflict of interest. It’s as if 23andMe got into the designer baby business.”

Though not necessarily damaging to a singular person, Backes said that what Phylos did collectively is bad enough. “They’ve collected an amount of genetic data that they can extract markers from to develop next-generation cannabis cultivars that will have a competitive advantage over the people who in trust extended their genetics to them.”

The principle governing other people’s information is clear, he added. “Data should always belong to the person who extends it whether they are extending their own genome or a plant to cultivate,” he opined. “The expectation is that. So, if Mowgli wants to exploit that data, he should pay each cultivator to do it. In other words, you should not be exploited for your data, and your surplus data should never be exploited for profit without your permission. The bottom line is that this is surveillance capitalism where people are making money off surplus data.”

Justice should be served by the community, he added. “They need to look at these guys and go, ‘We’re not going to buy anything from you ever because of what you’ve done.’ This is very much a reputation-driven business and I think they have completely damaged theirs.”

None of this surprises Backes. “It cost a lot of money to set up Phylos, with their gear,” he said. “It’s not state-of-the-art gear, but it’s expensive, and they have made promises to their investors to be able to create a business out of what they do. Testing genetics for cultivators is not a very good business, so they needed to exploit that data, because breeding the next generation of cannabis based on data they’ve acquired from duping people is a good business.”

But not everyone believes that what Phylos has done gives it a competitive advantage. According to Nathaniel Pennington, CEO of Humboldt Seed Company and a board member of Open Cannabis Project, the threat is overstated. “I strongly disagree that what they have somehow gives them this unbelievable advantage over any other breeders,” he said. “That’s a ridiculous thing to say. After watching the Benzinga presentation, it’s quite clear that his assertions of breeding dominance were simply to gain the favor of an investment company.

“I mean, I just don’t think the genetics they’ve received from submissions from around the world gives them some kind of huge advantage over any other breeding company. All the data and sequencing equipment in the world doesn’t compare to years of experience working with the species.”

Pennington may discount the threat but not the intention by Phylos to benefit from others’ work, the signs of which he has experienced firsthand. “On their website, it says Phylos is here to help breeders with screening tools for breeding genomics, but I don’t know how many times I’ve gone to them and asked them to develop a simple assay with me that would help my breeding, and we’ve taken that project to another company and we’re actively developing it right now.”

Pennington said he is worried because he cares deeply about the team at Phylos as well as the people upset with them, but added he’s been contacted recently by several companies struggling with what recourse they may have and seeking his advice. He said he just spoke with a company that currently has an agreement with Phylos. “They’re freaking out there,” he said. “They got suspicious about their agreement, because Phylos kept wanting information and genetics from them and then not coming through on their part of the deal, and not giving them any kind of advantage or help.”

Pennington recounted another conversation he had within the last several days with a company also working with Phylos that has a similar story. Pennington said they told him that the writing was on the wall with Phylos. “We gave them all of these genetics and we’ve been wondering for the last three months why they haven’t been fulfilling their end of the bargain,” he said they told him. “And now it’s kind of become evident that we can see what he said to his investors what their long-term intention is, and it wasn’t to help us develop a great product line, but to essentially take what they could from us and then leave us in the dust.” Pennington added that this company also said it would be looking into whatever recourse was available to it.

Pennington especially wanted to make clear that Humboldt Seed Company is not saying it will never work with Phylos again, but added. “Alienating yourself from the community that has the largest wealth of knowledge and interaction with the plant can’t help you reach your goals. It’s a road with no end.”

Dry versus wet

In search of answers, Future Cannabis Project asked genetics scientists working in the cannabis space to evaluate the the oft-repeated claim by Phylos and others that genetic information (DNA) derived from dry samples submitted to it provides limited value to its breeding program because it is significantly inferior to the information (RNA) derived from “wet” samples

“There is a lot of information in DNA,” said Reggie Gaudino, president at Steep Hill and a newly added board member of the Open Cannabis Project. “There is stuff [in DNA] related to lineage and there is stuff related to function. Some things, like the Phylos Galaxy, are related to lineage, and if you can make assumptions about function that go with lineage, you have a rough map that gets you halfway there. You can tell strain patterning and you can build maps, because when you have sequenced enough of the different strains you can do what’s called variant call tables, which allow you to say, ‘Blue Dream looks like this. It has these SNPs (single nucleotide polymorphisms). Or, ‘Green Crack is different because it has these SNPs.’

“If you get enough strains,” he continued, “now you have the ability to do a lot of work and breed a lot of things by following specific individual points of difference. You get a lot of information from DNA, so whoever is [saying it has no value] has no clue what their talking about. That’s the reality.

“You get a whole different level of information from the ability to look at RNA,” he added, “because the DNA tells you what the potential is, but it doesn’t tell you what the actual outcome will be. RNA is a better predictor of that, because now you can say, ‘This gene is expressed four times higher than that gene. So, yes, there is additional information that that can used as we get further down the path, but you get a whole bunch of information just from the [dry] flower.”

According to Eleanor Kuntz, a PhD in genetics from the University of Georgia and co-founder of botanical genomics company, LeafWorks, “It’s a bait-and-switch answer to say we can’t clone your plant or tissue couture your plant, which is true. You cannot do either of those things with a dry sample. But in the absence of information, which is the status quo of science surrounding this plant, you can get that information from dry samples and you can absolutely look at things, especially around areas of the genome where we know a lot using other data.

“For instance,” she added, “we know a lot about flowering time in general, but if you have lots of dry samples with DNA data, you can learn a lot about flowering time in cannabis because you have all that data. But you can’t find novel information from that data because you haven’t done an experiment to contextualize it.”

We wanted to know what Kuntz thought about Holmes’s comment that “the genome type test data is not valuable to a breeding program. Because it’s not paired with phenotype data, you have to generate that kind of data from living plants on a much bigger scale.”

“That’s a half-truth,” she said. “It is true that with uncontextualized data, you can’t get at phenotype in the same way, but the issue is that if you have that kind of data, and then you do your own research, you do your own experiments, that data becomes that much more valuable again.”

According to Kevin McKernan, chief science officer and co-founder of cannabis genomics research company, Medicinal Genomics, “We’re seeing the Phylos defense as a bunch of straw men. Okay, you can’t resurrect your plants from the DNA, of course you can’t, but you can amplify any gene you want out of that DNA, and you can sequence that genome and you will have a tremendous amount of intelligence about people’s plants. You can amplify genes of interest from one genome and put them in another genome; that’s not hard.

“Phylos may not have living tissue—there are mixed messages online about some people sending in living tissue and some not, I can’t vouch for that—but they definitely have the genomic DNA, and there’s a lot they can do with it,” he added.

Beg, borrow, and steal?

McKernan was at first reticent to speak publicly about Phylos despite having long-standing concerns about its practices. “We were going to stay out of the fray because they might send us a frivolous letter that I will give to legal to deal with,” he said, “but last week we made the decision that we couldn’t be ambivalent about this.”

The risk for doing nothing, he added, was both ethical and existential. “The frivolous letter is one cost to the company,” said McKernan. “The larger cost is if we sit on the sidelines and don’t speak out loudly about this, because then we will look like the next people about to pull off the same heist.”

The stakes are high because the threat is seen as dire. “Our sequencing business is basically at risk because of what they’ve done,” said McKernan. “No one will send samples to anybody after what happened unless sequencing companies come out very strongly opposed to this with evidence and methods to prevent it from happening in the future. So, that pivoted us toward, ‘Okay, enough.’”

As a result, McKernan has been on a tear the last week, posting not only to IG threads begun by Phylos and others, but also posting to his own IG account in an effort to set the record straight about Phylos, distinguish Medicinal Genomics practices from those of Phylos, and set in motion actions intended to correct what McKernan claims to be myriad “inaccuracies”  made by Phylos to potential investors regarding its competitive advantage in the industry. The gloves are off.

Regarding the question of how much data Phylos has made public versus what they may have retained for themselves, McKernan was circumspect. “We don’t know what they have internally,” he said, “but what they’ve made public is heavily compromised. I wouldn’t consider it a certification. The methods are unclear and are not peer reviewed. When you poke them about what their methods are, they lie and mention that they are using the same methods used in the Human Genome Project, and I can assure you and go on record that that is a straight up lie.

“You can tell they didn’t use those methods by the data they put it in NCBI (National Center for Biotechnology Information),” he added. “It’s a different sequencing platform, and it’s even listed at NCBI as using the sequencing platform that didn’t even exist before the Human Genome Project was around.

“What they put public is, I think, dust,” he continued. “Here’s the dust of the project, put public to satisfy people that you did something publicly, and they put it public very late. That’s one of the other issues. They didn’t put out public information daily; they harvested it for two years. All right, so the data that is public covers one to 2,000 SNPs. They’re on record to investors saying they have a 50,000 SNP chip array. So, you put 2,000 public. Where are the other 48,000?

“They are clearly using customers samples to at the very least pick out what should be sequenced,” he concluded.

Indeed, McKernan’s effort to correct what he sees as a seriously corrosive situation with legs has inspired him to engage in an escalating course of action.

“I can’t tell whether Phylos is overselling to investors to try and get money or whether they really have this huge advantage, because the data they made public is nothing to bank the company on, but the information they’re giving to investors we also know has some inaccuracies in it,” said McKernan.

Even the basic claim by Holmes that “we are not using the data from your plants to help us breed” is easily refuted. “He said the opposite in his investor presentation,” noted McKernan, “and we have slides Alicia Holloway presented at the ACE conference a few weeks ago that clearly demonstrate that they are using the Galaxy data to do whole genome sequencing work.”

The inaccuracies do not stop there, he added. “For instance, they mentioned they have an exclusive with Illumina for their array, but I know the Illumina people well,” he said. “They almost bought our company. I called them and said, ‘This sounds out of character. You guys have never done an exclusive before. What happened?’ And they said, ‘We still haven’t had an exclusive. Send us the presentation and we’re going to send it to legal. We’re going to make sure he’s not misrepresenting exclusive activity here.’

“The second thing they put in their document is that they’re working with Google Brain,” continued McKernan. “I happen to also know the guys at Google Brain. I called them up and asked if they were doing anything with cannabis with these guys, and they emphatically said, ‘We are not doing anything with Phylos, and we don’t want anything to do with cannabis. Please send me the videos and documents and I’m going to send them to legal.

“So, both Google and Illumina are saying they have no relationship with this guy while he’s claiming he has one to attract investors.”

Open Cannabis Project

Late last year, Open Cannabis Project co-founders Holmes and Jeremy Plumb were asked to submit their resignations as members of the non-profit’s board of directors by executive director Beth Schechter. It was news that was not widely disseminated at the time, and we were curious if it was related in any way to the questions of transparency that currently surround Phylos.

Schechter, who has a background in open data and technology education, got involved with OCP in late 2017 and runs it out of her Oregon home on a budget that can’t afford shoestrings. She spoke at length last week about a situation she has been dealing with pretty much since she became involved with OCP; namely, the litany of complaints from people ranging from Phylos competitors to others unhappy about issues ranging from community inclusion to data hoarding, with the latter issue becoming a recurring theme in Schechter’s relationship with Phylos, which was obviously in control of data derived from samples submitted to OCP.

“I began to get a little frustrated when we would be fielding some complaint on Instagram about Phylos hoarding data, and Open Cannabis Project is part of the problem,” she said. “And I remember emailing Phylos, ‘Sure would be cool if you uploaded that data to the National Center for Biotechnology Information. It’s been a year and a half since you released data. If you just upload it there’s no claim here from anyone.’ And they’re like, ‘We’ll get to this as soon as possible, and the soon as possible kept getting kicked down the line. I’m like, ‘Okay, that’s not so great. I’m not really thinking anything nefarious, but is clearly wasn’t a priority for them, and it was out of my hand. There was nothing that I could do.”

Schechter also had several people tell her that they felt like she had been used by Phylos. “After enough people say that, you can’t just ignore it,” she said. “You can’t just say, ‘Oh, whatever, you’re just being paranoid.’ And there’s only so many times that you can respond to something like, ‘Open Cannabis Project is covering up for Phylos,’ before you’re like, ‘Okay, what is going on? What I thought were conspiracy theories aren’t going away? Why? What’s the deal?’”

She also had people whisper in her ear, “I’ll bet Mowgli’s getting patents.” She could only respond, “I don’t know. I don’t talk to him that often and I’m not privy to what goes on at Phylos.”

The patent truth

“I was at MJBizCon and Peter [Cervieri] from Future Cannabis Project was doing interviews at the booth and asked me to do one,” said Schechter. “I was paired with someone and a question was asked about who some of the people are who are doing gnarly patents. I would probably change my answer now, but I named a couple of companies.  

“After the panel ended,” she added, “Peter said to me, ‘You know, you should really talk to Mowgli about that.’ I said, ‘What do you mean?’ I couldn’t really tell if he was joking or not, but he said, ‘Well, we should just get Mowgli on camera and ask him what he’s doing with patents.’ ‘I was like, that’s a lot, but okay, I’ll ask him.

“So, later that night I found Mowgli and asked him, ‘Are you planning on getting patents for plants?’ And he looked at me and said, ‘Yes, we are.’

“Okay, well I really hope you are transparent about that,” she told him. Schechter said she cannot remember what he said in response, but that that was the end of the conversation.

This was in November. In December, leading up to The Emerald Cup, Schechter recalled that she was really concerned that someone was going to ask her about Phylos patents in public. “I don’t have a good poker face,” she said. “So, I told Mowgli, ‘Look, I’m doing a panel and if someone asks me [about patents], I’m going to have to say yes.’ He said he thought there might be other responses, like if anyone has questions about Phylos, they should ask Phylos, which is true because I don’t have direct knowledge [of Phylos], so I shouldn’t answer that question.  But because he had told me, I would say yes.”

Schechter continued, “So, we had the conversation and he said he was really trying to get the data uploaded by The Emerald Cup. But by this point, I’m like, ‘Okay, you’re getting patents, you haven’t uploaded the data. I don’t really have a lot to hold people off from these things they’re saying [about you]. I need you to do the things you said you were going to do.’

“I was, like, ‘What are you doing? You need to be transparent. If this is what you are doing you need to be open about it, and in part, you need to be clear about it because you’re not actually doing anything wrong. So, what’s the reason for all the secrecy? I just don’t get it.’ And that’s really where I left it.

Phylos uploaded the data to NCBI by December 18.

“That sort of coincided with the big board meeting we scheduled for right after The Emerald Cup,” said Schechter. “We planned on having our big in-person board meeting the Monday after the Cup, and Mowgli and Jeremy Plumb (Director of Production Science at Pruf Cultivar and co-founder of OCP) said that they were not going to be able to make it, which was going to affect my ability to have a quorum. Also, they had not been able to make a few [previous] board meetings, and I was thinking, okay, it’s time. We had already discussed it, and I had told them I thought it was time for them to step down from the Board, but that I was super happy to have to have them as advisors, and they were, like, ‘We agree.’ So, I asked them to step down prior to that [Emerald Cup] weekend and we received their letters of resignation that weekend.”

But then another thing happened that only served to reinforce Schechter’s worst suspicions. “I was moderating a panel at The Emerald Cup that Jeremy was on. Reggie Gaudino also was on it, Dale Hunt was on it, and Jeremy Kapteyn (Rose Law Group), another wonderful IP lawyer,” she explained. “Part of what we were talking about—something that had come up in conversations at OCP a lot, too—was whether it made sense to tell growers to open source their work and open source their information at a moment when big companies are coming in and trying to commodify cannabis? Should we be telling them to open source everything, when in fact, they might need some kind of legal protection? We needed to acknowledge that there are times when patents are appropriate. Now, on a personal level patenting plants is weird to me, but in the business world and in the world of breeders, people have a right to protect their work and their inventions, and to do so in a way that does not hinder innovation. And it does not feel right to me and to many on my board to tell people to give away their information freely at this moment of cutthroat monetization. If a grower invents something that’s really neat, not even necessarily getting a patent on it, I want them to be able to be paid for their work in a significant way.

“So,” she continued, “we’re on this panel and we’re trying to talk about open source in the context of all that stuff, and Jeremy Plumb says, ‘Yeah, I used to be totally against patents but now I’m not totally against patents, and I’ve been doing this project with Phylos where me and a few other breeders have been sharing data with one another, and something, something, something.’ I was on stage and I got really angry, because after all that time, to be waiting on data and then to find out that, not the same data but other data-sharing was going on, meant there was time [for Phylos] to share data with other people but not time for them to share data with the public. That was hard for me to hear. By this point, it wasn’t even a red flag, because I’d already seen so many flags. It was more like a cherry on top of a cake that had been baked and frosted.”

Despite her shock, Schechter said she kept it together on stage, but confronted Plumb afterwards. “I asked him. ‘What’s this data sharing thing?’ I don’t even remember what he said because I was seeing red. Then I asked a Phylos’s employee what was up with the data sharing, and was told, ‘Oh, we have to talk about it later.’ I’m just mad. just angry.”

All of this happened at the end of the year and, for Schechter, represents the beginning of a major shift for Open Cannabis Project, one they are still thinking through. “It is important to all of us to have these public records for cannabis, and there are also ways to do it much better,” she said, adding, “By the way, prior art documentation is not just [genetic] data, and it’s not just chemical data, but data about the whole plant, how it was grown, the soil it was grown in. So, we’ve been having good conversations with groups and people who want to do the sort of documentation we think is necessary, but we also have no funding right now and are constantly dealing with these PR things.”

Schechter believes Phylos’s greatest sin is its duplicity, the two narratives. “What’s been hard for me is that, okay, if you’re getting patents on plants, at the end of the day that’s not even that big of a deal,” she said. “It’s not something I’m fond of, but it happens all the time. It’s not the big moral issue. The issue for me is that there have been two narratives happening. One narrative for investors and another for the community. And where I’ve been sort of caught in the middle of it is when people would say, ‘So-and-so said one thing here and they said one thing there; what are you going to do about it?’ And I would be, like, ‘I don’t know. I’m trying to do this job. I’m trying to move this project forward.’

“But, after looking into whether this was a plan to put data in the public domain so that it could be used by anyone, including Phylos, or a plan to get all the genetic material, and whether they’ve been holding on to genetic material,” she added, “I started digging into all of these big questions, and what I found is that as far as I can tell, no one has stolen any data and no one has stolen any genetics. There’s only so much I can see, of course, but no nefarious actions have taken place aside from these two narratives, and it just needs to stop. To me, that’s the worst of so much of this confusion that has been hard for everybody and hard for Open Cannabis Project.”

The Phylos fallout has just begun.

To Be Continued… Part II coming shortly.