Clerk of the House of Representatives
Legislative Resource Center
135 Cannon Building
Washington, DC 20515
http://lobbyingdisclosure.house.gov
Secretary of the Senate
Office of Public Records
232 Hart Building
Washington, DC 20510
http://www.senate.gov/lobby

LOBBYING REGISTRATION

Lobbying Disclosure Act of 1995 (Section 4)

Check One: New Registrant New Client for Existing Registrant Amendment

1. Effective Date of Registration
2/15/2023
2. House Identification
 39128
Senate Identification
 313271

REGISTRANT Organization/Lobbying Firm Self Employed Individual

3. Registrant Organization
Subject Matter
Address
1201 NY Ave. NW
Address2
​Suite 900
City
Washington
State
DC
Zip
20005
Country
USA

4. Principal place of business (if different than line 3)

City
State
Zip
Country
5. Contact name and telephone number International Number
Contact
​Mr. Steven Elmendorf
Telephone
​2028984797
E-mail
​LDA@teamsubjectmatter.com
6. General description of registrant’s business or activities
​Lobbying firm

CLIENT A Lobbying Firm is required to file a separate registration for each client. Organizations employing in-house lobbyists should check the box labeled “Self” and proceed to line 10. Self

7. Client name
​Polygon Labs Services (Switzerland) AG
Address
​Baarerstrasse 98
City
​Zug
State
Zip
​6300
Country
​SUI
8. Principal place of business (if different than line 7)
City
State
Zip
Country
9. General description of client’s business or activities
​Technology platform

LOBBYISTS

10. Name of each individual who has acted or is expected to act as a lobbyist for the client identified on line 7. If any person listed in this section has served as a “covered executive branch official” or “covered legislative branch official” within twenty years of first acting as a lobbyist for the client, state the executive and/or legislative position(s) in which the person served.

Name Covered Official Position (if applicable)
First
Last
Suffix
​Stacey ​Alexander ​Chief of Staff - Rep. Jim Matheson
​Barry ​LaSala ​Counsel - Senate Small Business Committee (Sen. John Kerry)
​James ​Ryan ​General Counsel - Sen. Harry Reid
​Rebecca ​Shaw ​Chief of Staff - Rep. Trey Hollingsworth; Deputy Chief of Staff & Legislative Director, Legislative Director, Sr. Legislative Assistant, Legislative Assistant - Rep. Chris Gibson; Intern - Rep. Devin Nunes
​Natalie ​Farr ​COS, Dep. COS - Sen. Cory Gardner; COS, Dep. COS/Leg. Dir., Leg. Dir. - Rep. Cory Gardner; Prof. Staff - H. Rep. Study Cmte (Rep. Tom Price); LA - DOL: LA- Rep. John Shadegg; Projects Asst -Rep. Policy Cmte (Sen. Jon Kyl)

LOBBYING ISSUES

11. General lobbying issue areas (Select all applicable codes).

​BAN
​FIN
​SCI
​TAX

12. Specific lobbying issues (current and anticipated)

Issues related to Web3 technology; issues related to privacy


AFFILIATED ORGANIZATIONS

13. Is there an entity other than the client that contributes more than $5,000 to the lobbying activities of the registrant in a quarterly period and either participates in and/or in whole or in major part supervises or controls the registrant’s lobbying activities?

No --> Go to line 14. Yes --> Complete the rest of this section for each entity matching the criteria above, then proceed to line 14.

Internet Address:
Name Address Principal Place of Business
Street
City State/Province Zip Code Country
​Polygon Labs Services (Delaware) Inc.
​8605 Santa Monica Blvd, PMB 42857
City
​West Hollywood
​CA
​900694109
​USA
State
Country
City
State
Country
City
State
Country

FOREIGN ENTITIES

14. Is there any foreign entity

a) holds at least 20% equitable ownership in the client or any organization identified on line 13; or

b) directly or indirectly, in whole or in major part, plans, supervises, controls, directs, finances or subsidizes activities of the client or any organization identified on line 13; or

c) is an affiliate of the client or any organization identified on line 13 and has a direct interest in the outcome of the lobbying activity?

No --> Sign and date the registration. Yes --> Complete the rest of this section for each entity matching the criteria above, then sign the registration.

Address Ownership
Name Street Principal place of business Amount of contribution
City State/Province Country
(city and state or country) for lobbying activities

​4th Fl Harbour Pl, 103 S Church St, POB 10240
City
​Polygon Labs Holdings (Cayman) Ltd.
​Grand Cayman KY1-1002
​CAY
State
Country
​0
​100
%
​4th Fl Harbour Pl, 103 S Church St, POB 10240
City
​Mihailo Bjelic (through holdings in Polygon Labs Holdings (Cayman) Ltd.
​Grand Cayman KY1-1002
​CAY
State
Country
​0
​22.76
%

CONVICTIONS DISCLOSURE

15. Have any of the lobbyists listed on this report been convicted in a Federal or State Court of an offense involving bribery, extortion, embezzlement, an illegal kickback, tax evasion, fraud, a conflict of interest, making a false statement, perjury, or money laundering?


Signature
Digitally Signed By: Steven Elmendorf
Date
6/26/2023 6:04:24 PM

ADDITIONAL LOBBYISTS

10. Supplemental. List any additional lobbyists for this client not listed on page 1, number 10.

Name Covered Official Position (if applicable) Have you been convicted of a crime?
First
Last
Suffix
ADDITIONAL LOBBYING ISSUES
11. Supplemental. General lobbying issue areas. Enter any additional codes for issues not listed on page 2, number 11.

ADDITIONAL AFFILIATED ORGANIZATIONS13. Supplemental. List any other affiliated organization that meets the criteria specified and is not listed on page 2, number 13.
Name Address Principal Place of Business
Street
City State/Province Zip Code Country
City
State
Country
City
State
Country
City
State
Country

ADDITIONAL FOREIGN ENTITIES
14. Supplemental. List any other foreign entity that meets the criteria specified and is not listed on page 2, number 14.
Name Address Principal place of business
(city and state or country)
Amount of contribution for lobbying activities Ownership
Street
City State/Province Country
​Polygon Foundation (through holdings in Polygon Labs Holdings (Cayman) Ltd)
​4th Fl Harbour Pl, 103 S Church St, POB 10240
​Grand Cayman KY1-1002
​CAY
City
State
Country
​0
​77.24 %
​Sandeep Nailwal (Polygon Foundation director)
​4th Fl Harbour Pl, 103 S Church St, POB 10240
​Grand Cayman KY1-1002
​CAY
City
State
Country
​0
​0 %
​Antoni Martin Beltran (Polygon Foundation director)
​4th Fl Harbour Pl, 103 S Church St, POB 10240
​Grand Cayman KY1-1002
​CAY
City
State
Country
​0
​0 %

ADDITIONAL LOBBYISTS

10. Supplemental. List any additional lobbyists for this client not listed on page 1, number 10.

Name Covered Official Position (if applicable) Have you been convicted of a crime?
First
Last
Suffix
ADDITIONAL LOBBYING ISSUES
11. Supplemental. General lobbying issue areas. Enter any additional codes for issues not listed on page 2, number 11.

ADDITIONAL AFFILIATED ORGANIZATIONS13. Supplemental. List any other affiliated organization that meets the criteria specified and is not listed on page 2, number 13.
Name Address Principal Place of Business
Street
City State/Province Zip Code Country
City
State
Country
City
State
Country
City
State
Country

ADDITIONAL FOREIGN ENTITIES
14. Supplemental. List any other foreign entity that meets the criteria specified and is not listed on page 2, number 14.
Name Address Principal place of business
(city and state or country)
Amount of contribution for lobbying activities Ownership
Street
City State/Province Country
​Jordi Baylina (Polygon Foundation director)
​4th Fl Harbour Pl, 103 S Church St, POB 10240
​Grand Cayman KY1-1002
​CAY
City
State
Country
​0
​0 %
​Sanket Shah (Polygon Foundation director)
​4th Fl Harbour Pl, 103 S Church St, POB 10240
​Grand Cayman KY1-1002
​CAY
City
State
Country
​0
​0 %
​Polygon Labs Tokens (Caymen) Ltd.
​4th Fl Harbour Pl, 103 S Church St, POB 10240
​Grand Cayman KY1-1002
​CAY
City
State
Country
​30000
​0 %