RE: Response to Concerning Post

RE: Response to Concerning Post

Nikita Kolmogorov

Nikita Kolmogorov

This is my personal opinion of the official Mirocana answer to my previous article. First of all, let me get it straight: I has never intended to cause any harm to Mirocana or anybody affiliated with it. Secondly, I highly appreciate professional answer provided by George (Mirocana CEO). Thirdly, I'd like to state that my main concern has always been to try to clarify as many sketchy things about Mirocana ICO as possible for the potential investors — hence I wrote the original review. Please, note that I have never claimed that Mirocana is a scam project but I've always considered such an option, just like any intelligent investor. My comments to the Mirocana article can be found below.

Please, note that Mirocana isn't just a startup funded by VC. They intend to raise $40 000 000 from usual investors claiming to give them profits. When you read every single point from this article, please, keep in mind that they are already raising money and every single day without response or necessary proofs can cost people their savings. They owe us information about their company and operations, they have to display it.

Everything Mirocana says about my personality might be true, except that I have never made a claim that Mirocana is a scam project. Also, I have demanded prompt response to my Mirocana review because their pre-sale would end soon and I didn't want anybody to invest to Mirocana without receiving the official response. My demands could have been seen as provocative, but without them (and without the help of my fellow subscribes, for some reason, called "bots") we wouldn't have got the official Mirocana response so fast.

We will provide you with the more detailed split of our returns by instruments and risk groups within two weeks from now. Please, be patient.

If they have been running this bot for 2 years now and been managing their own funds, why do they need 2 weeks to present us simple numbers that they should already have?

We already have quotes and other market data to train our neural nets. We receive our data from 40+ paid and free data sources that are described on our technology page. We constantly negotiate with new data vendors and seeking for an exclusive data edge. Predicting financial markets is a pure feature generation problem - the data itself has no value, the insights that you could "mine" from this data does.

Completely legit. Good answer, I take back my point from the previous article. Thank you.

Our roadmap was released in September of 2017. Our crowd-sourced learning platforms will be released according to our roadmap or earlier.  We do not plan to release all the platforms at once. We plan to gradually launch our platforms and keep the room of their adjustments to address the users' needs. We also believe that the strategy is the core, thus, we are not limited by our current view and plan to test other solutions for our clients and constantly improve our development plan. 

To be clear: I've never claimed that this tech isn't possible to build. I claimed that they don't have the human resources to build it. AI cryptotrading is the reality and it has already been built by multiple companies. But we'll get to the team later.

We have enough computing power to cover our current needs. We constantly adding new strategies and test different configurations of neural nets and it's clear to me that we will need more servers power in the future. We will rent additional servers as we mature.

My concern was strictly about how they are going to give users ability to test users' machine learning algorithms in real time. Currently it takes enormous power to train just one neural network a couple of times. They claim that they will provide their users with real-time checking of the neural network algorithms. My question is: how will they achieve testing of the user created neural network algorithms technically? They still haven't answered this one.

Mirocana Target platform will be the platform where the system predicts the success of ICOs based on the performance of past ICOs and users rating data. This platform will have a believability-weighted decision-making, meaning each forecaster will have its own weight based on past performance and assessments. The success of this platform will eventually depend on the number of users. We negotiate with a co-founder of CoinTelegraph the potential partnership in which we develop the platform and they provide traffic - if we will come up to an agreement we will launch the platform this year. For now, you can explore the prototype.

This is a very nice answer with the proof-of-concept MVP already built. I hoped that all the Mirocana answers were going to be like this one. But for this particular answer, thank you, George. I take back my point from the previous article.

The author claimed that Mirocana bot is disabled.
Trading activity of the bot was suspended in September 2017 but the other functionality of the bot is available. You can request a recommendation for any company that is listed on NYSE or NASDAQ stock exchanges or see real-time fundamentals data for these companies using in-line mode.
We will restore bot's trading operation this or next week. Currently, we apply the new version of our predictive system to this bot.

This bot is still disabled and no comments were given about the bot not performing well enough by their own official data. How can you build the product on top of the trading algorithms that don't perform?

This author claimed the lack of leadership and poor management.

I did, and George haven't debunked this point at all. The only thing he gave us was reassurance, like saying that: "I know I'm young and it concerns you. But don't worry, we work hard and everything is going to be alright!" However, it's totally up to the investors whether to bet on George or not. I don't want to push the argument about the founder's age any further — it is just a concern and you don't have to take it into account.

The author used social networks, which pretend to be the indicator of one's experience but do not present the full picture. We worked as the team in parallel to our main employments in the past.

I mostly got the information about the sources I had. Social networks, especially LinkedIn is a great way to figure out one's experience. However, my LinkedIn is completely empty, I admit. Although, I don't raise no money at the moment.

But let's get to their team one more time, shall we?

George Petrov (CEO, founder) - previously he was managing information security company, developing high-load backend infrastructure for mobile games and he was working in several IT-companies on leading positions as developer or data scientist.

We would like to know:

  • What information security company did George manage?
  • What was the most difficult task George completed while developing backend infrastructure of the mobile games?
  • What was the maximum number of people using high-load systems George built and what was the number of the requests per second? Links to the mobile games George worked on are required to proof his experience.
  • What were the IT-companies George has worked on leading positions as developer or data scientist and what were his titles exactly?
Eugene Ulyanov (co-founder) - has a Ph.D. in Law. In the past, he was a founder of a marketing agency and several start-ups together with Embria Ventures.

We would like to see:

  • Eugene's Ph.D. certificate in Law.
  • The name of the marketing agency that he founded, it's maximum size and the biggest project they worked on.
  • The names of the startups Eugene founded and their quick description.
  • Embria Ventures has plenty of companies on their website, which ones were founded by Eugene?
Alexy Dementyev (tech-lead) - was working on leading positions as a developer and engineer in several companies in Russia. He has an extensive experience of building high-load infrastructure and scalable systems.

We would like to know:

  • What companies did Alexy work at on leading positions as a developer and engineer?
  • What was Alexy's largest project? How many users used it, how many requests per second did it handle? Links or press releases are required to prove the experience.
Vasily Boychuk (data scientist) - analyst and developer of predictive models. In the past, he was a leading employee of a Research Institute for the Analysis of Social Network Data and the author of scientific publications on the subject of predictive modeling. He is responsible for developing and implementing simulations for strategies.

We would like to know:

  • Where can we find the scientific publications on the subject of predictive modeilng written by Vasily?
  • Can we see the proof that he has worked at Research Institute for the Analysis of Social Network Data? Can we also get his title and the link to the institue's website?

And what about the rest of the team? The last time I checked, I roasted 8 of them, we are missing at least 4 team members here: do they have nothing to be proud of except Mirocana yet?

Today, 4 engineers are involved in the development of our predictive system in a full-time capacity. It's not enough, we are hiring more in coming weeks. I invite any interested person to our office in the center of Saint-Petersburg.

Good answer. I would rather ask you to first find the team and then raise funding, but it's totally up to you and investors whether to believe that having only 4 developers having raised $170 000 in May and $260 000 in October you are capable of delivering the profitable product. My personal opinion: you aren't, but that's only my opinion. I'd take back the point from my previous article but I still think that Mirocana team is inexperienced and it's my right to think so.

There are no and never were any "fake advisors". Currently, we have five advisors and they are shown on our website (except Vadim Koleoshkin from Zerion who joined yesterday - they conduct an audit of our smart-contract). Now we negotiate with four more, two of them awaiting compliance approval. I think we will grow our advisory board to 12 before the token sale starts.

Sure, I take back my point about the "fake" advisors, even though I've never claimed that they are fake, I just mentioned that 5 out of 10 of them claimed not having worked with Mirocana. Believe it or not — it's up to investors, not me. The fact of putting the advisors faces and names on the website and the fact that you haven't put them back could mean something.

This author claimed the low-profile advisors.
We are constantly working with the market and best in class professionals to strengthen our advisory board. We plan to engage several specialists in quantitative trading, crypto trading and blockchain from the market to help us with our plans and, if necessary, adjust our strategy. However, we believe that our pool of advisors represents a solid set of different professional qualities.

I have never claimed that the advisors were low-profile. I claimed that they were irrelevant to the project itself (i.e. no trading, AI, investment, financial, blockchain advisors).

Firstly, Denis Efremov is not only assisting us with strategic operations of Mirocana as the corporation, he is also assisting us in building the partnerships with capital markets providers and crypto institutions being the fin-tech professional with capital markets focus.

Denis did confirm helping Mirocana with capital markets provides relationship. Mirocana now has one relevant advisor: financial. Still no tech, AI, machine learning or blockchain advisors.

Secondly, George is not only advising us with ICO preparation but is also sharing some insights on crypto turnover solutions, which are essential for our platform.

Whereas George haven't declined sharing insight on crypto turnover solutions, he did mention in the private messages on Facebook that he advises Mirocana on ICO process and company's finances. Even if he shares insights on crypto turnover solutions, Mirocana still has no tech, AI, machine learning or blockchain advisors.

The person is not familiar with our terms of the token sale. We have two-entity structure, the Canadian company is the main intellectual property owner in the group, hence the Estonian company provides the services to the clients using the technology of its Canadian affiliate. Estonian company is the one issuing tokens.
Our international legal advisors analyzed all legal base in Canada and provide us with the opinion that tokens are not securities in Canada neither per the federal nor per the regional law.We also conducted Howey Test with the help professional lawyers and confident that our tokens are not securities under the US legislation. We are conducting external legal review of our ICO and will release the independent legal opinion next week.

Sure, take your time. 2 weeks is just right for your pre-sale to end without releasing the necessary legal information to the investors. I have never snitched nor I intend to snitch anytime in my life and will not personally make any inquires, but keep in mind that if you'll get any meaningful investment from a Canadian investor, they would probably send a letter to OCS to check whether your tokens qualify as securities or not. I'm glad that you started the legal audit that should definitely clear things up for your potential investors.


I'll say it again:

  • I've never claimed that Mirocana is a scam project
  • I have no negative personal feelings to neither Mirocana company nor to anybody affiliated with it
  • Mirocana still has me banned on all of there channels despite my overall positive attitude towards their project

And now we have shortlisted our questions, thanks to the Mirocana answers. We hope that Mirocana will keep up the good work and answer the remaining questions:

  • Why will it take 2 weeks to release the trading data if it is already there?
  • How will they give users ability to train neural networks? Will they allow users to write and test machine learning algorithms?
  • Why there were no comments on the core product (Mirocana Telegram bot) performing poorly?
  • Why didn't they provide the information about the rest of the team?
  • We would like to know more facts about their team members to be sure that they are experienced enough. There should be no issues in providing such data if their claims are true
  • We would like to get the legal documents sooner, if possible — if not, it's up to investors to decide on investments
  • We would like to see relevant (AI, tech, blockchain, machine learning) advisors on board or Mirocana official response that they don't have any

I look forward to Mirocana responses and will definitely check all the facts that the provide us with as many times as required to dig up the truth.


Update from 23rd of October, 2017:

  1. *name removed* (one of the advisors) is no longer advising Mirocana as he confirmed in PM on LinkedIn. He has sent them the notice. I repeat from his words: "No longer involved, due to time constraints. No funds of any kind were ever exchanged between me or George. I can’t speak to anyone else. I also never accepted anything. Nor will there be any funds. Between George, Mirocana and I". We would like to see more tech advisors involved in the project, whereas right now Mirocana is only left with three advisors: internal finances, ICO process and legal. No tech or algo-trading advisors at all.