Section 200.2 (n)(1, 5): clarify the role of miners

[dexX7]

Context:

Section 200.2

(l) Transmission means the transfer, by or through a third party, of Virtual Currency from one Person to another Person, including the transfer from the account or storage repository of one Person to the account or storage repository of another Person;

(n) Virtual Currency Business Activity means the conduct of any one of the following types of activities involving New York or a New York Resident:

• (1) receiving Virtual Currency for transmission or transmitting the same;
• (5) controlling, administering, or issuing a Virtual Currency.

The following expresses my interpretation of 200.2 (n)(1):

Virtual Currency Business Activity means (...) receiving Virtual Currency [as a payment] for [providing the service of] transmission or transmitting the same

Since mining is an integral part of Bitcoin and other digital currencies, I think it needs to be clarified, if the above quoted subsections apply to miners which, depending on the interpretation, ...

1. transfer Virtual Currency from one person to another
2. receive a payment for this service in form of transaction fees
3. create or issue new units of Virtual Currency