Start Date of 3 year duration is unclear

[paulbarclay]

Section (a)(1) states within three years of the date of the first sale of Tokens.

Section (e) states The relief provided by this section will expire three years from the date the notice of reliance was filed.

These are contradictory. I think the reasonable approach would be 'within 3 years of first sale', as the timeline is already tight, and you have to file the disclosure before the sale (and you're not going to wait until the last minute to do so, because failing to file is bad).