transparency lab / investigations / the treasury playbook
critical financial governance · 6 companies · ~805,000 BTC combined · 12 anomalies

the treasury playbook

→ $62 billion raised. $592 million in operating revenue.

in august 2020, microstrategy purchased $250 million in bitcoin and filed an 8-k calling it "monetary engineering." the stock tripled in six months. five companies followed the same structure: use public market access to raise capital through equity offerings, convertible notes, or zero-interest bonds, then deploy the proceeds into bitcoin. the operating businesses that justify their listings generated a combined $592 million in revenue in their most recent fiscal years. strategy alone has since accumulated 762,099 BTC at a total cost of $57.69 billion. one of the six companies settled a federal fraud investigation, then immediately filed a $500 million offering to buy more bitcoin. this investigation documents the mechanics, the governance structures, and twelve anomalies across all six companies.

6 companies profiled
~805,000 BTC held combined
~$62B capital raised for BTC
12 anomalies documented

the playbook

the template was established in a single 8-k filing. five companies followed it. the rationale language was nearly identical across every announcement.

MicroStrategy 8-K · August 11, 2020 · CIK 1050446
"Bitcoin is digital gold — harder, stronger, faster, and smarter than any money that has preceded it. We find the global acceptance, brand recognition, ecosystem vitality, network dominance, architectural resilience, technical utility, and community ethos of Bitcoin to be persuasive evidence of its superiority as an asset class for those seeking a long-term store of value." — Michael J. Saylor, CEO

the stock was trading at $121 on august 11, 2020. within six months it reached $640. within four years, the company had accumulated over 500,000 BTC using capital raised through equity offerings and convertible notes. the mechanism was simple. a company with public market access used that access to buy an asset the market valued as scarce. every company that followed used nearly word-for-word identical justification.

bitcoin treasury companies
growing adopters
revenue-backed adopter
capital raise mechanisms
flagged structure
the adoption timeline

microstrategy: august 2020. semler scientific: may 2024. metaplanet: april 2024. kulr technology: december 2024. gamestop: march 2025. trump media: 2025. each announcement cited inflation risk, fiat currency debasement, and bitcoin as a store of value. the language did not change between 2020 and 2025.

the numbers

the table below covers each company's most recently disclosed bitcoin position alongside its last full fiscal year of operating results. the BTC/revenue multiple divides bitcoin holdings value by annual operating revenue. entries marked * include unrealized bitcoin appreciation in reported net income.

Company Ticker BTC strategy BTC held BTC value Capital raised (BTC) Annual revenue BTC/Revenue Net income/loss
Strategy MSTR Aug 11, 2020 762,099 $57.69B $57.69B $463.5M 124× $(1.17B)
Metaplanet MTPLF Apr 8, 2024 35,102 ~$2.4B ~$560M $58M 40× ¥6.4B*
Trump Media DJT 2025 ~9,673 $904.4M $2.44B $3.682M 246× $(712.3M)
GameStop GME Mar 25, 2025 4,710 $513M $1.3B $3,823M 0.13× $131.3M‡
Semler Scientific SMLR May 28, 2024 5,048 ~$420M ~$280M $56.3M 7.5× $40.9M*
KULR Technology KULR Dec 4, 2024 1,021 $101M $101M $10.7M 9.4× $(17.5M)
data notes

strategy (MSTR): BTC holdings and $57.69B cost basis as of March 24, 2026, per strategy.com/purchases and 8-K filings. average acquisition cost: $75,694/BTC across 100+ disclosed transactions. the BTC value column reflects total cost basis, not current market value. class A share count expanded from 330M to 10.3B (a 31× increase) in a January 2025 shareholder vote to enable ongoing at-the-market equity issuances that fund BTC purchases.

trump media (DJT): BTC unit count (~9,673) is derived from the $904.4M balance sheet value (Dec 31, 2025) at an approximate price of $93,500/BTC. the company does not separately disclose unit count. see full investigation.

gamestop (GME) : the $131.3M net income figure is driven by interest income on a $4.8B cash pile, not retail operations. retail operating profit: $36.1M. revenue fell 27.5% that same year; the company closed 590 stores.

semler scientific (SMLR): acquired by strive inc. (vivek ramaswamy) in an all-stock deal announced september 22, 2025, closed january 2026. the 5,048 BTC figure reflects holdings at the announcement date, valued at approximately $83,400/BTC. in april 2025, semler agreed to pay $29.75M to the DOJ to resolve a fraud investigation into its QuantaFlo device; it funded the payment via a coinbase loan secured by BTC while simultaneously filing a $500M securities offering to buy more.

* fair value accounting: net income figures marked * for semler scientific and metaplanet include unrealized bitcoin appreciation under ASU 2023-08. ex-BTC, semler earned ~$16M. metaplanet's hotel operations have not recorded an operating profit since 2017.

fiscal years: strategy, kulr, metaplanet = FY Dec 31, 2024. semler = FY Dec 31, 2024 (last standalone year). trump media = FY Dec 31, 2025. gamestop = FY Feb 1, 2025. all BTC figures from most recent company disclosures or strategy.com/purchases (strategy).

the re-rate

the central promise of the playbook is a stock re-rate. announce bitcoin, let the market price the stock as a leveraged bitcoin proxy rather than as an operating business, and raise capital at the new higher price. in most cases, the announcement spike was real. in most cases, it reversed.

Company Announcement Day-of change Outcome
Strategy (MSTR) Aug 11, 2020 +21% +1,600%+ over four years. MSTR was the originator; later adopters found a market that had already begun pricing the playbook.
Semler Scientific (SMLR) May 28, 2024 +43% day-of initial gains reversed. the company's revenue came from a single medical device then under federal fraud investigation. Strive (Ramaswamy) acquired it in January 2026 at a 210% premium to a heavily discounted share price.
Metaplanet (MTPLF) Apr 8, 2024 +19% on first disclosed purchase +1,744% within 12 months of the first bitcoin buy. Japanese retail investors drove the premium; Metaplanet became a proxy for bitcoin exposure in a market with limited crypto ETF access.
KULR Technology (KULR) Dec 4, 2024 +30%, peak $4.80 trading near pre-announcement levels by mid-2025. the re-rate lasted weeks, not months.
GameStop (GME) Mar 25, 2025 +11.7% intraday −25% within 48 hours when the $1.3B convertible offering was priced. down 22% from announcement level by December 2025. the gain erased once the dilution terms were disclosed.
Trump Media (DJT) May 27, 2025 fell on announcement CNBC headline: "DJT shares drop after Trump Media announces bitcoin raise." the market read the $2.5B capital raise as dilution. by August 2025, shares were down 50% year-to-date.
day-of stock change at announcement
+43% → −5%
12-month outcome vs. announcement price
+1,744% → −65%
what the re-rate data shows

the most durable re-rates came in 2020 (MSTR, as the originator) and 2024 (Metaplanet, which offered Japanese investors their first accessible bitcoin proxy). by 2025, the market had already priced the playbook. GameStop's announcement generated less than 48 hours of optimism before the convertible offering terms erased the gain. Trump Media's announcement triggered an immediate decline. raising capital on a bitcoin strategy still works. using it to re-rate the stock no longer does.

the multiple

when bitcoin holdings exceed annual operating revenue by 90× or 246×, the treasury is not a hedge against inflation. the operating business exists to service the capital structure that funds bitcoin purchases. the charts below show the ratio and the scale.

BTC holdings value / annual operating revenue
246× peak
capital raised for BTC vs annual operating revenue (log scale, $M)
57× avg (ex. GME)

governance

bitcoin treasury strategies are not neutral. they concentrate upside for insiders who hold discounted shares or control voting structures, while retail investors fund the treasury through equity dilution and debt subscriptions. four cases with structural asymmetries follow.

Strategy (MSTR)
Michael Saylor, Executive Chairman
Class B shares held 19,616,680
Class B votes 10 per share
Total voting control ~43% of all votes
Saylor shares sold (2021–Apr 2024) ~$399M
Company BTC deployed $29.3B
Source: Strategy DEF 14A · Form 4 filings (CIK 1050446) · insider tracking databases
Trump Media (DJT)
Donald J. Trump, Chairman
Shares held 114,750,000
Voting power 41.1%
Controlled company exemption claimed
BTC unrealized + realized losses, FY2025 $403.2M
FY2025 operating revenue $3.682M
Source: TMTG 10-K FY2025 · DEF 14A · see full investigation at /case/trump-media/
GameStop (GME)
Ryan Cohen, Chairman & CEO
Shares owned 42,082,626
Economic ownership ~9.3%
Cash compensation $0
Shares sold in 2024–2025 zero
Potential equity award (at $100B mkt cap, $10B EBITDA) ~$35B
Source: GME Schedule 13D/A · DEF 14A · GME 10-K FY2024 · CIK 1326380
KULR Technology (KULR)
Michael Mo, CEO & Chairman
Common shares held ~3.1M
Insider group ownership ~17.5%
Series A Preferred Stock issued to Mo (Jan 2025) 270,000 shares
Preferred stock type non-conv. voting only
BTC deployed vs annual revenue 9.4×
Source: KULR 10-K FY2024 · 8-K Jan 2025 (CIK 1698991) · Form 4 filings
Metaplanet: EVO Fund structure

metaplanet funds its bitcoin accumulation through a series of zero-interest yen-denominated bonds issued almost exclusively to EVO FUND, a cayman islands-based hedge fund. each bond series is convertible to equity in metaplanet upon maturity or at EVO's option. the structure allows EVO to acquire metaplanet shares at near-face-value while japanese retail investors on the tokyo stock exchange bear the dilution and the bitcoin price risk. cumulative bond issuances through mid-2025 exceeded ¥86.1 billion (~$560M USD). metaplanet has no sec reporting obligation.

the language gap

every announcement described bitcoin as a store of value. every 10-k risk factor section described it as speculative. each company filed both documents.

Strategy (MSTR) · Aug 11, 2020 vs FY2024 10-K
announcement (8-K, EX-99.1)
"This investment reflects our belief that Bitcoin, as the world's most widely-adopted cryptocurrency, is a dependable store of value and an attractive investment asset with more long-term appreciation potential than holding cash."
MicroStrategy 8-K · August 11, 2020 · CIK 1050446
FY2024 10-K risk factor
"The price of bitcoin is highly volatile and subject to wide fluctuations... We may lose all or substantially all of our investment in bitcoin. The market value of our bitcoin holdings could decrease substantially at any time."
Strategy 10-K · FY ended Dec 31, 2024 · CIK 1050446
Semler Scientific (SMLR) · May 28, 2024 vs FY2024 10-K
announcement (press release / 8-K)
"After studying various alternatives, we decided that holding bitcoin would be the best use of our excess cash... Bitcoin is now a major asset class with more than $1 trillion of market value. We believe it has unique characteristics as a scarce and finite asset that can serve as a reasonable inflation hedge."
Semler Scientific 8-K · May 28, 2024 · CIK 1554859 · Eric Semler, Chairman
FY2024 10-K risk factor
"Bitcoin is a highly speculative asset... The value of our bitcoin holdings is subject to extreme volatility, including significant and sudden decreases in value... We may face significant losses from such volatility."
Semler Scientific 10-K · FY ended Dec 31, 2024 · CIK 1554859
GameStop (GME) · March 25, 2025: announcement vs same-day earnings
investment policy update (8-K, Mar 25, 2025)
"The Board of Directors has approved an update to the Company's Investment Policy to add Bitcoin as a treasury reserve asset... a portion of our cash or future debt and equity issuances may be invested in Bitcoin."
GameStop Corp 8-K · March 25, 2025 · CIK 1326380
same-day earnings disclosure
net sales: $3.823 billion, down $1.45 billion (27.5%) from the prior fiscal year. 590 retail locations closed during the year. hardware revenue fell 30.5%. software revenue fell 31.1%. collectibles revenue fell 8.1%.
GameStop 10-K · FY ended Feb 1, 2025 · filed March 25, 2025 · CIK 1326380
KULR Technology (KULR) · Dec 4, 2024: bitcoin policy announcement vs FY2024 10-K
treasury strategy announcement (8-K, Dec 4, 2024)
"KULR believes that Bitcoin, as the world's most secure decentralized blockchain network, is a reliable store of value and a compelling investment. KULR's Bitcoin Treasury Strategy is to hold Bitcoin as its primary treasury reserve asset on an ongoing basis."
KULR Technology Group 8-K · December 4, 2024 · CIK 1698991
FY2024 10-K risk factor (filed same quarter)
"The price of Bitcoin is highly volatile and subject to wide fluctuations in response to various factors... A significant decline in the price of Bitcoin could have a material adverse effect on our business, financial condition, and results of operations... We may lose some or all of our investment in Bitcoin."
KULR Technology Group 10-K · FY ended Dec 31, 2024 · CIK 1698991

anomalies

01 📊
strategy: 762,099 BTC at $57.69B cost on $463.5M in annual software revenue. a 124× ratio.
Strategy (MSTR) · March 2026
critical
as of march 24, 2026, strategy held 762,099 BTC at a total cost of $57.69 billion, with an average acquisition price of $75,694 per coin. in the week of march 16–22, 2026 alone, the company purchased an additional 1,031 BTC for $76.6 million, funded by at-the-market class A equity sales. its enterprise analytics software business generated $463.5 million in revenue for FY2024. the ratio of total BTC cost to annual operating revenue: 124×. the company rebranded from microstrategy to strategy in february 2025. it has made more than 100 separately disclosed bitcoin purchases since august 2020. its equity market value is driven almost entirely by its bitcoin position, not by software cash flows. in a january 2025 shareholder vote, strategy expanded its authorized class A share count from 330 million to 10.3 billion (a 31× increase) to enable the ongoing at-the-market share sales that fund bitcoin purchases. that authorization dilutes class A shareholders. saylor's class B voting shares (10 votes each) are not diluted by class A issuances. his ~43% voting control is unaffected by the expansion.

source: strategy 10-K FY2024 (CIK 1050446) · strategy.com/purchases · 8-K march 24, 2026
02 ⚠️
trump media: $904M in bitcoin on $3.682M in revenue. a 246× multiple.
Trump Media (DJT) · FY2025
critical
trump media raised $2.44 billion in 2025 through equity offerings and zero-coupon convertible notes, then deployed the proceeds into a $904.4 million bitcoin treasury. annual revenue for FY2025: $3.682 million. the BTC/revenue ratio: 246×. in the first year of the bitcoin strategy, the company recorded $403.2 million in digital asset losses, equal to 109 times its total annual revenue. the company simultaneously launched five NYSE-listed ETFs and proposed a $1 billion investment in cronos tokens (approximately 19% of the total cronos market cap at the time). the sec sent 30 comment letters across four years questioning, among other things, the disclosure quality around the trump license agreement and the absence of quantified platform metrics.

see full investigation: /case/trump-media/ · 678 filings · 4 CIK entities
03 💸
combined: $34B raised for BTC against $592M in operating revenue
all six companies combined · excluding GameStop
critical
across the five non-gamestop companies in this investigation, cumulative capital raised to fund bitcoin purchases totals approximately $32.6 billion (strategy: $29.3B; trump media: $2.44B; metaplanet: ~$560M; semler scientific: $201M; kulr: $101M). their combined annual operating revenue: $592 million. the aggregate capital-to-revenue ratio: 55×. a further $1.3 billion in convertible notes was raised by gamestop, a company with $3.82 billion in annual revenue whose revenue fell 27.5% in the year it adopted the strategy. the total capital deployed across all six: approximately $34 billion. the combined operating revenue of all six: approximately $4.4 billion. gamestop accounts for 87% of that total.
04 🏦
gamestop: $1.3B in convertible notes to buy bitcoin while revenue fell 27.5%
GameStop (GME) · March–May 2025
high
on march 25, 2025, gamestop filed two things simultaneously: an updated investment policy adding bitcoin as a treasury reserve asset, and its fiscal year 2024 10-k reporting a 27.5% year-over-year revenue decline and the closure of 590 retail locations. on march 27, 2025, the company priced a $1.3 billion convertible notes offering due 2030 at a conversion price of $29.85/share. it used the proceeds to purchase 4,710 BTC for approximately $513 million on may 28, 2025. the notes mature in 2030 at face value. if the retail business continues its current trajectory (revenue fell from $9.1 billion in FY2019 to $3.8 billion in FY2024), the company will need to either refinance, convert, or repay $1.3 billion in notes at a time when its core business may be substantially smaller. ryan cohen's proposed $35 billion equity award requires the company to reach $100 billion in market capitalization and $10 billion in cumulative EBITDA to fully vest.

source: gamestop 10-K FY2024 · 8-K march 25, 2025 · convertible notes prospectus · CIK 1326380
05 📉
kulr: 90% of surplus cash into bitcoin. revenue: $10.7M. accumulated deficit: over $100M.
KULR Technology Group (KULR) · December 2024
high
on december 4, 2024, kulr technology group's board approved a policy to allocate up to 90% of surplus cash reserves into bitcoin. at year-end 2024, the company held $29.8 million in cash. annual revenue: $10.7 million. net loss: $17.5 million. accumulated deficit exceeded $100 million. by early 2026, the company had deployed approximately $101 million into 1,021 BTC at an average cost of approximately $108,884/BTC, equal to 9.4 times its annual revenue. the capital came partly from a $20 million coinbase prime credit facility and partly from at-the-market equity issuances, which dilute existing shareholders. in january 2025, the board issued 270,000 shares of non-convertible series a voting preferred stock to ceo michael mo. this structure protects incumbent management against shareholder challenge.

source: kulr 10-K FY2024 · 8-K december 4, 2024 · 8-K january 2025 · CIK 1698991
06 🔗
metaplanet: zero-interest yen bonds, exclusively to a single cayman islands fund
Metaplanet (MTPLF / TSE: 3350) · 2024–2025
high
metaplanet finances its bitcoin accumulation almost exclusively through zero-interest ordinary bonds denominated in japanese yen, subscribed by a single counterparty: EVO FUND, a cayman islands-based hedge fund. as of mid-2025, cumulative bond issuances exceeded ¥86.1 billion (~$560M USD). a single june 2025 tranche totaled ¥31.5 billion (~$210 million). the bonds pay 0% annual interest. they are convertible into metaplanet equity, allowing EVO to acquire shares at near-face-value of the bond principal. for japanese retail investors trading metaplanet on the tokyo stock exchange, this structure creates a recurring dilution mechanism: evo receives shares at a price determined by the bond conversion terms, while retail investors hold shares whose value depends entirely on the BTC price. metaplanet has no sec reporting obligation and does not file 20-F or 6-K documents with the sec.

source: metaplanet TSE disclosures · metaplanet FY2024 earnings presentation · verified press releases
07 ↗️
saylor sold ~$399M in MSTR shares while deploying $29.3B of company capital into bitcoin
Strategy / Michael Saylor · 2021–April 2024
high
michael saylor, who described bitcoin as "digital gold" and established the treasury playbook in august 2020, sold approximately $399 million of MSTR shares between 2021 and april 2024 across approximately 101 form 4 transactions. the most recent disclosed sale: april 25, 2024 (100 shares). over the same period, the company he leads as executive chairman deployed $29.3 billion of corporate capital into bitcoin through equity dilution and convertible debt. saylor currently holds 6,000 shares of class A common stock and 19,616,680 shares of class B common stock (10 votes per share), giving him approximately 43% of total voting power. the class A share count has been expanded multiple times to fund bitcoin purchases. the authorized share count was increased from 330 million to 10.3 billion in a january 2025 shareholder vote. dilution of class A shareholders funds the treasury. saylor's class B voting position is not diluted by class A issuances.

source: strategy form 4 filings (CIK 1050446) · strategy DEF 14A · insider tracking databases
08 🔁
five companies adopted the playbook within 48 months of the original announcement, using nearly identical language
cross-company pattern · 2020–2025
notable
microstrategy's august 2020 8-k described bitcoin as a "dependable store of value" and an "attractive investment asset" with "long-term appreciation potential." semler scientific's may 2024 announcement described bitcoin as "a reliable store of value" and "a reasonable inflation hedge." kulr's december 2024 announcement cited "Bitcoin's potential as a long-term store of value." trump media's 2025 disclosures reference bitcoin as a "store of value." gamestop's march 2025 policy cites bitcoin as a "treasury reserve asset": the same phrase used in saylor's 2020 8-k title. across five companies and five years, the announced rationale did not change. what changed: bitcoin's price reached $100,000+, making the stock re-rate more dramatic and the capital raise terms more attractive. the template was not just copied. the language was copied. the only variable was scale.
09 ⚖️
semler settled a $30M DOJ fraud probe, then immediately filed $500M in new bitcoin offerings
Semler Scientific (SMLR) · April 2025
critical
in april 2025, semler scientific agreed in principle to pay $29.75 million to the Department of Justice to settle a fraud investigation into the marketing of its QuantaFlo peripheral artery disease test. the DOJ alleged that semler misled medicare about the device's clinical accuracy. the investigation had been active since 2017 and involved multiple subpoenas. the device was semler's primary and nearly sole source of operating revenue: $56.3 million annually.

to fund the settlement, the company arranged a loan from coinbase prime, secured by its bitcoin holdings. the same week, the company filed an S-3 registration for a $500 million at-the-market securities offering to raise money to buy more bitcoin. chairman eric semler publicly tweeted "excited to buy more bitcoin" as the settlement was announced. semler had held bitcoin for less than one year at the time. the bitcoin treasury strategy did not protect the company from liability in its operating business. it did, however, provide the collateral to fund the settlement and the fundraising vehicle to raise more capital.

source: DOJ press release april 2025 · semler scientific 8-K april 2025 · S-3 filing (CIK 1554859) · STAT News march 3, 2025
10 🗳️
strategy authorized a 31× increase in class A shares in a single vote. class B holders were not diluted.
Strategy (MSTR) · January 2025
high
in a january 2025 shareholder vote, strategy's shareholders approved expanding the authorized class A common share count from 330 million to 10.3 billion, a 31× increase. the vote passed because saylor's class B shares carry 10 votes each, giving him approximately 43% of all votes despite holding a small fraction of the economic equity. the expanded share authorization exists primarily to enable continuous at-the-market equity issuances used to fund bitcoin purchases.

when new class A shares are sold into the market, existing class A shareholders are diluted. their ownership percentage falls. their share of future earnings and book value shrinks. saylor's class B position is not affected by class A issuances. his voting control is unaffected. the structure means that the mechanism funding the bitcoin treasury (selling class A shares) systematically transfers value from retail investors to the treasury, while the person directing that transfer retains full control and suffers no dilution.

between august 2020 and march 2026, strategy has raised approximately $57.69 billion through this structure. the class A share count has grown substantially. the software business revenue ($463.5M) has been roughly flat. the governance mechanism, not the business, is the engine.

source: strategy DEF 14A 2025 · 8-K january 2025 · strategy.com/purchases · CIK 1050446
11 📉
GameStop stock +11.7% on bitcoin announcement, then −25% within 48 hours when the financing terms landed
GameStop (GME) · March 25–27, 2025
high
on march 25, 2025, gamestop announced it was adding bitcoin as a treasury reserve asset. the stock jumped 11.7% in intraday trading. two days later, on march 27, 2025, gamestop priced a $1.3 billion convertible notes offering at 0% coupon, due 2030, at a conversion price of $29.85/share. the stock fell 25% that day, erasing all gains from the announcement.

by december 2025, gamestop shares were 22% below the pre-announcement closing price. the bitcoin re-rate lasted less than 48 hours. what the market initially priced as a strategic pivot, it quickly repriced as dilution. the convertible notes require the company to repay or convert $1.3 billion in 2030. gamestop's retail revenue has fallen from $9.1 billion in FY2019 to $3.8 billion in FY2024, a 58% decline in five years. at that pace, the company will be smaller and less able to service that debt at maturity.

the announcement also did not disclose board-level bitcoin expertise. gamestop's FY2024 proxy shows no director with a background in digital assets or crypto markets. the investment policy update cited ryan cohen's view that bitcoin was an appropriate treasury reserve asset. cohen proposed a $35 billion equity award for himself contingent on the stock reaching $100 billion market capitalization. the stock was at ~$24 on announcement day.

source: CoinDesk march 27, 2025 · gamestop 8-K march 25, 2025 · gamestop DEF 14A FY2024 · CIK 1326380
12 🔄
Vivek Ramaswamy's Strive acquired Semler Scientific in September 2025. the playbook is now consolidating.
Strive Inc. / Semler Scientific · September 2025
notable
on september 22, 2025, strive inc., the investment firm co-founded by former DOGE head and 2024 republican presidential candidate vivek ramaswamy, announced it would acquire semler scientific in an all-stock deal. the offer valued semler at $90.52 per share, a 210% premium to semler's closing price of $29.18 the prior friday. at the time, semler held 5,048 BTC and strive held 7,750 BTC. the combined entity would hold 12,798 BTC, ranking it among the top 15 corporate bitcoin holders globally.

shareholders approved the merger and it closed in january 2026. semler scientific no longer files independently with the SEC. the playbook established by saylor in august 2020 had, by early 2026, produced a consolidation effect: bitcoin treasury companies with insufficient operational scale absorbed into larger bitcoin holding vehicles. the acquirer (strive) had itself been launched as a pro-bitcoin investment product company. the acquired (semler) was a medical device company that pivoted to bitcoin in 2024. neither operates in the other's original industry. the combined entity is, in effect, a bitcoin holding company incorporated through the shells of a medical device firm and a financial products startup.

source: bloomberg sept 22, 2025 · strive inc. press release · semler scientific 8-K (CIK 1554859) · the block sept 22, 2025

what the filings don't answer

the public record documents what happened. these questions remain open.

Metaplanet · EVO FUND
All of Metaplanet's zero-interest yen bonds have been placed exclusively with a single Cayman Islands fund called EVO FUND. the fund's beneficial owners are not publicly disclosed. who controls EVO FUND, and what return mechanism do they hold on a zero-interest instrument?
Strategy · debt service
Strategy carries $7.7B in convertible debt. if BTC falls 50% from current levels, the company's $57.69B cost-basis holdings would be worth approximately $28B at market against $463.5M in annual software revenue. what is the liquidation or refinancing path, and which creditors bear that loss?
template diffusion
the rationale language across all six adoption announcements is nearly identical. did Saylor, Strategy, or any affiliated entity provide direct guidance to subsequent adopters, or did the template spread entirely through public channels?
SEC disclosure threshold
there is currently no specific SEC rule requiring enhanced disclosure when a company's treasury asset exceeds its annual operating revenue. DJT's bitcoin holdings are 246× its revenue. at what multiple does the reporting obligation change, and who determines that threshold?
GameStop · Cohen award
GameStop's FY2024 proxy includes a proposed $35 billion equity award for Ryan Cohen contingent on the company reaching a $100B market cap and $10B in EBITDA. the stock was at ~$24 on announcement day (market cap ~$11B). was the bitcoin treasury strategy designed in part to support those valuation milestones?

sources

all data sourced from sec edgar filings, company investor relations disclosures, and tokyo stock exchange filings. metaplanet has no sec reporting obligation. its figures derive from its own investor relations presentations and verified press releases.

Strategy (MSTR) · CIK 1050446
10-K FY2024, 10-Q Q1 2025, 8-K August 11, 2020 (EX-99.1), Form 4 filings, DEF 14A. Original bitcoin announcement: accession 0001193125-20-215604.
sec.gov/cgi-bin/browse-edgar · CIK 1050446
Trump Media (DJT) · CIK 1849821
10-K FY2025, 8-K filings (capital raises, ETF launches), Form 4 filings for Trump family. 678 filings across 4 CIK entities documented in full investigation.
full investigation: /case/trump-media/ · 678 filings · 4 entities
GameStop (GME) · CIK 1326380
10-K FY2024 (filed March 25, 2025), 8-K March 25, 2025 (investment policy update), 8-K May 28, 2025 (bitcoin purchase), convertible notes prospectus (April 2025), Schedule 13D/A (Ryan Cohen).
sec.gov/cgi-bin/browse-edgar · CIK 1326380
Semler Scientific (SMLR) · CIK 1554859
10-K FY2024, 8-K May 28, 2024 (EX-99.1 announcement press release), quarterly bitcoin holding updates, 8-K April 2025 (DOJ settlement in principle, $29.75M), S-3 April 2025 ($500M offering). Acquired by Strive Inc. (closed January 2026).
sec.gov/cgi-bin/browse-edgar · CIK 1554859
Strive Inc. / DOJ settlement
Strive acquisition announcement: Bloomberg Sept 22, 2025 · The Block Sept 22, 2025. DOJ QuantaFlo investigation: STAT News March 3, 2025; DOJ press release April 2025; CoinDesk April 15, 2025. Strive BTC holdings at acquisition: 7,749.8 BTC. Combined post-merger: 12,797.9 BTC.
no SEC CIK for Strive at time of merger · verified through press releases and SEC filings of acquired entity
KULR Technology Group (KULR) · CIK 1698991
10-K FY2024, 8-K December 4, 2024 (treasury strategy announcement), 8-K December 26, 2024 (first BTC purchase: 217.18 BTC for $21M), 8-K January 2025 (preferred stock issuance to CEO).
sec.gov/cgi-bin/browse-edgar · CIK 1698991
Metaplanet Inc. (MTPLF / TSE: 3350)
Metaplanet FY2024 earnings presentation (metaplanet.jp/presentation/en/FY2024-Earnings.pdf). X announcement April 8, 2024. Verified bond issuance press releases. No SEC filings. Trades OTC in US under MTPLF.
no sec edgar filings · tokyo stock exchange · metaplanet.jp IR
all figures sourced from primary documents (sec filings, company ir disclosures, tse filings). the trump media data set is documented in full at /case/trump-media/. metaplanet data is sourced from non-sec primary disclosures and should be treated accordingly. BTC unit counts derived from dollar values are approximate and noted as such. this investigation is for informational purposes only and does not constitute investment advice.