Coinbase chief legal officer Paul Grewal and Base founder Jesse Pollak argued that Layer-2 (L2) sequencers constitute infrastructure rather than exchanges.
Their statements contradict the current regulatory stance, considering SEC Commissioner Hester Peirce has previously warned that centralized matching engines may face exchange registration requirements.
Grewal compared Base’s sequencer to Amazon Web Services in a Sept. 22 post, stating that layer-2 blockchains operate as general-purpose infrastructure processing code deterministically.
He argued that L2s “batch all transactions while deferring any formal order interaction/matching rules to an app’s smart contracts and frontend.”
Pollak provided technical details supporting the infrastructure argument, explaining that Base’s sequencer collects user transactions, orders them first-in/first-out, and batches them to Ethereum for settlement.
He emphasized that sequencers determine transaction processing order but do not act as
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