Chris Fontes: Cannabis is Already Legal - Hemp vs Cannabis

Chris Fontes: Cannabis is Already Legal - Hemp vs Cannabis

Bryan Fields: What's up guys, welcome back to another episode of The Dime. I'm Bryan Fields, and with me as always is Kellan Finney. This week we've got a very special guest, Chris Fontes, CEO at High Spirits Beverage. Chris, thanks for taking the time. How are you doing today? Chris Fontes: I'm doing great, thanks for having me on the show. I've been looking forward to this for a long time, so appreciate the opportunity. Bryan Fields: How are we, Kellan? How are you doing? Kellan Finney: I'm doing really well, really excited to talk to Chris. I think we're going to cover a ton of topics today, and it's just nice to have a West Coaster back on, you know what I mean? I think Chris is in Denver, so there's a lot of West Coast loyalty. How are you, Bryan? Bryan Fields: Yes, yes. Kellan, you're right. Chris, we had to have an allegiance to the East or West Coast — which one do you choose? Chris Fontes: West Coast. Bryan Fields: There she is. All right, well I don't want to waste too much time on the West Coast, we've got a lot there, so we've got to get to some of these hemp topics today. Chris, before we dive in, can you give a little background about yourself and how you got into the cannabis space? Chris Fontes: Yeah, oh god, good question. I was in the legacy market when I was a teenager, and that was really me cutting my teeth into the space, understanding the plant, understanding the use cases, people's consumption profiles, etc. I looked at it more like a business than a hobby even at 15. I had a child young, at 21, and realized — this was at a time when you'd still go to jail for a very long time for this stuff, and you can still go to jail for it in a lot of states. I'm not ignorant to that. I grew up where there was nowhere legal, it was all highly illegal, and after having a kid at 21 I decided I'm really passionate about this plant but not passionate enough to make my kid grow up without a father. So I bounced out of it and ended up pursuing a career in programming — I'd been programming since I was about eight years old, really ahead of the curve on that — and made a lucrative career out of it that led me into general business operations, strategy, entrepreneurship type roles. I launched a couple companies with minimal success, had a software agency I was running for a bit, and one of my clients had entered the hemp space — this is 2018, pre-Farm Bill. They said, look, buying CBD isolate right now is like rolling the dice, Russian roulette — you might get a truckload of powdered sugar, or you might get what you bought, or it might be loaded with hexane and other crap you don't want. People are getting screwed left and right, and we want to create a marketplace where the product you purchase actually shows up because the marketplace guarantees it. As my agency was going through discovery with this group, we determined they didn't actually want to run the company and hadn't thought through the software well enough to have a full business model, and one thing led to the next and I ended up running that company and building it from scratch. I got really excited about the opportunity to enter cannabis, even though it was through industrial hemp and CBD at the time, and got to really understand the space. In 2018 the Farm Bill was signed in December, and as we were reading drafts of it coming up we wanted to make sure the marketplace was in compliance — if you're in Florida selling crude and someone in Colorado wants to buy it, what licenses do those states require for that transaction to happen, and can you even do that legally? Doing that deep dive gave me an opportunity to understand the industry from a legislative standpoint unlike a lot of people in the space at the time. So I recognized the 3% delta-9 advantage right away and did some quick napkin math and said, holy crap, you can make edibles with THC from hemp. But the business model I was responsible for at the time had nothing to do with CPG, and no one was getting high off hemp yet, and I didn't want to be the first guy to do that, even though I saw the opportunity early on. Fast forward through a couple pivots — no one jumps into the cannabis space and the first job they get is the one they have 15 years later, that's just not how it works in our environment. So a couple pivots later we were selling cured, top-shelf type-3 cannabis for inhalation, running a marketplace where you'd know exactly which farm it came from, with our own COAs, good bag appeal, properly cured — high CBD, low THC. While running that company, Project HempFlow, customers started hitting us up for delta-8 and delta-8-sprayed flower. I already knew about delta-8 through the labs I was connected to, and I talked to some chemist friends and decided this isn't for me — no one's consumed delta-8 in tangible quantities like we have delta-9, there are impurities in the conversion process ending up in the product, and I didn't know if the conversion process would be deemed legal in the future. Too risky, too unknown. So we decided not to purchase or resell any sprayed delta-8 flower, but I thought, well, the cat's out of the bag now on getting high from hemp with delta-8 — maybe it's time to talk about delta-9. So I finally secured a legal opinion and had a friend who was a gummy manufacturer do a test run of full-spectrum distillate, 10 milligram THC delta-9 gummies. They tested fine, consistency was okay, a little hempy for a 10-milligram gummy, but it worked, and I thought, this is a thing. Then I talked to USPS and asked, can I mail this, am I going to get in trouble? They looked it over and said nope, you're at 0.2%, this is a full-spectrum product, you can mail this all day, we'll add you to our whitelist so you don't get seized. So we did that — we launched a company called Trojan Horse Cannabis, the first intentionally delta-9 hemp product on the market, and through that we really started to see what you've probably talked about on your podcast before — the red-versus-blue-state legalization strategy. We kicked that off in a big way and helped the industry understand it — we plowed the fields, taught other companies how to do it, explained to distributors how it worked. Competitors literally called me and said, tell me how you're doing this so I can do it too, and instead of keeping it a secret I actually got the information out there. Looking back now, the 3% thing isn't rocket science — once you get it you're like, how did anyone not understand this before — but it was a really heavy lift to get people's brains to wrap around the concept initially. Bryan Fields: Can you explain that for anyone unfamiliar, and let them understand the differences? Chris Fontes: Yeah, absolutely. In 2018 the Farm Bill was signed into law, which included the Hemp Act of 2018. The Hemp Act did two primary things relevant to this conversation. Number one, it created a new definition called hemp. Hemp is just a legal definition — it's not botanical, not scientific in any way, it's a legal term. They could have called it clown weed and it would have been fine, because it has no relevance other than legislation. The definition of hemp is cannabis that happens to be 3% delta-9 by dry weight or less — if you have less than 0.3% THC in the plant, it's no longer called marijuana, it's called hemp. Number two, they changed the Controlled Substances Act under the definition of marijuana to say cannabis sativa L and all of its derivatives, etc., are completely illegal, schedule one, except for hemp as defined in the Agricultural Marketing Act of 1946. So they essentially said these types of cannabis plants with this little amount of THC are no longer controlled substances — not schedule three, not schedule four, not pharmaceutical-only, just not on the schedule anymore, period. The THC from this plant is essentially legal. Bryan Fields: It's delta-9 THC, not THCA, correct? Chris Fontes: Actually, THCA is also legal from the Farm Bill. The definition very clearly says the level of delta-9 is the differentiator between hemp and marijuana, and it doesn't matter if it's the acid or the neutral form. Bryan Fields: And just to add one more level — the difference between THC and THCA for those unfamiliar? Chris Fontes: THCA is what the plant actually makes — it's delta-9 THCA, the A is acid, a carboxyl-like group tied to the molecule. THCA converts to delta-9 through a process called decarboxylation. Most people do this unintentionally, not knowing they're doing it, when you light your joint, put flame to your bowl, your dab, whatever — that heat changes the THCA in your product to delta-9 on the fly, so you're inhaling delta-9. THCA has no impairing effects — you could take 30% THCA flower with no delta-9 in it, eat three pounds of it, and feel nothing, aside from some medical benefits, which is a whole separate topic, but no impairing effects or psychoactivity. Delta-9 the plant does not make — it degrades from THCA through heat or oxidization, time, these sorts of things — so delta-9 is inherently very low in the plant, even in the high-THCA varietals you see in dispensaries. Your 30% flower is probably really 30% THCA and 1% delta-9. THCA was not part of the definition of hemp, and it doesn't matter how a product got here or what licensing structure was used — if you possess something today, a court of law proving it's hemp or marijuana comes down to the delta-9 level. Delta-9 is the only metric that matters. Bryan Fields: And the reason they did that was to protect the farmers, correct — because it's inherent that when you grow hemp you'll have a little bit of these compounds present? Chris Fontes: Yes. Until recently there haven't been any varietals with actually 0% THC — it's been impossible. There are some genetics out there now bioengineered to completely knock out that latent THCA expression. THCA is converted down the chain from CBGA, the mother molecule that creates all the different compounds — CBDA, CBCA, all those A's. There's a primary metabolic pathway that creates the majority of CBGA into THCA, and some cultivars have knocked that pathway out — but you still get a little from latent, secondary metabolic pathways, sort of a byproduct. Now they've figured out how to make varietals that avoid that too. I haven't seen the plants or COAs myself, but I've read a lot about it. Now, total THC comes into play because of the USDA rule. People forget that when the legislation directed USDA to build a cultivation program, USDA was told to create testing methods that use post-decarboxylation or other similarly reliable methods. For a long time THCA wasn't being discussed in the hemp space, and people forget total THC wasn't invented until the final rule came out, well after legislation was approved. USDA took the term "post-decarboxylation" and interpreted it to mean the product has to be decarbed and then under 0.3% delta-9. That's a regulatory interpretation, not law. You could easily argue another similarly reliable method to determine delta-9 percentage is HPLC, which separates THCA from delta-9, rather than combining it all together. But people think THCA matters on a finished good because USDA implemented total THC — what they fail to understand is USDA only manages the plant. As soon as it's cut down, USDA says we're not in charge of this anymore, and anything they say beyond the plant being chopped is irrelevant. Bryan Fields: On that note, people think this is going to be fixed in the next Farm Bill — that they'll change the definition of hemp to say post-decarb or total THC. Do you think that'll happen? Chris Fontes: I would be absolutely shocked if this happened, and this isn't just my opinion — I'm heavily involved in multiple trade associations, I've actually been requested through a trade association to write a bill for the USDA for the next Farm Bill, and we've heard from multiple people, not just me, that the definition is not going to get touched in this Farm Bill, not with a ten-foot pole. We're dealing with insurrection, government corruption, trying to get federal funding passed so the government doesn't shut down, going through House Speakers like they're a Hot Pocket — you get a new one every day. They're not focused on touching hemp, and what they don't want to do is make anything worse or more complicated. Since they don't have the energy to really understand hemp, cannabis, and where this is all going to make smart choices, they've decided not to touch it at all, so it doesn't get worse — it may not get better, but it won't get worse, and they're not prepared to handle the consequences of changes. So I'd be shocked if there's a definition change in the Farm Bill, and on top of that, I don't think we're going to get a Farm Bill this year — probably late next year at the earliest. So we'll be in the situation we're in for a while — FDA isn't going to step in, DEA has no ability to step in, TTB would be a great option but unless directed legislatively, they won't touch it either. For people who don't understand: total THC is a number for the plant, not a finished good — there's no number for the finished good other than 3% delta-9, which is also arguably not accurate, but in practice everyone's going by that. We have essentially national cannabis legalization as long as you fit in some really narrow guidelines, which isn't all that different from every state marijuana program in existence — you have legal marijuana as long as you fit within the guidelines of that regulatory program. How is adult use in Kentucky, where you get your 10 milligram edible because it's 0.3% from hemp, any different than adult use in Colorado where you go to a dispensary, just because the plant percentage it came from is different? I don't understand how people consider one not a legal pathway or good progress for cannabis in general. Kellan Finney: What does the Health and Human Services rescheduling ruling suggest, and does it impact any of this? Chris Fontes: Yes, but not in the ways most people think. I have an interesting perspective here — I'm generally anti-schedule-three. I think this reclassification is bad for the industry. Bryan Fields: Could you expand on why you think it's bad? Chris Fontes: I think it's a case of hanging something shiny in front of you that makes you think it's really good. Schedule one or schedule two products are the requirement for the 280E tax provision — if you sell a schedule one or schedule two substance, the IRS code 280E says you're not allowed to deduct operating expenses, only cost of goods, so you can end up owing more tax than you made in profit. It's crippling the industry. People think once marijuana goes to schedule three, they won't be subject to 280E anymore and can operate like a real business — that's true, sort of, but here's why I think it's a problem: schedule three requires a prescription, it's a pharmaceutical product. You can't name a schedule three product that isn't mandated by pharmaceutical companies and run through that channel. To date, big pharma has stayed clear of marijuana, other than synthetics like Marinol and Epidiolex, because it's schedule one, which means even pharma has to do significant smoke and mirrors to get a synthetic cannabis product to market. When it goes schedule three, it's going to be a lot easier for them — that fits their SOP. Research is good for everybody, but it also opens pharma up to research more easily, and that research really benefits financially the entity doing it, because they get the patent and can sue other people who try to make the same thing. My fear is that schedule three lands, 280E opens up, everyone thinks this is the best thing that ever happened to cannabis, the industry grows bigger over the next three years, and pharma works in the background to figure out how to get a product to market under this category. Once they understand it, they'll do acquisitions — buying the biggest companies in the space, the ones with the largest target market and most researched product development. As soon as they have financial stake and can show damages, it becomes a RICO class-action lawsuit against every state allowing schedule three products to be sold without following proper (pharmaceutical) guidelines. What is a federal judge going to do, what would the Supreme Court rule, if pharma says "I'm following regulations, these other people are not, and the states are protecting them"? They're going to rule as the law states, not as people wish, and pharma will win — and when they do, states will start shutting down their programs and it'll all be owned by pharma. Bryan Fields: We could spend 45 minutes on that alone, but I want to focus on hemp — you're basically saying regulators opened up the cannabis industry and most people didn't recognize the floodgates had opened. To clarify, people today can order products online — like beverages — shipped to their house, consume them, and get high, correct? Chris Fontes: Correct. To tie in quickly — hemp is not marijuana, it's literally excluded from the CSA, which means if marijuana goes schedule three, unless there's legislative change putting hemp back into that classification, hemp is not schedule three. So you'll have this pharma-marijuana situation, and hemp will say, cool, you still want to get high through the mail, we can still do that — hemp will become the national adult-use recreational market because it's accessible without going through pharma, clear of pharma's talons. So yes, it's legal now, it's unregulated, which is not good for consumers or business — we need regulations — but it's legal, not criminal, to possess these products. Some states have tried to make it criminal and had their asses handed to them; other states are winning that fight. I do believe states should have the right to say you can't do this in our state, but I think it's time we get off the "terrifying devil's lettuce" stigma, because this isn't hurting anyone the way people think. Hemp is accessible now — at least ingestibles, which is pretty black and white, and we need regulations to make these products safe, but stopping it now is shortsighted. I was at a marijuana trade association conference in Washington State, on a panel invited so a room full of marijuana operators could "roast" me and make me prove why hemp should exist. A lot of the questions were about how it's already hard enough to exist as a marijuana company, and now they're fighting online mail order — how is that fair? I asked them: do you support interstate commerce of marijuana? Everyone said yes. I said, how are you going to protect against interstate commerce of marijuana if you can't protect against hemp — it's the same problem under a different name. If we all want marijuana truly normalized, true normalization means on your way home you stop for gas and pick up a thing of edibles from the gas station along with your Cheetos and a beer. Kellan Finney: Do hemp companies and marijuana companies operate by the same rules and regulations — financial, advertising, licensing fees? Chris Fontes: Completely different. Very few states have made any sort of uniformity here. Kellan Finney: Do you think that's fair? Maybe if both parties operated under the same rules, marijuana operators would feel it's more equitable. Chris Fontes: The basis of your statement is totally true, it's not fair, and I don't think marijuana companies should be regulated as hard as they are — they should be more regulated in some ways and way less in others. But I say it's not fair tongue-in-cheek, because no one is restricting a marijuana company from opening a hemp company — it's not restrictive to do so. It is very restrictive to get into the marijuana space; if you want to operate in Washington, Oregon, or Nevada, you need a lot of financial backing. I run a reasonably successful hemp company, I'm a social equity approved applicant with an approved application in Colorado, and I still can't afford to open a marijuana company here — nor would I, because they're all going out of business. To say it's not fair only holds if you concede you have to stay in marijuana and can't move to hemp, but there's no restriction on moving to hemp, and we're seeing more CPG companies do this — Cookies, Kiva, Coca-Cola even — realizing, I'm an idiot if I don't ship edibles through the mail. It's an economics thing too — there are no canopy limits on hemp, someone can grow 5,000 acres, farm it with a tractor, convert it, and the finished raw ingredient is drastically cheaper than from a marijuana operator. There's just no way to compete economically. Kellan Finney: Why do you think there isn't more of a push for marijuana companies to do that right now? Chris Fontes: Two things. One, sunk cost fallacy is very heavy in the marijuana space — people think, I've already paid X into this, I can't abandon it now, but that's false thinking, because what matters is where you're going, not where you've been. Two, there's a weird pride or ego about "doing things the right way," as if any marijuana regulations are objectively the right way — they all suck, and operators will say out of one side of their mouth we're doing it right, and out of the other that regulations are unsustainable and we're all going out of business. It's stigma and sunk cost fallacy, and eventually enough pain erodes that resistance. Kellan Finney: If the big MSOs — Trulieve, Curaleaf, Cresco, GTI — all decided to turn from cannabis to hemp, would that influence your perspective, or is it still fair game either way? Chris Fontes: To each their own, it's their option to choose, and they're choosing not to. I think they're dumb for not engaging in the hemp space. I don't personally want them to, because I don't like their influence on how they run cannabis, but that doesn't mean it's a bad move for them — I think it's a really good move, and if they and their investors were savvy, they'd move that direction. Bryan Fields: I listened to a podcast with Boris Jordan where he talked about the biggest challenge for him going forward being natural versus synthetic ingredients and securing product. Can you elaborate on whether that's part of why tier-one companies are hesitant to enter the space? Chris Fontes: I think it's a false narrative. I don't think synthesis really bothers them — I think they use it as an argument piece to win their side of the debate. Can you buy CBN products in marijuana dispensaries today? Yes — and where do you think they're getting that CBN from? Conversion, all synthetic. Same with CBC, a popular new cannabinoid in dispensaries — all synthetic. So to say synthesis is bad while selling synthetic CBN and CBC products is hypocritical. Also, marijuana regulatory systems don't have SOPs or standards for conversions, so to say hemp conversions are unregulated — well, so are theirs. I think some people in the marijuana space believe the narrative because they don't understand where their own CBN or CBC comes from either. But it doesn't have to be synthetic — it can absolutely be natural. We were the first company to use natural delta-9, and we've only ever used natural D9. I'm more comfortable extracting something from the plant the way it's been done for hundreds of years, something humans have actually been consuming, not a synthetic version. If a marijuana company really wanted to avoid synthetics, they could buy natural D9 — it's more expensive and a bit harder, but not impossible. People say the market doesn't have enough biomass, but that's just supply and demand — as demand grows, price rises, which incentivizes farmers to plant more biomass. In fact, I'll go further: all distillate consumed ten years from now will come from hemp. You can get more THC per acre from a grain crop stacked densely than from a high-THC type-one cannabis plant, purely by volume, even at a lower percentage. Big grain companies doing 100,000 acres are already making money off the grain — the THC from that biomass is essentially a byproduct they'd otherwise throw away. Once one big company realizes they can build extraction and distillation on-site, you get enormous volumes of cheap distillate as an afterthought of a much larger grain economy. Craft cannabis will still matter — no one wants a concentrate made from 5% THC grain varietals, it won't have the terpene profile or flavonoids people love — so that's where dispensaries are headed: higher-dosage, curated craft product, like a cigar shop versus buying a cigar at 7-Eleven. Kellan Finney: I completely agree — all form factors besides high-end inhalables will likely be hemp-derived; it makes economic sense. You can't plant 100,000 acres of marijuana right now, but you can with hemp tomorrow. A lot of companies crystallizing CBD end up with THCA as a byproduct they have to report and pay to store, so finding a channel for it is even more motivating since it's otherwise a waste product. And you also get the fiber and grain for building materials and renewable textiles, which was the original motivation behind the Hemp Act and the early-2010s pilot programs. Chris Fontes: Absolutely. The fiber and grain side of the plant is going to eclipse the cannabinoid side by volume by an insane amount once it gets off the ground — you could give every person in the US 100 milligrams a day and it still wouldn't compare to the revenue from fiber. So budget brands would be silly to look at hemp as a problem — it's their future whether they want it to be or not. High-quality inhalables will always have a market, but if you're a budget brand, hemp is where you're headed. Kellan Finney: A lot of markets also allow you to sell hemp-derived cannabinoids into the regulated cannabis market, right? Chris Fontes: Oh yeah — great example, the Utah medical program launched with product on the market before flower had even been grown. Some markets quietly import from places like California and pretend they're not, but Utah is a conservative market that didn't want to do that, so instead they imported CBD from the hemp space and converted it — the entire medical program ran on converted delta-9 for the first two years. People on Reddit say "I don't buy that cheap hemp stuff, I get mine from such-and-such in Salt Lake City," not realizing it's the same product at ten times the price. A lot of programs allow the import of hemp material and synthesize D9 from CBD inside the marijuana program, and somehow that's okay, but doing it outside the program is dangerous — I don't understand it. Marketing, baby. Bryan Fields: I want your perspective on Minnesota specifically for beverages — where are they found, what's the main ingredient, and what should a consumer expect and look for? Chris Fontes: That's tricky, because consumers don't have enough access to the right information to properly discern what's good for them, which is unfortunate — that's why we need regulations. No one checks the COA on their vanilla extract or on GNC supplements, all of which are often synthetic, because we don't want to, and if you're unregulated you're not releasing that information anyway. Minnesota's regulatory structure is exactly what other states should adopt — higher-milligram products in dispensaries, lower-milligram products available publicly anywhere alcohol is sold. If you consume a public serving and it's a bit too much, you have a bad time, not a hospital visit — that's the right dosage to keep public. I'm not comfortable with 1,000 milligrams per serving at 7-Eleven, but those higher-dose products should still be available to adults through dispensaries. When the industry consolidates — what I call the Great Consolidation — we'll just have cannabis, no more distinction between hemp and marijuana, but you'll still have high-dose and low-dose, and low-dose should be available everywhere alcohol is sold, with high-dose relegated to specialty stores. Minnesota is plowing the fields on this, though I think their caps are too low across the board — 5 milligrams per serving publicly is too low, should be 10, and 10 milligrams per serving in dispensaries is too low too, should be 100. A high-frequency, high-tolerance consumer paying $20 for 100 milligrams sounds perfect — that's how you fix the black market, which persists because rec dosage isn't large enough. Kellan Finney: Do you think it's an educational and experience curve that regulators need to go through to get comfortable with higher doses? Chris Fontes: It's time, comfort, and stigma. Regulators hear "1,000 milligrams" and think people are going to die — they're not, it's still cannabis. This is an extreme example, but 50 years from now, when people grow up with cannabis at 7-Eleven as normal, those future legislators won't be scared of a 1,000 milligram container. We should treat the impairing effects of THC the same as alcohol, because it's actually safer than alcohol, so the rules should be less restrictive, not more. And you don't get rid of the black market by restricting businesses — you get rid of it by letting businesses succeed and build products consumers actually want. Kellan Finney: There are so many layers of challenge here — fear, lack of knowledge, lack of research — all stacking up as obstacles for businesses trying to navigate, not just follow, regulation, while also educating consumers. Chris Fontes: Right, and it's similar to consumers buying off THC percentage in dispensaries — a horrible purchase decision, since you're never guaranteed the best quality product that way. You could get more impaired from 12% THC flower than 25%, depending on terpenes, flavonoids, minor cannabinoids, and curing. Because research has been suppressed so long, we lack good consumer data. Back in the day you got flower from your plug with no idea of the percentage, but you could tell you liked one better than another. It'll take a long time for that education — that percentage doesn't determine quality — to saturate the market, though connoisseurs buying craft cannabis will eventually get there. Bryan Fields: Do you think this could be addressed through regulation — like removing the requirement for a hard percentage number on a COA and instead classifying flower into ranges or categories? Chris Fontes: Right, like nobody buys wine because it's 14% versus 13.5% alcohol — that's never the deciding factor, it's about better-tasting products and other qualities. I've heard states propose banning cultivars above a certain THC percentage — like 18% — which doesn't save anybody, it just limits your available gene pool and pushes people back to the black market. What was actually proposed as a good idea in some places is to stop showing raw percentage and instead show a grading system — low, medium, high, super high — because those percentage numbers are essentially meaningless anyway; you're sampling one part of a batch and it's not representative of the whole. Lab shopping is a huge problem right now too — if you can convince a lab to inflate your THC percentage, you'll outsell your competitors. Kellan Finney: The challenge is scale — if a new, fearful consumer picks a product based on a low THC percentage and still ends up too high, having a panic attack, going to the hospital, or suing — how do we protect a new consumer while still moving away from percentage-based labeling? Chris Fontes: How have we systemically prevented kids just turning of age from drinking too much and getting sick their first year? We restrict by age, and beyond that, you make adult decisions — most people didn't ease into alcohol, they overdid it and learned to back off. We never solved that problem in alcohol after 100-plus years of legal access, so what makes us think we'll solve it immediately in cannabis, and why do we assume we have to before allowing access? THC percentage isn't solving the problem people think it's solving — it's compounding it. Kellan Finney: I agree, and I think ranges help because they reduce the incentive to buy purely on percentage and push people to look at terpene profile, bag appeal, minor cannabinoids, and other factors. Even low-THC type-three cultivars can get people high if they're not used to it — you build tolerance and often graduate to higher doses over time, and that's okay. We just need a system to indicate where a product falls on the spectrum, similar to knowing a Bud Light versus a Mike's Hard Lemonade will hit you differently. Chris Fontes: People are going to consume too much and have a bad time occasionally, and that's fine — the good news is you can't die from cannabis overconsumption the way you can from alcohol poisoning. Worst case with cannabis, you overconsume, maybe get a panic attack, feel nauseous, but the next day you're mostly fine, maybe some brain fog, whereas with alcohol you can feel like garbage and the older you get, the longer that lasts. And in terms of safety, someone extremely high behind the wheel is objectively less dangerous than someone extremely drunk, even though I'm not endorsing high driving publicly — high people become more cautious and less confident, driving slower, while drunk people become more confident and reckless. I even pitched this at a gentleman's club conference in Vegas trying to get THC beverages normalized in that scene — when people are drunk they get obstinate, confident, handsy, and aggressive, which plays out badly in that environment, whereas someone too high tends to become apologetic and compliant when confronted by security. Bryan Fields: Let's do a quick prediction — which states do you see following Minnesota's model, before and after the Great Consolidation? Chris Fontes: After the Great Consolidation, most states. Before consolidation, any state that has a properly regulated hemp program and then gets adult-use marijuana after the fact will follow Minnesota's footsteps, because the hemp industry already has a foothold and can defend itself. In mature markets like California, Nevada, Oregon, Washington, the large incumbent marijuana industry is very protected and will fight hard against hemp encroachment. But hemp companies never lobby against marijuana normalization — marijuana always lobbies against hemp. So when hemp comes first, marijuana follows and you get a Minnesota; when marijuana comes first and hemp tries to get a foothold, you get a Colorado or an Oregon every time. Kellan Finney: I'll go with the Bible Belt — states like Tennessee, Alabama, and Texas already have robust hemp programs built around CBD and fiber, and businesses there are realizing they need to diversify, so I think you'll see more Minnesota-style rollouts there before the Great Consolidation. Bryan Fields: We're in agreement, but since podcast rules require me to take a different stance, I'll say a state with a mature market takes the legal approach of "the Farm Bill says what it says, come get me," triggering a cascade of legal events, similar to what we've seen elsewhere in cannabis, forcing bigger conversations in DC. If I had to pick one, New York seems like the perfect candidate to challenge this from a legal standpoint, given the current chaos in that market. Bryan Fields: Chris, for our listeners who want to get in touch or buy some products from you, where can they find you? Chris Fontes: TrojanHorseCannabis.com — we'll be launching a High Spirits-focused website shortly, but right now TrojanHorseCannabis.com has all of our Trojan Horse and High Spirits products. If you want to follow me for industry commentary, I'm on LinkedIn as Chris Fontes, F-O-N-T-E-S — happy to post stuff that pisses people off or gets them excited on LinkedIn all the time, so follow me there too. Bryan Fields: Awesome, thanks for taking the time, this was a lot of fun. We'll link it all up in the show notes. Chris Fontes: Sounds great, thanks everyone.