Notice how you sidestepped the question. This reveals a weak point in your argument: that for a transaction to be labeled as "sats," the transaction itself must consist of sats being exchanged. By this logic, you wouldn't classify any custodial wallet-to-custodial wallet transactions as "sats," implying they shouldn't use the term at all. It's a valid stance to take. If that's your belief, I have no issue with it. Just make sure you are consistent in that view.

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No sats are being exchanged in this transaction. Should WOS be using the term sats?