I think he's just saying to

-- make a pool of N shares allocated to "technical founders".  Call this the
Technical Founders Pool

-- allocate M options on these shares to each technical founder, but with a
vesting condition that includes the condition that only N of the options
will ever be vested all total

This doesn't solve the tax problem though.

The closest *decent* way to do what you want to do is to contract  options
> upfront with modifying conditions and qualifications based on  future
> performance.

Do you believe that you could successfully do that?  Would you be willing
to
write up an initial shot at it?

        Mark


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