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Yep, first use here: #1019472
It's not a nuanced label as the article implies, but a slur for fake L2's that lie about being non-custodial. https://x.com/shocknet_justin/status/1939774027746484579?t=rVBRBHLZC28FyjfxkLeqjA&s=19
Shinobi, the author of the article, is a faithful waterboy for scammers though of course.
Spark and statechains are 100% custodial, naive users simply hoping they don't rug doesn't change that.