Subject: File No. 4-927
From: Ross P Brown

The order does not provide meaningful investor or issuer protection. Its conditions apply only to a capped, experimental on-chain venue. They leave the actual market, where price is set, capital is raised, and investors take risk, largely untouched. A market maker can still short the listed shares on NYSE or Nasdaq, hedge with listed options, and warehouse the obligation through CNS. That inventory can still pressure the stock and raise the issuer’s cost of capital. Nothing in the exemption limits that activity or gives the issuer any new tool against it. Investors on the TSV receive a token that must carry the same legal rights as the listed share and must halt when the primary exchange halts. That is a consistency rule, not a new protection and it does not improve disclosure, reduce short-sale risk, change settlement finality for the main market, or give holders any remedy they lack today on the listed stock. The issuer’s only new right is 30 days’ notice and a veto over third-party tokenization. That is a branding and control concession, not protection of the company’s ability to raise capital or of shareholders from traditional market-maker shorting. The Commission should not describe this relief as investor- or issuer-protective as it is a limited safe harbor from exchange and dealer registration for a parallel AMM venue. The risks that actually affect listed companies and their shareholders remain exactly where they were.