Subject: s7-02-22: WebForm Comments from Daniel W Primmer
From: Daniel W Primmer
Affiliation: Fraser Farm Co L.L.C

Apr. 19, 2023


April 19, 2023

 To the honorable protectors of our markets,
It is with great urgency that I am compelled to comment on this issue. There is only cryptocurrency that is exempt from being labeled a security and it is by definition Bitcoin. This is because it truly evades the defining hallmarks of a security in that there is no centralized governance to comprise it's structure. While other currencies may claim to be decentralized they all share the same reality, in that, someone is in control of their code and they can be manipulated. Bitcoin truly operates in a decentralized environment, therefore there is no prospect of it being something subject to filings or annual reports as there is no figurehead to do so. Wih Ethereum, dash, dogecoin, and all the rest, this is not the case. I feel the Honorable Mr. Gensler is aware of this fact and is seeking to right a ship where tokenized holdings can be used to keep ledgers unbalanced by using crafty financial slight of hand, akin to a depression era street grifter, that keeps regulators from seeing a
 clear depiction of financial mismanagement. This rule upon its face appears to reconcile that. It is imperative, however, that the SEC recognize the difference between Bitcoin (not a security) and Shtcoins (all other \"crypto\" and in fact securities) I'm sure that the SEC, as prevalent an adjudicator of right action as there is, will want to aid Mr. Gensler in this effort to root out corruption and resolve the tumult that has been levied upon our markets.