Subject: File No. SR-CboeBZX-2018-040
From: Zachary Ebling
Affiliation: CEO of Booyah Education Co., Ltd.

July 12, 2018

As a citizen of the United States who is witnessing the impact bitcoin and blockchain technology are having globally as I run a multinational startup, I want to urge the SEC to strongly consider the CBOE's Bitcoin ETF proposal.

Echoing a statement made previously by Tim Hong:
"...currently the top 0.67% addresses own 87.19% of the Bitcoins in circulation. A large percentage of these being extremely wealthy individuals or exchanges. This means that the current derivatives trading assessment for market supply / demand is highly volatile due to the small sample size of Bitcoin ownership. Therefore, additional financial investment entities are needed (such as ETFs) to combine institutional investors interests and decentralize Bitcoin ownership while promoting financial innovation in the U.S."

One of the greatest destabilizing factors in the entire cryptocurrency market is the volatility of Bitcoin, which as Tim Hong correctly pointed out is largely due to the centralized ownership of the asset class. The CBOE's Bitcoin ETF could cause an immediate shift in ownership percentage away from the hands of a few and into the portfolios of American institutional and retail investors. Providing a familiar on-ramp to Bitcoin ownership through an ETF will allow increased participation in one of the world's greatest technological innovations and also provide a safer platform for individuals to hold their assets (as opposed to a centralized cryptocurrency trading exchange that is highly vulnerable to bad actors).

Thank you for your time and consideration.