Subject: File No. SR-CboeBZX-2018-040
From: Benjamin M Noble

September 21, 2018

I'd like to use this opportunity to express my support for the VanEck SolidX Bitcoin ETF.

I've worked in emerging technology for many years. I've watched the slow transition from on-premises networks to cloud systems. In the face of progress there is always uncertainty and doubt. However, the evolution of global blockchain policy and the entrance of major enterprises should be an obvious indication of technological progress.

IBM, Salesforce, Microsoft, Oracle and many other enterprise software providers have staffed blockchain teams to herald in the next evolution of connectivity. That speaks volumes to the economic potential of blockchain.

Blockchain is controversial because it is revolutionary. It is rearchitecting exchange. It is changing our concept of trust in a time where trust is dwindling. The public wants open and transparent transactions conducted free of interference and potential corruption.

Disruption is seldom met with total acceptance.

The claims of manipulation and fraud in Bitcoin are particularly concerning for those who would like to see serious advancements in policy. People in these comments have claimed that Tether and exchanges have colluded or facilitated collusion to manipulate markets.

The truth is that volatility is a consequence of trade psychology. And most people don't want to take accountability for bad trade decisions. It is easy when someone loses money to point the finger at "evildoers." Where does personal accountability come into play?

Today, the market is subject to arbitrage due to lower volume and adoption. Limited access makes it easier for individuals to place large buy or sell orders and trigger frenzied reactions. This is a consequence of restricting market adoption and not something that needs policing but rather a guiding hand. More diversity of buyers and sellers will dilute the impact of market entries and exits. Consequently, exchanges and wallets associated with agitating markets would be easier to flag when trying to manipulate at global scale (that is the benefit of a transparent ledger). If manipulation does exist, it is my opinion that it does not exist at a scale of consequence to most investors and should be fairly easy to mitigate. At the moment, the market behaves like high-risk stocks, and amateur investors will always find a scapegoat.

Please, allow this ETF to facilitate the entry of more mature money. It will facilitate growth that ushers in stability through broader price agreements. Then, it can act as "digital gold" and a true store of value.