Subject: SR-CboeBZX-2023-028: Webform Comments from Travis Kling
From: Travis Kling
Affiliation: Ikigai Asset Management

Aug. 14, 2023

I run a crypto investment fund called Ikigai Asset
Management that was launched in 2018. Before crypto, I spent a decade
in traditional finance, including as a portfolio manager at Point72. I
have traded many billions of dollars of crypto in the last five years.
I have traded on Coinbase, FTX.com, Binance.com, BitMEX and numerous
other crypto exchanges. I give you that background to frame my view as
a domain expert on the matter at hand.

A SSA with Coinbase is not sufficient surveillance to ensure the spot
Bitcoin market is not manipulated. Coinbase only does a small fraction
of total spot Bitcoin volume. The overwhelmingly dominant exchange for
spot Bitcoin volume is Binance.com. Binance's founder Changpeng
Zhao is a criminal with an abhorrent moral compass. He heavily
manipulates the price of Bitcoin for his own purposes. According to
the CFTC's own complaint against Binance, Changpeng controls more
than 300 trading accounts on Binance. HE USES THESE ACCOUNTS TO
MANIPULATE THE SPOT PRICE OF BITCOIN. This has been known by industry
insiders for years.

If a spot Bitcoin ETF is approved while Binance.com maintains its
current level of dominance in crypto trading, the ETF will be exposed
to the manipulations of Changpeng Zhao and this is very bad for all
investors, both retail and institutional alike. The DOJ has the
evidence it needs to bring heavy-handed criminal charges against
Binance and Changpeng. The DOJ can bring these charges and the
dominance of Binance can be significantly diminished, or even better,
Binance can be shut down entirely. This is the best outcome for crypto
market participants. If Binance.com were to be shut down, the
landscape thereafter would likely be such that a SSA with Coinbase
would THEN be sufficient to ensure the effects of market manipulation
were kept to a minimum.

Do not approve a spot Bitcoin ETF right now. You never should have
approved a futures ETF because the futures price is beholden to the
spot price and the spot price has always been, and continues to be,
manipulated by bad actors. If the SEC loses its case against
Grayscale, find another reason to block the spot ETF approval or
rescind the futures ETF approval. Then have the DOJ drop the hammer,
clear out Binance and thereafter approve a spot ETF. This is the
correct order of things to ensure the safety of US investors.

Please email me if you want to talk in more detail. Happy to help
however I can. Thank you for your time.