Subject: File No. SR-CboeBZX-2025-013
From: Hayden Davis

Current State of Solana: Primary Use Case: The main use case of Solana currently appears to be the launch and trading of memecoins, which often involve high levels of speculation, insider trading, and rug pulls. Market Manipulation: The ecosystem has seen significant issues with market manipulation, as evidenced by Hayden Davis's confessions about his involvement in sniping tokens at launch for LIBRA and MELANIA, both Solana-based memecoins. Regulatory and Clarity Issues: Lack of Futures Market: There's currently no futures market for Solana, which is typically a sign of a less mature or less regulated asset in financial markets. Tokenomics and Securities: The early tokenomics of Solana, along with its presales, have not been clearly defined under securities law, leaving questions about whether these should be treated as securities unresolved. Onchain Analytics: There's a notable absence of comprehensive on-chain analytics tools for Solana, which could help in providing transparency and oversight needed for financial products like ETFs. Ethical and Legal Concerns: Insider Trading: Davis's admissions highlight a broader issue of insider trading within the Solana memecoin space, where those with early access or launch team involvement can significantly influence market outcomes. Market Stability: His claim of stabilizing the market is contentious, as the practice of sniping tokens at launch can lead to manipulation more than stabilization. Implications for ETF Approval: Given these factors—rampant speculation, market manipulation, regulatory ambiguities, and lack of transparency tools—an argument can be made that approving a Solana ETF might be premature or ill-advised. ETFs generally require a level of market maturity, regulatory clarity, and investor protection mechanisms that seem to be lacking in the current Solana ecosystem. This situation underscores a need for more robust regulatory frameworks around cryptocurrencies, especially for those like Solana where memecoins and their associated risks are predominant. The discussion around a Solana ETF would likely need to address these issues head-on before moving forward.