Subject: SR-ISE-2025-12: Webform Comments from Randy T.
From: Randy T.
Affiliation:

Jun. 19, 2025

The IBIT option is the primary source of Paper Bitcoin in
the system. Its being used to manipulate pricing not create a fair
market. 

As of today, June 19th 2025 The total open interest for IBIT options,
per Fintel, is 4,037,838 contracts (2,562,493 calls + 1,475,345 puts),
representing approximately 403,783,800 IBIT shares or 228,108.5
Bitcoins worth of exposure. To match the exposure of 1 Bitcoin,
approximately 18 options contracts (call or put) are needed, covering
1,800 IBIT shares.

228,108 Bitcoins would need to be delivered if all contracts were
exercised. No exchange has anywhere near this amount readily available
and according to Coinglass this number would represent nearly 10 pct
of ALL Bitcoin on all exchanges. 

The market makers simply cannot deliver the BTC, the shares are not
bought immediately with Options to create neutrality. 

How is this a free and fair market?