May 6, 2025
Vladimir Sochilin Moscow, Russian Federation 6 May 2025 Secretary Securities and Exchange Commission 100 F Street NE Washington, DC 20549‑1090 Re: SR‑NASDAQ‑2025‑005 – Comment on Canary Capital Spot Litecoin ETF Dear Secretary: I write in strong support of SR‑NASDAQ‑2025‑005, which would permit the Nasdaq Stock Market to list and trade shares of the Canary Litecoin ETF. In my view, the proposal fully satisfies Section 6(b)(5) of the Securities Exchange Act of 1934 because Litecoin (LTC) functions as a commodity‑type asset, is resistant to fraud and manipulation, and has proved itself a reliable store of value over more than a decade of continuous operation. 1. Litecoin is a bona‑fide commodity The Commodity Futures Trading Commission has repeatedly classified Litecoin as a digital commodity, identical in legal status to Bitcoin and Ether (see CFTC v. McAfee, 2021). Like Bitcoin, Litecoin is secured by Proof‑of‑Work mining and lacks any central issuer, profit expectation, or contractual claim—features that distinguish commodities from securities under Howey. Major U.S. trading venues already list regulated LTC derivatives (e.g., the CME Group’s Litecoin futures, launched May 2021), underscoring regulatory recognition of LTC as a commodity. 2. Proven resistance to fraud, hacking, and network disruption Since its genesis block in October 2011, the Litecoin network has maintained > 99.99 % uptime with no protocol‑level hacks or rollbacks. The hashing algorithm (Scrypt) and large decentralized miner set create a computational cost that deters 51 % attacks; network hashrate now exceeds 1 PHash/s. Security audits by Electric Coin Company (2022) and the Litecoin Foundation (2023) found no critical vulnerabilities outstanding. 3. Deep, transparent, and liquid markets Average daily spot volume across the top 10 regulated exchanges exceeded US $800 million in Q1 2025, according to Kaiko. LTC markets exhibit low concentration—no single venue accounts for more than 15 % of global volume—reducing manipulation risk. Public on‑chain data (Glassnode) show > 5 million unique wallets holding LTC and an average daily on‑chain transfer value above US $300 million. 4. Parity with recently approved BTC and ETH spot ETFs The Commission’s approval of spot Bitcoin and Ether ETFs (January 2024; December 2024) hinged on surveillance‑sharing agreements and demonstrable market efficiency. The Canary ETF proposal offers the same surveillance‑sharing mechanism with the Nasdaq and major LTC trading platforms. Historical 90‑day correlation of LTC with BTC is 0.72 (Kaiko), implying that market surveillance tools effective for BTC ETFs will be equally effective for LTC. 5. Investor protection and public interest Approving a spot Litecoin ETF will: Broaden investor access to a long‑standing commodity asset within regulated brokerage accounts. Lower custody risk by eliminating the need for retail investors to self‑secure private keys. Enhance market transparency through daily ETF disclosure requirements and regulated market making. For these reasons, I respectfully urge the Commission to approve SR‑NASDAQ‑2025‑005 without further delay. Litecoin’s commodity characteristics, robust security record, and substantial market maturity meet—indeed, exceed—the standards the Commission has already applied to other digital‑asset ETFs. Thank you for considering my views. Sincerely, Vladimir