Subject: SR-NASDAQ-2025-005 LTC ETF
From: Raphael Devonas
Affiliation:

May 7, 2025

To whom it may concern, 


I invite those considering the approval of any ETF involving Litecoin to observe not only the similarity of Litecoin to cryptocurrencies that have already been approved for ETFs (Bitcoin and Ethereum), but to note its superiority as a store of value to both BTC and ETH. 


Litecoin is consistently the #1 currency used for payments on many crypto payment platforms, including Bitpay. The reason for this is that, contrary to Bitcoin and Ethereum, Litecoin has much faster wallet-to-wallet transaction speeds, and the fees are a fraction of the cost as compared to BTC and ETH. And all of this with zero down time in the 13 years since its launch. The vast majority of crypto networks, including Ethereum and especially Solana and Ripple (XRP), have frequent downtime and are plagued by inferior technology and fundamentals, not to mention highly concerning conflicts of interest by founders. 


Litecoin matches BTC in maturity and public trust. A truly decentralized currency based on proof of work, it enjoys an extremely high level of security that rivals Bitcoin. 77% of Litecoin holders have held for more than one year. In this sense, Litecoin is superior to all other cryptocurrencies. 


In weighing all cryptocurrencies against core metrics, whether it be longevity, reliability, security, efficiency, or low transaction costs, Litecoin is clearly superior to all contenders. Any reasons that could possibly justify the approval of Bitcoin and Ethereum for ETFs are matched or bested in Litecoin. 


Please forgive a slight digression if you would, so that I might address a related, deeply concerning matter at hand: I strongly caution against the approval of ETFs for centralized endeavors such as Ripple, which are one founder rugpull away from being the Enron of cryptocurrencies. The SEC should take steps to protect consumers from the deeply centralized product that is XRP. Ripple is a financial catastrophe -not unlike FTX- just waiting to happen. 


Approving strong, stable, time-tested investments for ETFs while rejecting projects plagued by insecurity and liability that reflect the antithesis of Satoshi’s white paper will provide the market with much needed clarity when it comes to not only cryptocurrencies, but the investment landscape as a whole. Investors should see the SEC selecting for utility, reliability and stability while at the same time rejecting products that fail to meet those high standards. 



I believe the approval of a Litecoin ETF strengthens the image of the SEC as a rational and trustworthy institution. 


Thank you for your consideration, 


Raphael Devonas 
US Citizen & Utah Resident 
Litecoin holder and user since 2017