I am writing to provide comments on the proposed rule change to list and trade shares of the Canary Litecoin ETF under Nasdaq Rule 5711(d). This proposed ETF meets regulatory standards through its structured safeguards and compliance framework: 1. Surveillance-Sharing Agreement: Nasdaq’s existing surveillance-sharing agreement with Coinbase Derivatives via the Intermarket Surveillance Group (ISG) is a crucial mechanism. It facilitates the cross-market sharing of trade data, allowing the SEC and market participants to detect unusual patterns and investigate potential manipulation in the underlying Litecoin spot and futures markets. 2. Qualified Custodians: The use of BitGo Trust Company and Coinbase Custody Trust Company as custodians introduces robust security measures, including regulatory oversight under state trust laws, third-party audits, SOC 2 compliance, and insurance coverage. These entities are well-equipped to mitigate risks associated with digital asset storage and handling. 3. Transparent Pricing Mechanism: The ETF’s methodology will rely on established pricing sources using volume-weighted average price (VWAP) calculations or other verifiable benchmarks, which further reduces susceptibility to price manipulation. 4. Proven Market Integrity: Litecoin has a long-standing record of operational stability, high liquidity across reputable exchanges, and broad global distribution - characteristics that minimize the risk of centralized influence or price manipulation. 5. Investor Protections and Disclosures: The proposed ETF will be subject to the same disclosure requirements as other commodity-based ETPs, providing regular reporting and risk disclosures to investors to ensure informed decision-making. The proposed structure satisfies the requirements under Section 6(b)(5) of the Exchange Act by promoting a fair and orderly market, protecting investors, and guarding against fraudulent and manipulative acts. I respectfully urge the Commission to recognize the adequacy of these safeguards and allow the rule change to move forward. Sincerely, Omied Sadeghi