Subject: File No. SR-NASDAQ-2025-005
From: Paul Jenkin

To the Securities and Exchange Commission, I am writing to express strong support for the approval of the spot Litecoin (LTC) Exchange-Traded Funds (ETFs) proposed by Canary Capital. Litecoin, as one of the longest-standing and most resilient cryptocurrencies, represents a decentralized network of sound money with unique attributes that warrant its inclusion in regulated investment products like ETFs. Below, I outline key reasons why these ETFs should be approved sooner rather than later, addressing Litecoin’s significance, its operational excellence, and the irrelevance of its market capitalization as a deterrent to approval. 1. Litecoin’s Proven Longevity and Network Reliability Litecoin, launched in 2011 by Charlie Lee, is a proof-of-work cryptocurrency forked from Bitcoin’s codebase, designed to offer faster transaction confirmations and lower fees. It boasts the longest uptime of any blockchain, operating continuously for over 14 years without a single instance of downtime. This unparalleled reliability underscores Litecoin’s robustness and security, making it a trusted digital asset for investors and users worldwide. Approving Litecoin ETFs would provide retail and institutional investors with regulated exposure to a cryptocurrency with a proven track record of stability. 2. Exponentially Growing Network Metrics Litecoin’s on-chain metrics demonstrate significant growth and adoption, reflecting its increasing relevance in the digital asset ecosystem: Transaction Volume: Litecoin processes millions of transactions annually, with daily volumes often surpassing $1 billion, indicating strong user activity. Address Growth: The number of active Litecoin addresses has grown steadily, with over 8 million unique addresses holding LTC as of 2025, signaling widespread adoption. Hashrate and Security: Litecoin’s mining hashrate has reached all-time highs, reflecting a decentralized and secure network resistant to attacks. 3. Litecoin as Sound Money in a Decentralized Network Litecoin embodies the principles of sound money: scarcity, divisibility, portability, and durability. With a fixed supply cap of 84 million LTC, it is inherently deflationary, akin to Bitcoin. Its decentralized network, supported by thousands of miners globally, ensures censorship resistance and permissionless access, aligning with the ethos of financial sovereignty. Litecoin’s classification as a commodity, not a security, by analysts and its regulatory clarity further strengthen its case for ETF approval. The SEC’s acknowledgment of Litecoin’s similarity to Bitcoin in prior filings reinforces its suitability for regulated investment products. 4. Market Capitalization Should Not Deter Approval While Litecoin’s market capitalization, approximately $7.8 billion as of May 2025, is smaller than Bitcoin or Ethereum, this should not be a barrier to ETF approval. Market cap is a snapshot of price and circulating supply, not a measure of a network’s utility, security, or investor interest. Litecoin’s decentralized nature ensures its value lies in its network effects, not centralized control or speculative hype. The success of Bitcoin and Ethereum ETFs, despite their initially modest market caps at launch, demonstrates that investor demand and regulatory safeguards—not market size—drive ETF viability. Litecoin’s liquidity, with daily trading volumes often exceeding $750 million, supports the operational feasibility of ETFs. Approving Litecoin ETFs would democratize access to a fundamentally strong asset, fostering innovation in the U.S. financial markets. 5. Investor Demand and Regulatory Opportunity The filing of several Litecoin ETF applications reflects significant institutional interest, with firms like Canary Capital, CoinShares, and Grayscale recognizing Litecoin’s potential. Public sentiment, as evidenced by Polymarket predictions assigning an 80% approval probability for Litecoin ETFs in 2025, underscores strong investor enthusiasm. Under new SEC leadership, including Chair Paul Atkins, who has expressed openness to digital assets, approving Litecoin ETFs presents an opportunity to align regulatory policy with market innovation. Delaying approval risks stifling competition and pushing investment to unregulated offshore markets. 6. Addressing Potential Concerns The SEC has sought feedback on risks such as market manipulation and fraud. Litecoin’s transparent blockchain, high liquidity, and established market infrastructure (e.g., trading on major exchanges like Coinbase and Binance) mitigate these concerns. Its proof-of-work consensus, similar to Bitcoin’s, ensures robust security against manipulation. Additionally, the proposed ETFs’ structure, backed by custodians and regulated exchanges like Nasdaq and NYSE Arca, provides sufficient investor safeguards. Conclusion Litecoin’s unmatched uptime, growing adoption, and alignment with sound money principles make it an ideal candidate for spot ETFs. Its relatively small market capitalization reflects its early-stage potential, not a limitation, and should not deter approval given its liquidity and investor demand. Approving the Canary Capital, CoinShares, and Grayscale Litecoin ETFs would expand investor choice, enhance market transparency, and position the U.S. as a leader in crypto innovation. I urge the SEC to act swiftly to approve these applications, enabling regulated access to one of the most resilient cryptocurrencies in existence. Thank you for considering this comment. Sincerely, Paul Jenkin