In accordance with the Securities Exchange Act of 1934, the Commission has the responsibility to ensure that approved ETFs meet standards for market transparency, align with the public interest, and comply with listing requirements that protect investors. Based on historical data and regulatory findings, I urge the SEC to reject the proposal on the following grounds: Market Transparency Issues The SEC has consistently emphasized the need for reliable pricing, liquidity, and valuation mechanisms in ETFs. However, Litecoin's market has been subject to manipulation, raising serious concerns about its price integrity. Notably, in CFTC Docket No. 21-03, Coinbase admitted to engaging in wash trading on Litecoin pairs, a practice that artificially inflates trading volume and distorts price discovery. This documented case of manipulation highlights the lack of transparency in Litecoin markets and undermines confidence in its ability to support a fair and efficient ETF product. Failure to Align with Public Interest The approval of an LTC ETF must align with the SEC’s mandate to protect investors and promote fair and orderly markets. Given Litecoin’s history of manipulated trading activity, the introduction of an ETF could mislead retail investors into believing the asset operates within a well-regulated framework. Unlike Bitcoin, which now benefits from deeper institutional oversight and market surveillance agreements, Litecoin lacks significant regulatory controls, increasing the risk of fraud. Approving an LTC ETF under these conditions would expose investors to heightened market manipulation risks without sufficient safeguards. Failure to Meet Listing Standards SEC precedent has shown that ETF approvals require exchanges to maintain robust surveillance-sharing agreements to monitor and mitigate fraudulent activity. However, the markets where Litecoin is primarily traded do not meet these requirements. The absence of meaningful surveillance-sharing agreements means there is no effective mechanism to prevent manipulation of LTC prices, making it impossible for any ETF tracking Litecoin to comply with the necessary listing standards. Given the CFTC’s enforcement action against Coinbase, which found direct evidence of market manipulation in LTC trading, it is clear that the Litecoin market does not possess the regulatory safeguards required for an ETF to operate in a fair and orderly manner.