Subject: File No. SR-NASDAQ-2025-013
From: Edgar

The proposed approval of a Litecoin (LTC) ETF poses significant risks due to the highly concentrated distribution of Litecoin ownership and its susceptibility to market manipulation. As of 2024, data reveals that the top 100 Litecoin addresses hold approximately 39% of the total supply, with the top 10 controlling over 15%. Many of these wallets are believed to be controlled by a small group of entities, including exchanges and private investors, which makes the asset highly centralized. Such an uneven distribution creates an environment where a handful of major holders, or "whales," can easily influence the price of Litecoin through coordinated buying or selling activity, leading to significant volatility. This concentration undermines the stability and integrity necessary for a publicly traded fund, which could harm retail investors who may not understand the risks of an asset prone to manipulation. In 2024, Litecoin exhibited patterns characteristic of a "pump and dump" scheme. Prices often surged dramatically before halving events or major announcements, followed by rapid declines driven by large sell-offs from top holders. Retail investors, lured by promises of substantial returns, were often left holding the asset at significant losses once prices deflated. The speculative nature of Litecoin's market, combined with its limited utility compared to other cryptocurrencies, makes it an unsuitable candidate for an ETF, which is meant to provide stable, diversified, and regulated exposure to financial markets. Approving a Litecoin ETF would effectively legitimize a volatile and manipulable asset, potentially leading to significant losses for investors and further damaging confidence in the broader cryptocurrency ecosystem. For these reasons, the SEC should strongly reconsider allowing a Litecoin ETF at this time.