Subject: File No. SR-NASDAQ-2025-018
From: Joe Lange
Affiliation:

Apr. 3, 2025

Dear Commissioners,
I am writing to voice my unequivocal support for the listing of a Hedera (HBAR) exchange-traded fund (ETF) on NASDAQ. I believe such approval would provide important benefits to U.S. market participants and promote the SEC’s core objectives of fair, orderly, and efficient markets. Below are the key points I hope you will consider:
1. Straightforward, Regulated Access to Digital Assets
An HBAR ETF would grant people a familiar, regulated channel for accessing the Hedera network’s native token without the complexities of managing private keys or interacting with unregulated platforms. This structure aligns with existing financial safeguards, providing a level of transparency and oversight that reduces the likelihood of mismanagement or misconduct.
2. Strong Governance and Progressive Decentralization
Hedera’s governance model is designed to balance decentralization, efficiency, and security. The Hedera Governing Council—comprised of up to 39 global organizations across various sectors—ensures no single entity can monopolize network decision-making. Equally important, Hedera has a clear roadmap to scale its network, adding more publicly accessible nodes over time. This thoughtful approach to decentralization helps maintain network reliability while expanding participation.
3. Transparent and Fair Token Distribution
HBAR’s tokenomics are grounded in transparency and fairness. The total supply of 50 billion HBAR is pre-minted, with allocations overseen by the Governing Council and ecosystem foundations. A structured vesting schedule mitigates sudden market fluctuations and fosters long-term commitments to the network’s success. These practices reflect Hedera’s commitment to responsible growth and clarity regarding token allocation.
4. Market Readiness and Broader Ecosystem Benefits
The growing market demand and positive reception of Hedera signal its readiness for an ETF. By creating an avenue for people to access HBAR through a regulated product, the SEC would encourage deeper liquidity, better price discovery, and more robust market infrastructure. This paves the way for broader adoption of digital asset technologies in a manner consistent with strong oversight and consumer protection.
5. Addressing Negative Perspectives
Some in the broader cryptocurrency sphere have voiced concerns about new projects receiving regulatory approval, but these critiques often arise from fears of competition rather than objective assessments of public benefit. Hedera’s emphasis on rigorous governance, open communication, and incremental decentralization distinguishes it within a rapidly evolving sector. Approving an HBAR ETF would signal that well-structured digital asset initiatives have a legitimate path under a reputable regulatory framework.
Conclusion
By listing an HBAR ETF on NASDAQ, the Commission would bolster consumer protections within the digital asset space while enabling secure and convenient participation in a promising technology. Hedera’s governance model, transparent token distribution, and market maturity make it an excellent candidate for an ETF. I respectfully urge the SEC to approve this filing and help set a precedent for responsible, forward-thinking integration of digital assets into U.S. markets.
Thank you for your consideration.
Sincerely,
Joe
[NOTE: When publishing my comment publicly, please only include my first name. Thank you!]