Subject: File No. SR-NASDAQ-2025-018
From: Zachary Spooner
Affiliation:

Apr. 3, 2025

Regarding the HBAR ETF, 


The Hedera Hashgraph public ledger is uniquely positioned as a kind of public utility. Unlike most distributed ledgers, fees are paid in the native token, but are denominated in dollars. This means that companies building on Hedera can use it strictly for the utility of fast, fair and secure transactions, without any participation in or exposure to HBAR price fluctuations. A company may simply estimate their daily transaction costs (in dollars) and purchase the necessary amount of HBAR to cover transaction fees. In this manner, demand for HBAR is not derived from price speculation, but rather from the utility of the network. Additionally, Hedera Hashgraph is a registered LLC in the state of Delaware, opting to remain in the U.S. rather than moving operations to a more crypto-friendly regulatory environment, and has made every effort to engage regulators and comply with (arguably vague) U.S. regulations. The Hedera governing council is composed of many blue-chip companies from a variety of market silos, as well as several top-tier universities from around the globe. It is a challenge to find any cryptocurrency foundations which have made more efforts to legitimize an often fraud-and-scam ridden industry. 


Please take these points into consideration when making your decisions...