Subject: SR-NASDAQ-2025-021: Webform Comments from Anonymous
From: Anonymous
Affiliation:

Mar. 19, 2025

The SEC should not approve the HBAR ETF because Hedera is
NOT truly decentralized. Here are the reasons why:

(1) Too few nodes on Hedera: Currently, there are only 30 nodes (with
a maximum up to 39) on the Hedera network. In comparison, most other
top blockchain protocols have thousands of validator nodes. This makes
Hedera one of the most centralized networks among the top protocol
chains.

(2) Hedera is a permissioned network: On the Hedera network, anyone
who wants to run a node cannot be assigned a validator node. The only
way to be eligible to run a validator node is to be elected as a
governing council member. The Hedera’s governing council elects new
members that can then run a node, and these members typically are
large multi-national companies. Also most of the governing council
members are non-USA companies with 19 out of the 30 being based
outside of the USA.

(3) Hashgraph operates most of the nodes: Although each governing
council member is supposed to manage and operate its own node, most
governing council members do NOT operate its assigned node. In fact,
Hashgraph, which is controlled by the founders of Hedera, operates the
nodes for most of the governing council members, therefore Hashgraph
is in control of most of Hedera’s nodes weakening the argument of
decentralization.