Subject: File No. SR-NYSEArca-2017-06
From: Jeffrey Wilcke
Affiliation: Ethereum Foundation

February 8, 2017

There are major ethical concerns and conflicts of interest around Digital Currency Group (DCG), the parent company of the Bitcoin Investment Trust, and their media subsidiary Coindesk.

DCG operates funds that can have a market-moving impact on the digital currency industry while simultaneously operating one of the largest media organizations in the industry, which can be used to exploit investors.

For example, Grayscale, a subsidiary of DCG, operates an ethereum classic fund Ethereum Classic Investment Trust, a barely recognized alt-coin thats illegally infringing on a trademark of the Ethereum Foundation. Yet the currency has been written about more than 88 times on Coindesk.com, and DCG has become the most prominent and public supporter and investor in the token.

This represents a clear conflict of interest giving DCG the ability to "pump-and-dump" worthless assets by offering publicity and easy-access to unsophisticated investors. DCG should be required to divest its ownership and control of this market-manipulating subsidiary before making a DCG controlled investment vehicle available to the public.