Subject: File No. NYSEArca-2021-90
From: Adam Pierce
Affiliation:

May. 08, 2022

Dear Sir or Ma'am: 


I write to recommend against permitting a Bitcoin ETF or permitting other cryptocurrency products and derivatives. 


Bitcoin is a fictional asset. This alone is obviously disqualifying. 


Purchasing a Bitcoin does not confer an ownership benefit to any particular amount of computing equipment, electricity, or anything else. 


What kind of asset is Bitcoin? 


Bitcoin lacks the features of a functional currency, namely face value and redemption mechanism. Bitcoin lacks physical form to be a commodity or specie. Bitcoin lacks dividend or ownership rights to be an equity. Bitcoin lacks coupon or principal to be a bond. If owning a certain amount of Bitcoin constitutes intellectual property, then intellectual property of what? And with what enforcement rights against infringement? 


Thank you for your attention, 
Adam Pierce 
Dallas Texas