The Commission should withdraw the proposed amendments to Rule 3b-16. Decentralized exchanges are NOT equivalent to traditional intermediaries in financial markets. So, it makes no sense to broadly lump Decentralized exchanges in with traditional exchanges as the Proposed Rule amendment would do. Although superficially, Decentralized exchanges may appear to have some attributes similar to traditional markets, with study, one would find that Decentralized exchanges can also have significantly fewer or perhaps even zero intermediary attributes by the use of highly independent software protocols. Decentralized exchanges functioning on auditable blockchains can function with significantly less direct human counterparty features whereas traditional financial markets do not function in such a way whatsoever. The Proposed Rule seeks to utilize a law that does not account for 21century technology to include these software protocols. The proposal should be rejected. The Proposed Rule appears unfairly prejudicial against new entities, developers, and innovators and the retail investor’s freedom of choice and association. It is obvious the current large institutions with traditional exchanges are already more or less compliant with the SEC rules. These large institutions are seeking to gain a foothold in the digital asset realm. Such institutions already have a significant war chest to further their economic advantage and the Proposed Rule amendment forces the innovator to come to a playing field already dominated by large institutions. This forces the “little guy” off of US soil and further stifles innovation stemming from our own shores. Also, as a retail investor already with a significant portion of my assets in traditional markets, why should I not have the option to place some of my assets in a more innovative self-custodial model of software-based asset holding? Why should I not have the right to give such an asset freely to friend or family member via a smart contract? The best models ought to have the ability to compete with each other in a fair manner so retail investors and asset holders have a choice. A move to force decentralized entities to comply with already existing systems is unfair and favors large institutions over the “little-guy” while infringing on the rights of law abiding citizens. At the very least, for these reasons, please reject the proposed amendments to Rule 3b-16. Thank you for your time.