Subject: File No. SR-BatsBZX-2016-30
From: Philip C Chronakis, Esq.
Affiliation: Attorney, Adjunct Professor of Law

March 7, 2017

Hon. Michael S. Piwowar, Acting Chairman
Hon. Kara M. Stein, Commissioner
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Re: File No. SR-BatsBZX-2016-30

Dear Commissioners Piwowar and Stein,

I respectfully submit this letter in support of the Proposed Rule Change to Bats-BZX Rule 14.11(e)(4), and more generally, in support of the Securities and Exchange Commissions consideration of the underlying request to create a publicly traded Exchange Traded Fund for the commodity of Bitcoin.

The SECs upcoming decision represents an opportunity for the United States to pave the road - for millions of American citizens and foreign investors alike – towards safe, regulated, access to the financial and technological benefits of Bitcoin and the Blockchain.

Billions of dollars worldwide have poured into Blockchain development and Bitcoin innovation. Billions more will follow. The Blockchains distributed ledger technology is here to stay. Bitcoin as a store of value (having recently passed the price of gold in each assets base unit) is here to stay.

Thus, the question before the SEC is whether to extend the benefits of these cutting-edge developments – and widen the circle of opportunity – to hundreds of millions of other investors, within the safety of a publicly traded ETF that can become part of a brokerage account or retirement plan.

I respectfully submit that the SEC should approve the proposed rule change so that everyone may have the opportunity to include Bitcoin in their investment portfolios, to whatever degree they feel comfortable, under Wall Streets umbrella, rather than through individual exchanges not overseen by the SEC.

While governmental regulation may offend some of Bitcoins creators, idealism is subordinate to reality. In reality, billions of dollars are flowing into Bitcoin and Blockchain investments and ventures. In reality, more companies accept Bitcoin as a form of payment each month. In reality, Bitcoin ATMs are proliferating throughout the United States.

Denial of the proposed rule will not stop Bitcoins progress, but approval of the proposed rule, and the underlying COIN ETF, will put the SEC in the ideal position to oversee Bitcoins development as an investment asset – and provide fair, broad-based investment opportunities for not only the connected (or technologically savvy) few, but to all Americans who deserve the same chance to benefit from this technological breakthrough
and financial opportunity.

When the SEC approved the first gold ETF, tens of millions of investors had the freedom to direct their savings into this precious metal, without having to mine for gold, or purchase some with no idea of its purity. Unlike gold, Bitcoin and the Blockchain cannot be – and never have been – diluted via other metals and alloys (the basis for President Nixons decision to remove the United States from the gold standard). Unlike bank and corporate
computer servers, the Blockchain has never been hacked or corrupted. But, privately owned Bitcoin exchanges pose some risk to investors, whereas the BATS exchange under the SECs purview is the perfect laboratory in which Bitcoin and the Blockchains development can continue with reliability and security.

The SECs approval of the proposed rule change will protect investors who are already flocking to Bitcoin as a store of value and as a currency. Protection of investors remains one of the SECs central tenets. I respectfully urge you to approve the rule change, so that this inevitable march forward of technological progress can be extended to include
all desirous investors, and remain under the SECs watchful, yet free-market, guidance.

Thank you for your consideration.

Respectfully submitted,

Phil Chronakis
New York, New York