Subject: File No. SR-CboeBZX-2021-051
From: Adam Girts
Affiliation: Law Student, University of Michigan

November 5, 2021

This does not, to my lay eyes, seem resistant to manipulation. The Exchange emphasizes de-centralized nature of bitcoin itself, however as I understand their proposal to be, that is a red herring. They are pegging the value to a collection of independent exchanges, who collectively, would be able to manipulate the bitcoin index by manipulation of their own forums.