Subject: File No. SR-NYSE-2023-09
From: Carter

This proposal is unworkable on it's face. As a statistically trained individual, let me tell you. you cannot create a new class of assets that exist only as a statistical representation. Such an object would be undefinable as it rests on a fixed definition of the contributing factors, accurate measurement, and consistent formulas. As such, "Natural Assets – A statistical representation..." creates an unworkable problem in this proposal on it's face. There is no definite value of these assets. Secondly, this rule fails to open up a dictionary. A "natural" process occurs without human intervention, as such these process cannot be said to be under human control. While there may be sellable rights and value associated with the results of these processes, ownership doesn't exist for them. They can improve or collapse entirely without human input, any value they may present is ephemeral until a transfer occurs between humans of a more definite product of the process. If I spread out some flour mixed with water and wait, I may get moldy flour or I may get a natural starter. That outcome without further human intervention is entirely dependent on natural processes. The result may have no value or a great deal of value at all. Like Shrodinger's cat, until you reach a result it's an entirely hypothetical construct. This is gambling in the highest, and no human has a description of all the variables. This proposal can only result in fraud and abuse. Do not allow it to more forward.