Subject: File No. SR-NYSEArca-2017-139
From: SAM M AHN

August 16, 2018

I left a comment, against the whole idea of bitcoin, at SR-CboeBZX-040 on 08/13/2018. This is in succession to it.

In said comment, I classified money, according to the way of carrying intrinsic value, into three kinds: commodity money, warehouse certificate money and note money. I said that bitcoin is a commodity money.

After writing it, I found an assertion that bitcoin is not a commodity money, but a expense certificate money. The purpose of this writing is to find whether an expense certificate can have intrinsic value and become money.

The idea of expense certificate money originates from Adam Smith, David Ricardo and Karl Marks, who thought the value of something comes from the labor put into it.

Now we see things much brighter, and know that the value of a gold nugget picked up easily in a stream is the same as the value of same-sized gold dug out after expense of ten million dollars. Cost is only a reference to the value. Cost alone cannot establish any value.

Bitcoin's value is recognized by some people who believe it can function as money. But nothing can be a universal money without recognition of its intrinsic value, before considering its money-hood. If bitcoin has to be called an expense certificate generally, I would call it a waste certificate specifically. Some find its value in association with blockchain technology, but blockchain is being used without bitcoin.

While reading bitcoin-related SR proposals, the arguments are focused on Securities Exchange. My two comments including this are focused on Securities. When I read the public comments, many people seem not understanding that the Commission handles both (1) Securities and (2) Exchange of Securities. In this sense, I would like to call this agency Securities and Securities Exchange Commission instead.