Subject: File No. SR-NYSEArca-2021-90
From: David Golumbia
Affiliation:

Apr. 18, 2022

Dear SEC, 



My name is David Golumbia. I am an academic researcher, professor at Virginia Commonwealth University, and the author of The Politics of Bitcoin: Software as Right-Wing Extremism, one of the first academic books about cryptocurrency. 



I strongly encourage you not to convert the Grayscale Bitcoin Trust (GBTC) to a Spot ETF. 



You are being inundated by comments made by those with vested interests in the perpetuation of the multilevel marketing/Ponzi scheme that characterizes the entire cryptocurrency space. Many of those comments are being coordinated over social media and via websites such as this one run by Grayscale itself: https://grayscale.com/comment/. 



You have every reason to reject this application. As you and other regulators have noted repeatedly, Bitcoin trading is almost entirely constituted by market manipulation of various sorts, and depends on that market manipulation to keep cash flowing into the system. 



The reason Grayscale wants this Spot ETF is clear: they like all the other market manipulators in the crypto space need a constant inflow of real dollars to prop up their manipulation, so that they can continue to dump their tokens into the hands of ever more unsuspecting consumers. That they are obviously engaged in selling their own tokens for a profit while bullying others into buying at the same time is only one of many tactics they use that are illegal in well-ordered markets. 



David Golumbia