7. In the Principal Investment Strategy section, please add disclosure regarding the relative sizes (or market capitalizations) of the bitcoin and ether markets as of a recent date similar to other series’ sector concentration disclosures as of a certain date.
Registrant added disclosure regarding the relative sizes (or market capitalization) of the bitcoin and ether markets as of a recent date.
8. In the second paragraph of the Principal Investment Strategy section, the Fund discloses that it may invest in investment companies. Please revise “may” to “will” in light of the AFFE line in the fee table.
Registrant revised the sentence to replace “may” with “intends to” in light of the AFFE line in the fee table.
9. In the fourth paragraph of the Principal Investment Strategy section where Registrant has included a cross-reference to a later discussion in the “Overview of the Fund” section regarding bitcoin, ether, bitcoin futures and ether futures, please also note in the cross-reference that there is a discussion of the bitcoin and ethereum blockchains.
Registrant revised the cross-reference to state that there is also a discussion of bitcoin and ethereum blockchains.
10. At the end of the Principal Investment Strategy section, where the disclosure discusses CFTC regulation, please remove all references to swaps.
Registrant revised the disclosure to remove references to swaps.
Principal Investment Risks
11. In the new bitcoin and ether risks sections, confirm “bitcoin blockchain” is capitalized throughout if it is a defined term.
Registrant respectfully declines to capitalize “bitcoin blockchain” as it is not a defined term in the Fund’s disclosure.
12. The newly added disclosure under “Ether Risk” discusses risks associated with ether being considered a security under state or federal law. Please expand the risk to capture the nuance of ether being a security or being offered and sold as a security.
Registrant added additional risk disclosure to the “Ether Risk” in the summary section to capture the nuance of ether being a security or being offered and sold as a security.
13. In the “Ether and Ethereum Network” sub-section of the “Overview of the Fund” section, please distinguish more clearly between ether and ethereum (i.e., ethereum is the blockchain and ether is the native crypto asset of the ethereum blockchain).
Registrant added disclosure distinguishing ether and Ethereum, including stating that Ethereum is the blockchain and ether is the native crypto asset on the Ethereum blockchain.
14. The “Ether and Ethereum Network” sub-section of the “Overview of the Fund” section refers to platforms on which ether trades as “digital asset exchanges.” The Staff reiterates comment 41 that such venues are not, and should not be referred to as “exchanges.”
Registrant revised this disclosure to change the reference from “exchanges” to “trading platforms.”
15. In the disclosure describing digital asset trading platforms and their “largely unregulated” status, please clarify that such status may be attributable to a possible lack of regulatory compliance and cross reference the disclosure regarding the Constituent Exchanges described under the “Bitcoin Futures and Ether Futures” sub-section of the “Overview of the Fund” section.
Registrant has revised this disclosure to clarify that such status may be attributable to a possible lack of regulatory compliance and to cross reference the disclosure regarding the Constituent Exchanges described under the “Bitcoin Futures and Ether Futures” sub-section of the “Overview of the Fund” section.
16. In the “Smart Contracts and Development on the Ethereum Network” subsection of the “Overview of the Fund” section, Registrant discusses potential uses for the network, including the importance of smart contract-based applications for, among others, the so-called “DeFi” platforms and non-fungible tokens (“NFTs”). Please disclose the risks related to the regulation of these applications and other activities occurring on the ethereum blockchain, including that operators of DeFi applications and issuers of NFTs have been subject to enforcement actions by the SEC and CFTC.
Registrant has revised the disclosure to disclose the risks related to the regulation of these applications and other activities occurring on the ethereum blockchain, including that operators of DeFi applications and issuers of NFTs have been subject to enforcement actions by the SEC and CFTC.
17. In the first bullet point under the “Creation of New Ether” subsection of the “Overview of the Fund” section, please clarify that proceeds of the initial distribution of 60 million ether through a crowd sale were used to pay for the development of the ethereum protocol.
Registrant added disclosure to clarify that the proceeds of the initial distribution of 60 million ether through a crowd sale were used to pay for the development of the Ethereum network protocol.
Statement of Additional Information Comments:
