BITCF First Bitcoin Capital Corporation (PK)

VANCOUVER, BC / ACCESSWIRE / May 5, 2017 / First Bitcoin Capital Corp. (OTC PINK: BITCF):

Hon. Michael S. Piwowar, Acting Chairman
Hon. Kara M. Stein, Commissioner
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

May 4. 2017

Re: File No. SR-BatsBZX-2016-30

Dear Commissioners Piwowar and Stein,

We, First Bitcoin Capital Corp respectfully submit this letter in support of the Proposed Rule Change to Bats-BZX Rule 14.11(e)(4), and more generally, in support of the Securities and Exchange Commission's consideration of the underlying request to create a publicly traded Exchange Traded Fund for the commodity of Bitcoin.

As the leading public company in the Bitcoin space, we would like to present our conclusive research for your kind consideration.

Based on this research, the primary way that the SEC protects the public is through requiring adequate and accurate disclosures. In this regard, it appears that COIN has overwhelmingly met those requirements and the SEC has not raised the adequacy and/or accuracy of the COIN disclosures as an issue. On the other hand, the concern about the lack of regulation is covered thereby giving potential speculators and investors this knowledge to fulfill the logic behind the SEC's adequate and accurate disclosure requirements.

The SEC revealed that it fears the ability (presumably of some billionaire) to manipulate Bitcoin as a commodity, yet that would likely be more difficult to accomplish than the Hunt Brothers achieved in their attempt to monopolize silver.

The significant supply and demand and diversity of market factors driving BTC would easily make such a feat nearly, if not, impossible.

Imagine trying to move in and out of 300 markets worldwide needing to wield hundreds of millions of dollars to have any influence and to what avail? So, say some currency manipulator like Soros tried this, he could just as easily lose his shirt and how long could he sustain such an operation? Apparently, it would be in an effort to buy and sell shares of the EFT named COIN for a profit. If the manipulator were successful in controlling BTC in the markets, there would be no need to utilize the EFT to achieve that goal.

Recent history has already given us a clear view of how COIN would look and trade in a similar entity trading as Global Bitcoin Trust (GBTC) on the OTCQX found at http://www.otcmarkets.com/stock/GBTC/quote where today's price movements on a smaller scale reflected the substantial increases in BTC's rising price and volume.

Consider for example that $959,301,000 worth of BTC has traded in the past 24 hours (at the time of writing this) according to http://coinmarketcap.com/currencies/bitcoin/ and this covers dozens of exchanges around the world trading in at least 300 fiat and cryptocurrencies that charge fees. It does not include those exchanges that are commission free, nor those that have not provided their API to coinmarketcap.com.

Another aspect that makes Bitcoin less susceptible to manipulation is the fact that each transference from wallet to wallet of Bitcoin can be seen on an open public ledger known as a blockchain.

The example of the Hunt Brothers is relevant because worldwide silver daily trading volume is similar in size to Bitcoin, and was mostly an unregulated commodity decades ago- similar to Bitcoin today.

Governments around the world are beginning to regulate trading of Bitcoin, for example, Japan began regulating BTC last month. The New York banking authority began regulating bitcoin exchanges and FINCEN requires registration for Bitcoin exchanges in the USA.

Gemini, a regulated exchange affiliated with COIN through their founders, the Winklevoss Twins, accounts for a very small amount of Bitcoin trading and would not be a good vehicle for manipulation as inexplicably envisioned by the SEC.

Imagine if the conclusion were made that due to the Hunt Brothers attempt to corner the silver market that silver could not be the basis of a commodity based Exchange Traded Fund?

Similar arguments could be made for the EtherIndex Ether Trust first filed in July 2016, seeking to launch an ETF backed by a cache of ethers on the NYSE Arca exchange as well as any other leading altcoins that would enter into an EFT.

Thank you for your kind consideration.

Respectfully submitted,

Simon Rubin, Chairman of the Board
FIRST BITCOIN CAPITAL CORP.

SOURCE: First Bitcoin Capital Corp.

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