Notice2025-04152

Self-Regulatory Organizations; NYSE Arca, Inc.; Notice of Filing of Proposed Rule Change To List and Trade Shares of the Bitwise Dogecoin ETF Under NYSE Arca Rule 8.201-E (Commodity-Based Trust Shares)

Primary source

Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.

Published
March 17, 2025

Issuing agencies

Securities and Exchange Commission

Full Text

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<title>Federal Register, Volume 90 Issue 50 (Monday, March 17, 2025)</title>
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[Federal Register Volume 90, Number 50 (Monday, March 17, 2025)]
[Notices]
[Pages 12429-12438]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-04152]


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SECURITIES AND EXCHANGE COMMISSION

[Release No. 34-102570; File No. SR-NYSEARCA-2025-19]


Self-Regulatory Organizations; NYSE Arca, Inc.; Notice of Filing 
of Proposed Rule Change To List and Trade Shares of the Bitwise 
Dogecoin ETF Under NYSE Arca Rule 8.201-E (Commodity-Based Trust 
Shares)

March 11, 2025.
    Pursuant to Section 19(b)(1) \1\ of the Securities Exchange Act of 
1934 (``Act'') \2\ and Rule 19b-4 thereunder,\3\ notice is hereby given 
that, on March 3, 2025, NYSE Arca, Inc. (``NYSE Arca'' or ``Exchange'') 
filed with the Securities and Exchange Commission (``Commission'') the 
proposed rule change as described in Items I, II, and III below, which 
Items have been prepared by the self-regulatory organization. The 
Commission is publishing this notice to solicit comments on the 
proposed rule change from interested persons.
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    \1\ 15 U.S.C. 78s(b)(1).
    \2\ 15 U.S.C. 78a.
    \3\ 17 CFR 240.19b-4.
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I. Self-Regulatory Organization's Statement of the Terms of Substance 
of the Proposed Rule Change

    The Exchange proposes to list and trade shares of the Bitwise 
Dogecoin ETF (the ``Trust'') under NYSE Arca Rule 8.201-E (Commodity-
Based Trust Shares). The proposed rule change is available on the 
Exchange's website at <a href="http://www.nyse.com">www.nyse.com</a>, at the principal office of the 
Exchange, and at the Commission's Public Reference Room.

II. Self-Regulatory Organization's Statement of the Purpose of, and 
Statutory Basis for, the Proposed Rule Change

    In its filing with the Commission, the self-regulatory organization 
included statements concerning the purpose of, and basis for, the 
proposed rule change and discussed any comments it received on the 
proposed rule change. The text of those statements may be examined at 
the places specified in Item IV below. The Exchange has prepared 
summaries, set forth in sections A, B, and C below, of the most 
significant parts of such statements.

A. Self-Regulatory Organization's Statement of the Purpose of, and the 
Statutory Basis for, the Proposed Rule Change

1. Purpose
    The Exchange proposes to list and trade shares (``Shares'') of the 
Trust \4\ pursuant to NYSE Arca Rule 8.201-E, which governs the listing 
and trading of Commodity Based Trust Shares.\5\
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    \4\ The Trust is a Delaware statutory trust. On January 28, 
2025, the Trust filed with the Commission an initial registration 
statement (the ``Registration Statement'') on Form S-1 under the 
Securities Act of 1933 (15 U.S.C. 77a). The description of the 
operation of the Trust herein is based, in part, on the most recent 
Registration Statement. The Registration Statement is not yet 
effective, and the Shares will not trade on the Exchange until such 
time that the Registration Statement is effective.
    \5\ Commodity-Based Trust Shares are securities issued by a 
trust that represents investors' discrete identifiable and undivided 
beneficial ownership interest in the commodities deposited into the 
trust.
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    According to the Registration Statement, the Trust will not be 
registered as an investment company under the Investment Company Act of 
1940,\6\ and is not required to register thereunder. The Trust is not a 
commodity pool for purposes of the Commodity Exchange Act.\7\
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    \6\ 15 U.S.C. 80a-1.
    \7\ 17 U.S.C. 1.
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    The Exchange represents that the Shares satisfy the requirements of 
NYSE Arca Rule 8.201-E and thereby qualify for listing on the Exchange.
Operation of the Trust \8\
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    \8\ The description of the operation of the Trust, the Shares, 
and the Dogecoin market contained herein is based, in part, on the 
Registration Statement. See note 4, supra.
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    The Trust will issue the Shares which, according to the 
Registration Statement, represent units of undivided beneficial 
ownership of the Trust. The Trust is a Delaware statutory trust and 
will operate pursuant to a trust agreement (the ``Trust Agreement'') 
between Bitwise Investment Advisers, LLC (the ``Sponsor'' or 
``Bitwise'') and Delaware Trust Company, as the Trust's trustee (the 
``Trustee''). Coinbase Custody Trust Company, LLC will maintain custody 
of the Trust's Dogecoin (the ``Dogecoin Custodian''). Bank of New York 
Mellon will be the custodian for the Trust's cash holdings (in such 
role, the ``Cash Custodian''), the administrator of the Trust (in such 
role, the ``Administrator''), and the transfer agent for the Trust (in 
such role, the ``Transfer Agent'').
    According to the Registration Statement, the investment objective 
of the Trust is to seek to provide exposure to the value of Dogecoin 
held by the Trust, less the expenses of the Trust's

[[Page 12430]]

operations. In seeking to achieve its investment objective, the Trust 
will hold Dogecoin and establish its Net Asset Value (``NAV'') at the 
end of every business day by reference to the CF Dogecoin-Dollar 
Settlement Price (the ``Pricing Benchmark'').\9\
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    \9\ The Pricing Benchmark is a standardized reference rate 
published by CF Benchmarks Ltd. that is designed to reflect the 
performance of Dogecoin in U.S. dollars.
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    The Trust's only asset will be Dogecoin and, under limited 
circumstances, cash.\10\ The Trust does not seek to hold any non-
Dogecoin crypto assets and has expressly disclaimed ownership of any 
such assets in the event the Trust ever involuntarily comes into 
possession of such assets.\11\ The Trust will not use derivatives that 
may subject the Trust to counterparty and credit risks. The Trust will 
process creations and redemptions in cash. The Trust's only recurring 
ordinary expense is expected to be the Sponsor's unitary management fee 
(the ``Sponsor Fee''), which will accrue daily and will be payable in 
Dogecoin monthly in arrears. The Administrator will calculate the 
Sponsor Fee on a daily basis by applying an annualized rate to the 
Trust's total Dogecoin holdings, and the amount of Dogecoin payable in 
respect of each daily accrual shall be determined by reference to the 
Pricing Benchmark. Financial institutions authorized to create and 
redeem Shares (each, an ``Authorized Participant'') will deliver, or 
cause to be delivered, cash in exchange for Shares of the Trust, and 
the Trust will deliver cash to Authorized Participants when those 
Authorized Participants redeem Shares of the Trust.
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    \10\ The Trust conducts creations and redemptions of its Shares 
for cash. Authorized Participants will deliver cash to the Cash 
Custodian pursuant to creation orders for Shares, and the Cash 
Custodian will hold such cash until such time as it can be converted 
to Dogecoin, which the Trust intends to do on the same business day 
in which such cash is received by the Cash Custodian. Additionally, 
the Trust will sell Dogecoin in exchange for cash pursuant to 
redemption orders of its Shares. In connection with such sales, an 
approved Dogecoin Trading Counterparty (defined below) will send 
cash to the Cash Custodian. The Cash Custodian will hold such cash 
until it can be distributed to the redeeming Authorized Participant, 
which it intends to do on the same business day in which it is 
received. In connection with the purchases and sales of Dogecoin 
pursuant to its creation and redemption activity, it is possible 
that the Trust may retain de minimis amounts of cash as a result of 
rounding differences. The Trust may also initially hold small 
amounts of cash to initiate Trust operations in the immediate 
aftermath of its Registration Statement being declared effective. 
Lastly, the Trust may also sell Dogecoin and temporarily hold cash 
as part of a liquidation of the Trust or to pay certain 
extraordinary expenses not assumed by the Sponsor. Under the Trust 
Agreement, the Sponsor has agreed to assume the normal operating 
expenses of the Trust, subject to certain limitations. For example, 
the Trust will bear any indemnification or litigation liabilities as 
extraordinary expenses. In any event, in the ongoing course of 
business, the amounts of cash retained by the Trust are not expected 
to constitute a material portion of the Trust's holdings.
    \11\ The Trust may, from time to time, passively receive, by 
virtue of holding Dogecoin, certain additional digital assets (``IR 
Assets'') or rights to receive IR Assets (``Incidental Rights'') 
through a fork of the Dogecoin Network or an airdrop of assets. The 
Trust will not seek to acquire such IR Assets or Incidental Rights. 
Pursuant to the terms of the Trust Agreement, the Trust has 
disclaimed ownership in any such IR Assets and/or Incidental Rights 
to make clear that such assets are not and shall never be considered 
assets of the Trust and will not be taken into account for purposes 
of determining the Trust's NAV or NAV per Share.
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Custody of the Trust's Custodian
    The Trust's Dogecoin Custodian will maintain custody of all of the 
Trust's Dogecoin, other than that which is maintained in a trading 
account (the ``Trading Balance'') with Coinbase, Inc. (the ``Prime 
Execution Agent,'' which is an affiliate of the Dogecoin Custodian), in 
the ``Trust Dogecoin Account.'' The Trading Balance will only be used 
in the limited circumstances in which the Trust is using the Agent 
Execution Model (as defined below) to effectuate the purchases and 
sales of Dogecoin. The Dogecoin Custodian provides safekeeping of 
Dogecoin using a multi-layer cold storage security platform designed to 
provide offline security of the Dogecoin held by the Dogecoin 
Custodian.
Valuation of the Trust's Dogecoin
    The net assets of the Trust and its Shares are valued on a daily 
basis with reference to the Pricing Benchmark, a standardized reference 
rate that is designed to reflect the performance of Dogecoin in U.S. 
dollars. The Trust uses the Pricing Benchmark to calculate its NAV, as 
described below in ``Net Asset Value.''
    The Sponsor, in its sole discretion, may cause the Trust to price 
its portfolio based upon an index, benchmark, or standard other than 
the Pricing Benchmark at any time, with prior notice to the 
shareholders and the Exchange, if investment conditions change or the 
Sponsor believes that another index, benchmark, or standard better 
aligns with the Trust's investment objective and strategy. The Sponsor 
may make this decision for a number of reasons, including, but not 
limited to, a determination that the Pricing Benchmark price of 
Dogecoin differs materially from the global market price of Dogecoin 
and/or that third parties are able to purchase and sell Dogecoin on 
public or private markets not included among the Constituent Platforms, 
and such transactions may take place at prices materially higher or 
lower than the Pricing Benchmark price. The Sponsor, however, is under 
no obligation whatsoever to make such changes in any circumstance. In 
the event that the Sponsor intends to establish the Trust's NAV by 
reference to an index, benchmark, or standard other than the Pricing 
Benchmark, it will provide shareholders with notice in a prospectus 
supplement and/or through a current report on Form 8-K or in the 
Trust's annual or quarterly reports.\12\
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    \12\ The Sponsor will provide notice of any such changes in the 
Trust's periodic or current reports and, if the Sponsor makes such a 
change other than on an ad hoc or temporary basis, will file a 
proposed rule change with the Commission.
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The Pricing Benchmark
    The Pricing Benchmark is published by CF Benchmarks Ltd. (the 
``Benchmark Provider'') \13\ and was created to facilitate financial 
products based on Dogecoin. It serves as a once-a-day benchmark rate of 
the U.S. dollar price of Dogecoin (USD/DOGE), calculated as of 4:00 
p.m. Eastern Time (``E.T.''). The Pricing Benchmark aggregates the 
trade flow of several major Dogecoin trading venues (the ``Constituent 
Platforms''), during an observation window between 3:00 p.m. and 4:00 
p.m. E.T. into the U.S. dollar price of one Dogecoin at 4:00 p.m. E.T. 
The Pricing Benchmark is representative of the Dogecoin trading 
activity on the Constituent Platforms.
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    \13\ The Benchmark Provider also publishes the CF Dogecoin-
Dollar Spot Rate, which is a continuous measure of the U.S. dollar 
price of one Dogecoin calculated once per second. The CF Dogecoin-
Dollar Spot Rate is also representative of the Dogecoin trading 
activity on the Constituent Platforms.
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    The Pricing Benchmark is designed based on the IOSCO Principals for 
Financial Benchmarks and subject to the U.K. Benchmarks Regulation 
(``BMR''). The Pricing Benchmark is administered through the Benchmark 
Provider's codified policies for index integrity, including a 
conflicts-of-interest policy, a control framework, an accountability 
framework, and an input data policy. The Pricing Benchmark is subject 
to oversight by the Benchmark Provider's CF Cryptocurrency Index Family 
Oversight Function (``Benchmark Provider Oversight Function'').
Methodology
    The Benchmark Provider calculates the Pricing Benchmark based on 
the ``Relevant Transactions'' \14\ of the Constituent Platforms as 
follows:
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    \14\ ``Relevant Transactions'' are any Dogecoin spot trades that 
occur during the twelve equally sized time intervals of five minutes 
in length that occur on a Constituent Platform and ares reported 
through an API.

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[[Page 12431]]

    <bullet> All Relevant Transactions are added to a joint list, 
recording the time of execution, trade price and size for each 
transaction.
    <bullet> The list is partitioned by timestamp into twelve equally 
sized time intervals of five minutes in length.
    <bullet> For each partition separately, the volume-weighted median 
\15\ trade price is calculated from the trade prices and sizes of all 
Relevant Transactions (i.e., across all Constituent Platforms).
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    \15\ A volume-weighted median differs from a standard median in 
that a weighting factor, in this case trade size, is factored into 
the calculation.
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    <bullet> The Pricing Benchmark is then determined by the equally 
weighted average of the volume medians of all partitions.
    A trading venue is eligible as a Constituent Platform if, in the 
opinion of the Benchmark Provider Oversight Function, it fulfills the 
following criteria:
    <bullet> The venue facilitates spot trading of the relevant base 
asset against the corresponding quote asset (the ``Relevant Pair'') and 
makes trade data and order data available through an Automatic 
Programming Interface (``API'') with sufficient reliability, detail, 
and timeliness.
    <bullet> The average daily volume contribution of the Relevant Pair 
spot trading volume during the observation window for the Relevant Pair 
is greater than 3% of the other Constituent Platforms in combination 
for 45 consecutive days.
    <bullet> The venue has published policies designed to ensure fair 
and transparent market conditions at all times and has processes in 
place intended to identify and impede illegal, unfair or manipulative 
trading practices.
    <bullet> The venue does not impose undue barriers to entry or 
restrictions on market participants, and utilizing the venue does not 
expose market participants to undue credit risk, operational risk, 
legal risk or other risks.
    <bullet> The venue complies with applicable law and regulation, 
including, but not limited to capital markets regulations, money 
transmission regulations, client money custody regulations, know-your-
client regulations, and anti-money laundering regulations.
    <bullet> The venue cooperates with inquiries and investigations of 
regulators and the Administrator upon request.
    As of the date of this filing, the Constituent Platforms included 
in the Pricing Benchmark are Coinbase, Gemini, and Kraken.
    <bullet> Coinbase: A U.S.-based digital asset trading platform 
registered as a Money Services Business (``MSB'') with the U.S. 
Department of the Treasury Financial Crimes Enforcement Network 
(``FinCEN'') and licensed as a virtual currency business under the New 
York Department of Financial Services (``NYDFS'') BitLicense, as well 
as a money transmitter in various U.S. states. Subsidiaries operating 
internationally are further regulated as e-money providers (Republic of 
Ireland, Central Bank of Ireland) and Major Payment Institutions 
(Singapore, Monetary Authority of Singapore).
    <bullet> Gemini: A U.S.-based digital asset trading platform that 
is licensed as a virtual currency business under the NYDFS BitLicense. 
It is also registered with FinCEN as an MSB and is licensed as a money 
transmitter in various U.S. states. It is also registered with the UK 
Financial Conduct Authority (``FCA'') as a Crypto Asset Business.
    <bullet> Kraken: A U.S.-based digital asset trading platform that 
is registered as an MSB with FinCEN in various U.S. states, Kraken is 
registered with the FCA as a Crypto Asset Business and is authorized by 
the Central Bank of Ireland as a Virtual Asset Service Provider. Kraken 
also holds a variety of other licenses and regulatory approvals, 
including from the Canadian Securities Administrators.
Net Asset Value
    The Trust's only asset will be Dogecoin and, under limited 
circumstances, cash. The Trust's NAV and NAV per Share will be 
determined by the Administrator once each Exchange trading day as of 
4:00 p.m. E.T., or as soon thereafter as practicable. The Administrator 
will calculate the NAV by multiplying the number of Dogecoin held by 
the Trust by the Pricing Benchmark for such day, adding any additional 
receivables and subtracting the accrued but unpaid liabilities of the 
Trust. The NAV per Share is calculated by dividing the NAV by the 
number of Shares then outstanding. The Administrator will determine the 
price of the Trust's Dogecoin by reference to the Pricing Benchmark, 
which is published and calculated as set forth above.
Intraday Trust Value
    The Trust uses the CF Dogecoin-Dollar Spot Price to calculate an 
Indicative Trust Value (``ITV''). One or more major market data vendors 
will disseminate the ITV, updated every 15 seconds each trading day as 
calculated by the Exchange or a third-party financial data provider 
during the Exchange's Core Trading Session (9:30 a.m. to 4:00 p.m., 
E.T.). The ITV will be calculated throughout the trading day by using 
the prior day's holdings at the close of business and the most recently 
reported price level of the CF Dogecoin-Dollar Spot Price. The ITV will 
be widely disseminated by one or more major market data vendors during 
the NYSE Arca Core Trading Session.
Creation and Redemption of Shares
    The Trust creates and redeems Shares from time to time, but only in 
one or more Creation Units, which will initially consist of at least 
10,000 Shares, but may be subject to change (``Creation Unit''). A 
Creation Unit is only made in exchange for delivery to the Trust or the 
distribution by the Trust of an amount of cash, equivalent to the value 
of Dogecoin represented by the Creation Unit being created or redeemed, 
the amount of which is representative of the combined NAV of the number 
of Shares included in the Creation Units being created or redeemed 
determined as of 4:00 p.m. E.T. on the day the order to create or 
redeem Creation Units is properly received. Except when aggregated in 
Creation Units or under extraordinary circumstances permitted under the 
Trust Agreement, the Shares are not redeemable securities.
    Authorized Participants are the only persons that may place orders 
to create and redeem Creation Units. Authorized Participants must be 
(1) registered broker-dealers or other securities market participants, 
such as banks and other financial institutions, that are not required 
to register as broker-dealers to engage in securities transactions 
described below, and (2) Depository Trust Company (``DTC'') 
participants. To become an Authorized Participant, a person must enter 
into an Authorized Participant Agreement with the Trust and/or the 
Trust's marketing agent (the ``Marketing Agent'').
    According to the Registration Statement, when purchasing or selling 
Dogecoin in response to the purchase of Creation Units or the 
redemption of Creation Units, which will be processed in cash, the 
Trust would do so pursuant to either (1) a ``Trust-Directed Trade 
Model,'' or (2) an ``Agent Execution Model,'' which are each described 
in more detail below.
    The Trust intends to utilize the Trust-Directed Trade Model for all 
purchases and sales of Dogecoin and would only utilize the Agent 
Execution Model in the event that no Dogecoin trading counterparty 
approved by the Sponsor (an ``Dogecoin Trading

[[Page 12432]]

Counterparty'') \16\ is able to effectuate the Trust's purchase or sale 
of Dogecoin. Under the Trust-Directed Trade Model, in connection with 
receipt of a purchase order or redemption order, the Sponsor, on behalf 
of the Trust, would be responsible for acquiring Dogecoin from an 
approved Dogecoin Trading Counterparty in an amount equal to the Basket 
Amount (as defined below). When seeking to purchase Dogecoin on behalf 
of the Trust, the Sponsor will seek to purchase Dogecoin at 
commercially reasonable price and terms from any of the approved 
Dogecoin Trading Counterparties.\17\ Once agreed upon, the transaction 
will generally occur on an ``over-the-counter'' basis.
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    \16\ The Dogecoin Trading Counterparties with which the Sponsor 
will engage in Dogecoin transactions are unaffiliated third-parties 
that are not acting as agents of the Trust, the Sponsor or the 
Authorized Participant, and all transactions will be done on an 
arms-length basis. There is no contractual relationship between the 
Trust, the Sponsor or the Dogecoin Trading Counterparty.
    \17\ The Sponsor will maintain ownership and control of Dogecoin 
in a manner consistent with good delivery requirements for spot 
commodity transactions.
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    Whether utilizing the Trust-Directed Trade Model or the Agent 
Execution Model, the Authorized Participants will deliver only cash to 
create shares and will receive only cash when redeeming Shares. 
Further, Authorized Participants will not directly or indirectly 
purchase, hold, deliver, or receive Dogecoin as part of the creation or 
redemption process or otherwise direct the Trust or a third party with 
respect to purchasing, holding, delivering, or receiving Dogecoin as 
part of the creation or redemption process. Additionally, under either 
the Trust-Directed Trade Model or the Agent Execution Model, the Trust 
will create Shares by receiving Dogecoin from a third party that is not 
the Authorized Participant and is not affiliated with the Sponsor or 
the Trust, and the Trust--not the Authorized Participant--is 
responsible for selecting the third party to deliver the Dogecoin. The 
third party will not be acting as an agent of the Authorized 
Participant with respect to the delivery of the Dogecoin to the Trust 
or acting at the direction of the Authorized Participant with respect 
to the delivery of the Dogecoin to the Trust. Additionally, the Trust 
will redeem Shares by delivering Dogecoin to a third party that is not 
the Authorized Participant and is not affiliated with the Sponsor or 
the Trust, and the Trust--not the Authorized Participant--is 
responsible for selecting the third party to receive the Dogecoin. 
Finally, the third party will not be acting as an agent of the 
Authorized Participant with respect to the receipt of the Dogecoin from 
the Trust or acting at the direction of the Authorized Participant with 
respect to the receipt of the Dogecoin from the Trust.
Acquiring and Selling Dogecoin Pursuant to Creation and Redemption of 
Shares Under the Trust-Directed Trade Model
    Under the Trust-Directed Trade Model and as set forth in the 
Registration Statement, on any business day, an Authorized Participant 
may create Shares by placing an order to purchase one or more Creation 
Units with the Transfer Agent through the Marketing Agent. Such orders 
are subject to approval by the Marketing Agent and the Transfer Agent. 
For purposes of processing creation and redemption orders, a ``business 
day'' means any day other than a day when the Exchange is closed for 
regular trading (``Business Day''). To be processed on the date 
submitted, creation orders must be placed before 4:00 p.m. E.T. or the 
close of regular trading on the Exchange, whichever is earlier, but may 
be required to be placed earlier at the discretion of the Sponsor. A 
purchase order will be effective on the date it is received by the 
Transfer Agent and approved by the Marketing Agent (``Purchase Order 
Date'').
    Creation Units are processed in cash. By placing a purchase order, 
an Authorized Participant agrees to deposit, or cause to be deposited, 
an amount of cash equal to the quantity of Dogecoin attributable to 
each Share of the Trust (net of accrued but unpaid expenses and 
liabilities) multiplied by the number of Shares (10,000) comprising a 
Creation Unit (such quantity, the ``Basket Amount''). That cash amount 
is derived by multiplying the Basket Amount by the value of Dogecoin 
ascribed by the Pricing Benchmark. The Sponsor will cause to be 
published each Business Day, prior to the commencement of trading on 
the Exchange, the Basket Amount relating to a Creation Unit applicable 
for such Business Day. However, the Authorized Participant is also 
responsible for any additional cash required to account for the price 
at which the Trust agrees to purchase the requisite amount of Dogecoin 
from an Dogecoin Trading Counterparty to the extent it is greater than 
the Pricing Benchmark price on each Purchase Order Date.
    Prior to the delivery of Creation Units, the Authorized Participant 
must also have wired to the Transfer Agent the nonrefundable 
transaction fee due for the creation order. Authorized Participants may 
not withdraw a creation request. If an Authorized Participant fails to 
consummate the foregoing, the order may be cancelled.
    Following the acceptance of a purchase order, the Authorized 
Participant must wire the cash amount described above to the Cash 
Custodian, and the Dogecoin Trading Counterparty must deposit the 
required amount of Dogecoin with the Dogecoin Custodian by the end of 
the day E.T. on the Business Day following the Purchase Order Date. The 
Dogecoin will be purchased from Dogecoin Trading Counterparties that 
are not acting as agents of the Trust or agents of the Authorized 
Participant. These transactions will be done on an arms-length basis, 
and there is no contractual relationship between the Trust, the 
Sponsor, or the Dogecoin Trading Counterparty to acquire such Dogecoin. 
Prior to any movement of cash from the Cash Custodian to the Dogecoin 
Trading Counterparty or movement of Shares from the Transfer Agent to 
the Authorized Participant's DTC account to settle the transaction, the 
Dogecoin must be deposited at the Dogecoin Custodian.
    The Dogecoin Trading Counterparty must deposit the required amount 
of Dogecoin by end of day E.T. on the Business Day following the 
Purchase Order Date prior to any movement of cash from the Cash 
Custodian or Shares from the Transfer Agent. Upon receipt of the 
deposit amount of Dogecoin at the Dogecoin Custodian from the Dogecoin 
Trading Counterparty, the Dogecoin Custodian will notify the Sponsor 
that the Dogecoin has been received. The Sponsor will then notify the 
Transfer Agent that the Dogecoin has been received, and the Transfer 
Agent will direct DTC to credit the number of Shares ordered to the 
Authorized Participant's DTC account and will wire the cash previously 
sent by the Authorized Participant to the Dogecoin Trading Counterparty 
to complete settlement of the Purchase Order and the acquisition of the 
Dogecoin by the Trust, as described above.
    As between the Trust and the Authorized Participant, the expense 
and risk of the difference between the value of Dogecoin calculated by 
the Administrator for daily valuation using the Pricing Benchmark and 
the price at which the Trust acquires the Dogecoin will be borne solely 
by the Authorized Participant to the extent that the Trust pays more 
for Dogecoin than the price used by the Trust for daily valuation. Any 
such additional cash amount will be included in the amount of cash 
calculated by the Administrator on the Purchase Order Date, 
communicated to the Authorized Participant on the

[[Page 12433]]

Purchase Order Date, and wired by the Authorized Participant to the 
Cash Custodian on the day following the Purchase Order Date. If the 
Dogecoin Trading Counterparty fails to deliver the Dogecoin to the 
Dogecoin Custodian, no cash is sent from the Cash Custodian to the 
Dogecoin Trading Counterparty, no Shares are transferred to the 
Authorized Participant's DTC account, the cash is returned to the 
Authorized Participant, and the Purchase Order is cancelled.
    Under the Trust-Directed Trade Model and according to the 
Registration Statement, the procedures by which an Authorized 
Participant can redeem one or more Creation Units mirror the procedures 
for the creation of Creation Units. On any Business Day, an Authorized 
Participant may place an order with the Transfer Agent through the 
Marketing Agent to redeem one or more Creation Units. To be processed 
on the date submitted, redemption orders must be placed before 4:00 
p.m. E.T. or the close of regular trading on the Exchange, whichever is 
earlier, or earlier as determined by the Sponsor. A redemption order 
will be effective on the date it is received by the Transfer Agent and 
approved by the Marketing Agent (``Redemption Order Date''). The 
redemption procedures allow Authorized Participants to redeem Creation 
Units and do not entitle an individual shareholder to redeem any Shares 
in an amount less than a Creation Unit, or to redeem Creation Units 
other than through an Authorized Participant. In connection with 
receipt of a redemption order accepted by the Marketing Agent and 
Transfer Agent, the Sponsor, on behalf of the Trust, is responsible for 
selling the Dogecoin to an approved Dogecoin Trading Counterparty in an 
amount equal to the Basket Amount.
    The redemption distribution from the Trust will consist of a 
transfer to the redeeming Authorized Participant, or its agent, of the 
amount of cash the Trust received in connection with a sale of the 
Basket Amount of Dogecoin to an Dogecoin Trading Counterparty made 
pursuant to the redemption order. The Sponsor will cause to be 
published each Business Day, prior to the commencement of trading on 
the Exchange, the redemption distribution amount relating to a Creation 
Unit applicable for such Business Day. The redemption distribution 
amount is derived by multiplying the Basket Amount by the value of 
Dogecoin ascribed by the Pricing Benchmark. However, as between the 
Trust and the Authorized Participant, the expense and risk of the 
difference between the value of Dogecoin ascribed by the Pricing 
Benchmark and the price at which the Trust sells the Dogecoin will be 
borne solely by the Authorized Participant to the extent that the Trust 
receives less for Dogecoin than the value ascribed by Pricing 
Benchmark.
    Prior to the delivery of Creation Units, the Authorized Participant 
must also have wired to the Transfer Agent the nonrefundable 
transaction fee due for the redemption order.
    The redemption distribution due from the Trust will be delivered by 
the Transfer Agent to the Authorized Participant once the Cash 
Custodian has received the cash from the Dogecoin Trading Counterparty. 
The Dogecoin Custodian will not send the Basket Amount of Dogecoin to 
the Dogecoin Trading Counterparty until the Cash Custodian has received 
the cash from the Dogecoin Trading Counterparty and is instructed by 
the Sponsor to make such transfer. Once the Dogecoin Trading 
Counterparty has sent the cash to the Cash Custodian in an agreed upon 
amount to settle the agreed upon sale of the Basket Amount of Dogecoin, 
the Transfer Agent will notify Sponsor. The Sponsor will then notify 
the Dogecoin Custodian to transfer the Dogecoin to the Dogecoin Trading 
Counterparty, and the Transfer Agent will wire the cash proceeds to the 
Authorized Participant once the Trust's DTC account has been credited 
with the Shares represented by the Creation Unit from the redeeming 
Authorized Participant. Once the Authorized Participant has delivered 
the Shares represented by the Creation Unit to be redeemed to the 
Trust's DTC account, the Cash Custodian will wire the requisite amount 
of cash to the Authorized Participant. If the Trust's DTC account has 
not been credited with all of the Shares of the Creation Unit to be 
redeemed, the redemption distribution will be delayed until such time 
as the Transfer Agent confirms receipt of all such Shares. If the 
Dogecoin Trading Counterparty fails to deliver the cash to the Cash 
Custodian, the transaction will be cancelled, and no transfer of 
Dogecoin or Shares will occur.
Acquiring and Selling Dogecoin Pursuant to Creation and Redemption of 
Shares Under the Agent Execution Model
    Under the Agent Execution Model, the Prime Execution Agent, acting 
in an agency capacity, would conduct Dogecoin purchases and sales on 
behalf of the Trust with third parties through its Coinbase Prime 
service pursuant to the Prime Execution Agent Agreement. To utilize the 
Agent Execution Model, the Trust may maintain some Dogecoin or cash in 
the Trading Balance with the Prime Execution Agent. The Prime Execution 
Agent Agreement provides that the Trust does not have an identifiable 
claim to any particular Dogecoin (and cash); rather, the Trust's 
Trading Balance represents an entitlement to a pro rata share of the 
Dogecoin (and cash) the Prime Execution Agent holds on behalf of 
customers who hold similar entitlements against the Prime Execution 
Agent. In this way, the Trust's Trading Balance represents an omnibus 
claim on the Prime Execution Agent's Dogecoin (and cash) held on behalf 
of the Prime Execution Agent's customers.
    To avoid having to pre-fund purchases or sales of Dogecoin in 
connection with cash creations and redemptions and sales of Dogecoin to 
pay Trust expenses not assumed by the Sponsor, to the extent 
applicable, the Trust may borrow Dogecoin or cash as trade credit 
(``Trade Credit'') from Coinbase Credit, Inc. (the ``Trade Credit 
Lender'') on a short-term basis pursuant to the Coinbase Credit 
Committed Trade Financing Agreement (the ``Trade Financing 
Agreement'').
    On the day of the Purchase Order Date, the Trust would enter into a 
transaction to buy Dogecoin through the Prime Execution Agent for cash. 
Because the Trust's Trading Balance may not be funded with cash on the 
Purchase Order Date for the purchase of Dogecoin in connection with the 
Purchase Order under the Agent Execution Model, the Trust may borrow 
Trade Credits in the form of cash from the Trade Credit Lender pursuant 
to the Trade Financing Agreement or may require the Authorized 
Participant to deliver the required cash for the Purchase Order on the 
Purchase Order Date. The extension of Trade Credits on the Purchase 
Order Date allows the Trust to purchase Dogecoin through the Prime 
Execution Agent on the Purchase Order Date, with such Dogecoin being 
deposited in the Trust's Trading Balance.
    On the day following the Purchase Order Date (the ``Purchase Order 
Settlement Date''), the Trust would deliver Shares to the Authorized 
Participant in exchange for cash received from the Authorized 
Participant. Where applicable, the Trust would use the cash to repay 
the Trade Credits borrowed from the Trade Credit Lender. On the 
Purchase Order Settlement Date for a Purchase Order utilizing the Agent 
Execution Model, the Dogecoin associated with the Purchase Order and 
purchased on the Purchase Order Date is swept from the

[[Page 12434]]

Trust's Trading Balance with the Prime Execution Agent to the Trust 
Dogecoin Account with the Dogecoin Custodian pursuant to a regular end-
of-day sweep process. Transfers of Dogecoin into the Trust's Trading 
Balance are off-chain transactions and transfers from the Trust's 
Trading Balance to the Trust Dogecoin Account are ``on-chain'' 
transactions represented on the Dogecoin blockchain. Any financing fee 
owed to the Trade Credit Lender is deemed part of trade execution costs 
and embedded in the trade price for each transaction.
    For a Redemption Order utilizing the Agent Execution Model, on the 
day of the Redemption Order Date the Trust would enter into a 
transaction to sell Dogecoin through the Prime Execution Agent for 
cash. The Trust's Trading Balance with the Prime Execution Agent may 
not be funded with Dogecoin on trade date for the sale of Dogecoin in 
connection with the redemption order under the Agent Execution Model, 
when Dogecoin remains in the Trust Dogecoin Account with the Dogecoin 
Custodian at the point of intended execution of a sale of Dogecoin. In 
those circumstances the Trust may borrow Trade Credits in the form of 
Dogecoin from the Trade Credit Lender, which allows the Trust to sell 
Dogecoin through the Prime Execution Agent on the Redemption Order 
Date, and the cash proceeds are deposited in the Trust's Trading 
Balance with the Prime Execution Agent. On the business day following 
the Redemption Order Date (the ``Redemption Order Settlement Date'') 
for a redemption order utilizing the Agent Execution Model where Trade 
Credits were utilized, the Trust delivers cash to the Authorized 
Participant in exchange for Shares received from the Authorized 
Participant. In the event Trade Credits were used, the Trust will use 
the Dogecoin that is moved from the Trust Dogecoin Account with the 
Dogecoin Custodian to the Trading Balance with the Prime Execution 
Agent to repay the Trade Credits borrowed from the Trade Credit Lender.
    For a redemption of Creation Units utilizing the Agent Execution 
Model, the Sponsor would instruct the Dogecoin Custodian to prepare to 
transfer the Dogecoin associated with the redemption order from the 
Trust Dogecoin Account with the Dogecoin Custodian to the Trust's 
Trading Balance with the Prime Execution Agent. On the Redemption Order 
Settlement Date, the Trust would enter into a transaction to sell 
Dogecoin through the Prime Execution Agent for cash, and the Prime 
Execution Agent credits the Trust's Trading Balance with the cash. On 
the same day, the Authorized Participant would deliver the necessary 
Shares to the Trust and the Trust delivers cash to the Authorized 
Participant.
Fee Accrual
    According to the Registration Statement, the Trust's only recurring 
ordinary expense is expected to be the Sponsor Fee, which will accrue 
daily and will be payable in Dogecoin monthly in arrears. The 
Administrator will calculate the Sponsor Fee on a daily basis by 
applying an annualized rate to the Trust's total Dogecoin holdings, and 
the amount of Dogecoin payable in respect of each daily accrual shall 
be determined by reference to the Pricing Benchmark.
Background
    Dogecoin is a digital asset that is created and transmitted through 
the operations of the peer-to-peer ``Dogecoin Network,'' a 
decentralized network of computers that operates on cryptographic 
protocols. The Dogecoin Network allows people to exchange tokens of 
value, called Dogecoin or ``DOGE.''
    Transactions of Dogecoin are processed by a distributed network of 
computers called ``miners.'' Miners are rewarded with Dogecoin for 
their efforts. No single entity owns or operates the Dogecoin Network 
or manages the ``Dogecoin Blockchain,'' a secure digital ledger where 
all transactions of Dogecoin are recorded; instead, the infrastructure 
is collectively maintained by a decentralized user base.
    Dogecoin can be used to pay for goods and services, including to 
send a transaction on the Dogecoin Network, or it can be converted to 
fiat currencies, such as the U.S. dollar. The Dogecoin Network is based 
on a shared public ledger, the Dogecoin Blockchain, similar to the 
Bitcoin network. However, the Dogecoin Network differentiates itself 
from many other digital asset networks in that its stated primary 
function is as an open-source peer-to-peer digital currency, not a 
store of value. Dogecoin may be used, among other purposes, for 
tipping, donations, and online purchases.
    Unlike a centralized system, no single entity controls the Dogecoin 
Network. Instead, a network of independent nodes validates transactions 
and reaches consensus using the proof-of-work mechanism employed by the 
Dogecoin Blockchain. This system ensures network security by requiring 
computational power from miners. The Dogecoin Blockchain was originally 
created as a fork of the Litecoin Blockchain, but was subsequently 
refactored to operate from a technical perspective in a manner similar 
to the Bitcoin Blockchain. Unlike the Bitcoin Blockchain, however, 
which settles a block of transactions roughly every 10 minutes, the 
Dogecoin Blockchain settles a block of transactions roughly every 1 
minute. This makes the Dogecoin Blockchain suitable for transactions 
that need faster confirmation times. The Dogecoin Blockchain can also 
settle more transactions per second than the Bitcoin Blockchain. 
Notably, however, significantly less computing power is directed to 
maintaining the Dogecoin Blockchain as compared to the Bitcoin 
Blockchain, which may make the Dogecoin Blockchain less secure than the 
Bitcoin Blockchain.
    Transactions on the Dogecoin blockchain are validated by a 
decentralized network of miners using a proof-of-work consensus 
mechanism. These miners compete to solve complex cryptographic puzzles, 
and the first to solve a puzzle adds a new block to the blockchain. 
Unlike systems that rely on trusted validators, Dogecoin's network 
relies on computational power to ensure that transactions are valid and 
correctly ordered on the ledger. Miners are entities (which can be 
individuals, mining pools, or organizations) that dedicate computing 
resources to secure the network and validate transactions. This 
decentralized process is designed to maintain the integrity and 
accuracy of the Dogecoin Blockchain. Each node in the network 
independently verifies transactions and blocks to ensure they follow 
the protocol's rules. The decentralized architecture of Dogecoin 
eliminates the need for trusted lists, as consensus is achieved through 
the proof-of-work system, ensuring a trustless and secure network.
    Dogecoin was initially developed in 2013 by the software developers 
Billy Markus and Jackson Palmer, who created the Dogecoin Blockchain 
and launched the Dogecoin Network as a way of making fun of Bitcoin and 
other digital assets, which they believed were being taken too 
seriously. Dogecoin was designed as a ``fun and friendly internet 
currency,'' and adopted the image of a Shibu Inu dog as its logo. 
Despite, or perhaps because of, its satirical origins, Dogecoin gained 
rapid interest and adoption in online communities, and rapidly became 
one of the larger digital assets when measured by market 
capitalization. Users soon began using Dogecoin for certain financial 
transactions, including tipping, trading, and donations. Dogecoin is 
often referred to as the first ``meme coin,''

[[Page 12435]]

which refers to digital assts that are inspired by internet memes or 
trends.
    At the time of its launch in 2013, Dogecoin's Blockchain had no 
pre-mined supply. Instead, new Dogecoins are continuously created as 
miners validate transactions and secure the network. Dogecoin's 
issuance follows an inflationary model, with no fixed supply cap. 
Initially, the reward for mining a block was randomized, but in 2014, 
it was fixed at 10,000 Dogecoins per block. This ongoing issuance 
ensures a consistent supply of Dogecoins to reward miners and maintain 
network security. Dogecoin's supply is entirely determined by its 
blockchain protocol and mining process, without any controlling 
organization managing reserves or distributing coins.
Applicable Standard
    As described below, the Sponsor believes the structure and 
operation of the Trust are designed to mitigate fraudulent and 
manipulative acts and practices, to protect investors and the public 
interest. The Sponsor accordingly believe the Commission should approve 
the listing and trading of Shares of the Trust.
Use of Pricing Benchmark
    The Sponsor believes that the Pricing Benchmark represents an 
effective means to mitigate the impact of potential fraud and 
manipulation on the reference price for Dogecoin.
    Specifically, the Sponsor believes that the use of the Pricing 
Benchmark can (i) mitigate the effects of fraud, manipulation, and 
other anomalous trading activity on the Dogecoin reference rate, (ii) 
provide a real-time, volume-weighted fair value of Dogecoin, and (iii) 
appropriately handle and adjust for non-market related events.
    The Sponsor believes that the Pricing Benchmark accomplishes those 
objectives in the following ways:
    1. The Pricing Benchmark selects as Constituent Platforms trading 
venues that contribute to pricing in a manner that is consistent with 
increasing manipulation resistance and integrity. As noted above, 
trading venues are only eligible for selection as Constituent Platforms 
if the Benchmark Provider Oversight Function concludes that they meet 
the following criteria:
    a. The venue facilitates spot trading of the Relevant Pair and 
makes trade data and order data available through an API with 
sufficient reliability, detail, and timeliness.
    b. The average daily volume contribution of the Relevant Pair spot 
trading volume during the observation window for the Relevant Pair is 
greater than 3% of the other Constituent Platforms in combination for 
45 consecutive days.
    c. The venue has published policies designed to ensure fair and 
transparent market conditions at all times and has processes in place 
intended to identify and impede illegal, unfair or manipulative trading 
practices.
    d. The venue does not impose undue barriers to entry or 
restrictions on market participants, and utilizing the venue does not 
expose market participants to undue credit risk, operational risk, 
legal risk or other risks.
    e. The venue complies with applicable law and regulation, 
including, but not limited to, capital markets regulations, money 
transmission regulations, client money custody regulations, know-your-
client regulations, and anti-money laundering regulations.
    2. The Pricing Benchmark is administered and provided by the 
Benchmark Provider, which is an Administrator of Benchmarks under the 
BMR, received its regulatory authorization in 2019, and has held this 
regulatory authorization continuously since then. The Benchmark 
Provider's compliance with the BMR's comprehensive regulation of 
financial benchmarks has been audited since 2020.\18\
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    \18\ The latest IASE 300 Reasonable Assurance Auditors Report by 
KPMG as of the date of this filing is publicly available at: <a href="https://www.cfbenchmarks.com/legal/audit">https://www.cfbenchmarks.com/legal/audit</a>.
---------------------------------------------------------------------------

    3. The Pricing Benchmark's continued compliance with venue 
eligibility and other criteria is reviewed on an annual basis by the 
Benchmark Provider Oversight Function, an independent committee as 
defined in Article 5 of the EU Benchmark Regulation 2016/1011 (EU BMR) 
and the retained EU law in the UK (The Benchmarks (Amendment and 
Transitional Provision) (EU Exit) Regulations 2019) and Article 3 of 
the Level 2 Delegated Act 2018/1637 (Commission Delegated Regulation 
(EU) 2018/1637).
Availability of Information
    The NAV per Share will be calculated and disseminated daily to all 
market participants at the same time. Quotation and last-sale 
information regarding the Shares will be disseminated through the 
facilities of the CTA. The ITV will be calculated every 15 seconds 
throughout the core trading session each trading day.
    The Sponsor will cause information about the Shares to be posted to 
the Trust's website (<a href="https://www.bitwiseinvestments.com/">https://www.bitwiseinvestments.com/</a>): (1) the NAV 
and NAV per Share for each Exchange trading day, posted at end of day; 
(2) the daily holdings of the Trust, before 9:30 a.m. E.T. on each 
Exchange trading day; (3) the Trust's effective prospectus, in a form 
available for download; and (4) the Shares' ticker and CUSIP 
information, along with additional quantitative information updated on 
a daily basis for the Trust. For example, the Trust's website will 
include (1) the prior Business Day's trading volume, the prior Business 
Day's reported NAV and closing price, and a calculation of the premium 
and discount of the closing price or mid-point of the bid/ask spread at 
the time of NAV calculation (``Bid/Ask Price'') against the NAV; and 
(2) data in chart format displaying the frequency distribution of 
discounts and premiums of the daily closing price or Bid/Ask Price 
against the NAV, within appropriate ranges, for at least each of the 
four previous calendar quarters. The Trust's website will be publicly 
available prior to the public offering of Shares and accessible at no 
charge.
    Investors may obtain on a 24-hour basis Dogecoin pricing 
information based on the Pricing Benchmark, CF Dogecoin-Dollar Spot 
Rate, and spot Dogecoin market prices from various financial 
information service providers. Current Dogecoin spot market prices are 
also available with bid/ask spreads from Dogecoin trading platforms, 
including the Constituent Platforms of the Pricing Benchmark.
    Information regarding market price and trading volume of the Shares 
will be continually available on a real-time basis throughout the day 
on brokers' computer screens and other electronic services.
    Information regarding the previous day's closing price and trading 
volume information for the Shares will be published daily in the 
financial section of newspapers.
Trading Halts
    With respect to trading halts, the Exchange may halt or suspend 
trading in the Shares of the Trust in accordance with its rules. 
Additionally, trading in Shares of the Trust will be halted if the 
circuit breaker parameters in NYSE Arca Rule 7.12-E have been reached. 
Trading also may be halted because of market conditions or for reasons 
that, in the view of the Exchange, make trading in the Shares 
inadvisable.
    The Exchange may halt trading during the day in which an 
interruption to the dissemination of the ITV or Pricing Benchmark (if 
the Exchange becomes aware that the Pricing Benchmark is not

[[Page 12436]]

being published) occurs. If the interruption to the dissemination of 
the ITV or Pricing Benchmark persists past the trading day in which it 
occurred, the Exchange will halt trading no later than the beginning of 
the trading day following the interruption. In addition, if the 
Exchange becomes aware that the NAV with respect to the Shares is not 
disseminated to all market participants at the same time, it will halt 
trading in the Shares until such time as the NAV is available to all 
market participants.
Trading Rules
    The Exchange deems the Shares to be equity securities, thus 
rendering trading in the Shares subject to the Exchange's existing 
rules governing the trading of equity securities. Shares will trade on 
the NYSE Arca Marketplace from 4:00 a.m. to 8:00 p.m. E.T. in 
accordance with NYSE Arca Rule 7.34-E (Early, Core, and Late Trading 
Sessions). The Exchange has appropriate rules to facilitate 
transactions in the Shares during all trading sessions. As provided in 
NYSE Arca Rule 7.6-E, the minimum price variation (``MPV'') for quoting 
and entry of orders in equity securities traded on the NYSE Arca 
Marketplace is $0.01, with the exception of securities that are priced 
less than $1.00 for which the MPV for order entry is $0.0001.
    The Shares will conform to the initial and continued listing 
criteria under NYSE Arca Rule 8.201-E. The trading of the Shares will 
be subject to NYSE Arca Rule 8.201-E(g), which sets forth certain 
restrictions on Equity Trading Permit (``ETP'') Holders acting as 
registered Market Makers in Commodity-Based Trust Shares to facilitate 
surveillance. The Exchange represents that, for initial and continued 
listing, the Trust will be in compliance with Rule 10A-3 under the 
Act,\19\ as provided by NYSE Arca Rule 5.3-E. A minimum of 100,000 
Shares of the Trust will be outstanding at the commencement of trading 
on the Exchange.
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    \19\ With respect to the application of Rule 10A-3 (17 CFR 
240.10A-3) under the Act, the Trust relies on the exemption 
contained in Rule 10A-3(c)(7).
---------------------------------------------------------------------------

Surveillance
    The Exchange represents that trading in the Shares of the Trust on 
the Exchange will be subject to the existing trading surveillances 
administered by the Exchange, as well as cross-market surveillances 
administered by the Financial Industry Regulatory Authority (``FINRA'') 
on behalf of the Exchange, which are designed to detect potential 
violations of Exchange rules and applicable federal securities laws 
with respect to the Shares of the Trust trading on the Exchange.\20\ 
The Exchange represents that these procedures are adequate to properly 
monitor Exchange trading of the Shares in all trading sessions and to 
deter and detect violations of Exchange rules and federal securities 
laws with respect to the Shares of the Trust trading on the Exchange.
---------------------------------------------------------------------------

    \20\ FINRA conducts cross-market surveillances on behalf of the 
Exchange pursuant to a regulatory services agreement. The Exchange 
is responsible for FINRA's performance under this regulatory 
services agreement.
---------------------------------------------------------------------------

    The existing surveillances referred to above generally focus on 
detecting securities trading outside their normal trading patterns, 
which could be indicative of manipulative or other violative activity 
with respect to the Shares of the Trust. When such situations are 
detected, surveillance analysis follows and investigations are opened, 
where appropriate, to review the behavior of all relevant parties for 
all relevant trading violations.
    The Exchange or FINRA, on behalf of the Exchange, or both, may 
communicate regarding trading in the Shares with other markets and 
other entities that are members of the Intermarket Surveillance Group 
(``ISG''). The Exchange or FINRA, on behalf of the Exchange, or both, 
may obtain trading information regarding trading in the Shares and 
Dogecoin derivatives from such markets and other entities. In addition, 
the Exchange may obtain information regarding trading in the Shares and 
Dogecoin derivatives from markets and other entities with which the 
Exchange has in place a comprehensive surveillance sharing agreement 
(``CSSA'').\21\ The Exchange is also able to obtain information from 
ETP Holders regarding their trading (as principal or agent) in the 
Shares and any underlying Dogecoin, options on Dogecoin futures, or any 
other Dogecoin derivatives.\22\
---------------------------------------------------------------------------

    \21\ For a list of the current members of ISG, see 
<a href="http://www.isgportal.org">www.isgportal.org</a>. The Exchange notes that not all components of the 
Trust may trade on markets that are members of ISG or with which the 
Exchange has in place a CSSA.
    \22\ See NYSE Arca Rule 10.8210.
---------------------------------------------------------------------------

    In addition, under NYSE Arca Rule 8.201-E(g), an ETP Holder acting 
as a registered Market Maker in the Shares is required to provide the 
Exchange with information relating to its accounts for trading in any 
underlying commodity, related futures or options on futures, or any 
other related derivatives. Commentary .04 of NYSE Arca Rule 11.3-E 
requires an ETP Holder acting as a registered Market Maker, and its 
affiliates, in the Shares to establish, maintain and enforce written 
policies and procedures reasonably designed to prevent the misuse of 
any material nonpublic information with respect to such products, any 
components of the related products, any physical asset or commodity 
underlying the product, applicable currencies, underlying indexes, 
related futures or options on futures, and any related derivative 
instruments (including the Shares). As a general matter, the Exchange 
has regulatory jurisdiction over its ETP Holders and their associated 
persons, which include any person or entity controlling an ETP Holder. 
To the extent the Exchange may be found to lack jurisdiction over a 
subsidiary or affiliate of an ETP Holder that does business only in 
commodities or futures contracts and that subsidiary or affiliate is a 
member of another regulatory organization, the Exchange could obtain 
information regarding the activities of such subsidiary or affiliate 
through surveillance sharing agreements with regulatory organizations 
to the extent the Exchange has such an agreement with that regulatory 
organization.
    In addition, the Exchange also has a general policy prohibiting the 
distribution of material, non-public information by its employees.
    All statements and representations made in this filing regarding 
(a) the description of the index, portfolio, or reference assets of the 
Trust, (b) limitations on index or portfolio holdings or reference 
assets, or (c) the applicability of Exchange listing rules specified in 
this rule filing shall constitute continued listing requirements for 
listing the Shares on the Exchange.
    The Sponsor has represented to the Exchange that it will advise the 
Exchange of any failure by the Trust to comply with the continued 
listing requirements, and, pursuant to its obligations under Section 
19(g)(1) of the Act, the Exchange will monitor for compliance with the 
continued listing requirements. If the Trust is not in compliance with 
the applicable listing requirements, the Exchange will commence 
delisting procedures under NYSE Arca Rule 5.5-E(m).
Information Bulletin
    Prior to the commencement of trading, the Exchange will inform its 
ETP Holders in an ``Information Bulletin'' of the special 
characteristics and risks associated with trading the Shares. 
Specifically, the Information Bulletin will discuss the following: (1) 
the procedures for creations of Shares in Creation Units; (2) NYSE Arca 
Rule 9.2-E(a), which imposes a duty of due diligence on its ETP Holders 
to learn the essential facts relating to every customer

[[Page 12437]]

prior to trading the Shares; (3) information regarding how the value of 
the ITV and NAV is disseminated; (4) the possibility that trading 
spreads and the resulting premium or discount on the Shares may widen 
during the Opening and Late Trading Sessions, when an updated ITV will 
not be calculated or publicly disseminated; (5) the requirement that 
members deliver a prospectus to investors purchasing newly issued 
Shares prior to or concurrently with the confirmation of a transaction 
and (6) trading information.
    In addition, the Information Bulletin will reference that the Trust 
is subject to various fees and expenses as described in the 
Registration Statement. The Information Bulletin will disclose that 
information about the Shares of the Trust is publicly available on the 
Trust's website.
    The Information Bulletin will also discuss any relief, if granted, 
by the Commission or the staff from any rules under the Act.
2. Statutory Basis
    The basis under the Act for this proposed rule change is the 
requirement under Section 6(b)(5) \23\ that an exchange have rules that 
are designed to prevent fraudulent and manipulative acts and practices, 
to promote just and equitable principles of trade, to remove 
impediments to, and perfect the mechanism of a free and open market 
and, in general, to protect investors and the public interest.
---------------------------------------------------------------------------

    \23\ 15 U.S.C. 78f(b)(5).
---------------------------------------------------------------------------

    The Exchange believes that the proposed rule change is designed to 
prevent fraudulent and manipulative acts and practices in that the 
Shares will be listed and traded on the Exchange pursuant to the 
initial and continued listing criteria in NYSE Arca Rule 8.201-E. The 
Exchange has in place certain surveillance procedures that are adequate 
to properly monitor trading in the Shares on the Exchange in all 
trading sessions and to deter and detect violations of Exchange rules 
and federal securities laws applicable to the Shares of the Trust 
trading on the Exchange. The Exchange or FINRA, on behalf of the 
Exchange, or both, will communicate as needed regarding trading in the 
Shares with other markets that are members of the ISG, and the Exchange 
or FINRA, on behalf of the Exchange, or both, may obtain trading 
information regarding trading in the Shares from such markets. In 
addition, the Exchange may obtain information regarding trading in the 
Shares from markets with which the Exchange has in place a CSSA. Also, 
pursuant to NYSE Arca rules, the Exchange is able to obtain information 
from ETP Holders regarding their trading (as principal or agent) in the 
Shares and any underlying Dogecoin, options on Dogecoin futures, or any 
Dogecoin derivatives.
    The proposed rule change is also designed to prevent fraudulent and 
manipulative acts and practices in connection with trading in the 
Shares on the Exchange because of the Pricing Benchmark's eligibility 
criteria for Constituent Platforms, regulation under the BMR, and 
monitoring for continued compliance by the Benchmark Provider Oversight 
Function. Accordingly, the Pricing Benchmark is designed to (i) 
mitigate the effects of fraud, manipulation, and other anomalous 
trading activity on the Dogecoin reference rate, (ii) provide a real-
time, volume-weighted fair value of Dogecoin, and (iii) appropriately 
handle and adjust for non-market related events.
    The proposed rule change is designed to promote just and equitable 
principles of trade and to protect investors and the public interest in 
that there is a considerable amount of Dogecoin price and market 
information available on public websites and through professional and 
subscription services. Investors may obtain, on a 24-hour basis, 
Dogecoin pricing information based on the spot price for Dogecoin from 
various financial information service providers. The closing price and 
settlement prices of Dogecoin are readily available from the 
Constituent Platforms and other publicly available websites. In 
addition, such prices are published in public sources, or on-line 
information services. The NAV per Share will be calculated daily and 
made available to all market participants at the same time. The Trust 
will provide website disclosure of its NAV daily. One or more major 
market data vendors will disseminate for the Trust on a daily basis 
information with respect to the most recent NAV per Share and Shares 
outstanding. In addition, if the Exchange becomes aware that the NAV 
per Share is not disseminated to all market participants at the same 
time, it will halt trading in the Shares until such time as the NAV is 
available to all market participants. Quotation and last-sale 
information regarding the Shares will be disseminated through the 
facilities of the CTA. The ITV will be widely disseminated on a per 
Share basis every 15 seconds during the NYSE Arca Core Trading Session 
(normally 9:30 a.m., E.T., to 4:00 p.m., E.T.) by one or more major 
market data vendors. The Exchange represents that the Exchange may halt 
trading during the day in which an interruption to the dissemination of 
the ITV or the value of the Pricing Benchmark occurs. If the 
interruption to the dissemination of the ITV or the value of the 
Pricing Benchmark persists past the trading day in which it occurred, 
the Exchange will halt trading no later than the beginning of the 
trading day following the interruption.
    The proposed rule change is designed to perfect the mechanism of a 
free and open market and, in general, to protect investors and the 
public interest in that it will facilitate the listing and trading of 
an additional type of exchange-traded product that will enhance 
competition among market participants, to the benefit of investors and 
the marketplace. As noted above, the Exchange has in place surveillance 
procedures relating to trading in the Shares on the Exchange and may 
obtain information via ISG from other exchanges that are members of ISG 
or with which the Exchange has entered into a CSSA. In addition, as 
noted above, investors will have ready access to information regarding 
the Trust's NAV, ITV, and quotation and last sale information for the 
Shares.

B. Self-Regulatory Organization's Statement on Burden on Competition

    The Exchange does not believe that the proposed rule change will 
impose any burden on competition that is not necessary or appropriate 
in furtherance of the purposes of the Act. The Exchange notes that the 
proposed rule change will facilitate the listing and trading of a new 
type of Commodity-Based Trust Share based on the price of Dogecoin that 
would enhance competition among market participants, to the benefit of 
investors and the marketplace.

C. Self-Regulatory Organization's Statement on Comments on the Proposed 
Rule Change Received From Members, Participants, or Others

    No written comments were solicited or received with respect to the 
proposed rule change.

III. Date of Effectiveness of the Proposed Rule Change and Timing for 
Commission Action

    Within 45 days of the date of publication of this notice in the 
Federal Register or within such longer period up to 90 days (i) as the 
Commission may designate if it finds such longer period to be 
appropriate and publishes its reasons for so finding or (ii) as to 
which the self-regulatory organization consents, the Commission will:
    (A) by order approve or disapprove the proposed rule change, or

[[Page 12438]]

    (B) institute proceedings to determine whether the proposed rule 
change should be disapproved.

IV. Solicitation of Comments

    Interested persons are invited to submit written data, views and 
arguments concerning the foregoing, including whether the proposed rule 
change is consistent with the Act. Comments may be submitted by any of 
the following methods:

Electronic Comments

    <bullet> Use the Commission's internet comment form (<a href="https://www.sec.gov/rules/sro.shtml">https://www.sec.gov/rules/sro.shtml</a>); or
    <bullet> Send an email to <a href="/cdn-cgi/l/email-protection#f486819891d9979b9999919a8087b4879197da939b82"><span class="__cf_email__" data-cfemail="2e5c5b424b034d4143434b405a5d6e5d4b4d00494158">[email&#160;protected]</span></a>. Please include 
file number SR-NYSEARCA-2025-19 on the subject line.

Paper Comments

    <bullet> Send paper comments in triplicate to Secretary, Securities 
and Exchange Commission, 100 F Street NE, Washington, DC 20549-1090.

All submissions should refer to file number SR-NYSEARCA-2025-19. This 
file number should be included on the subject line if email is used. To 
help the Commission process and review your comments more efficiently, 
please use only one method. The Commission will post all comments on 
the Commission's internet website (<a href="https://www.sec.gov/rules/sro.shtml">https://www.sec.gov/rules/sro.shtml</a>). Copies of the submission, all subsequent amendments, all 
written statements with respect to the proposed rule change that are 
filed with the Commission, and all written communications relating to 
the proposed rule change between the Commission and any person, other 
than those that may be withheld from the public in accordance with the 
provisions of 5 U.S.C. 552, will be available for website viewing and 
printing in the Commission's Public Reference Room, 100 F Street NE, 
Washington, DC 20549, on official business days between the hours of 10 
a.m. and 3 p.m. Copies of the filing also will be available for 
inspection and copying at the principal office of the Exchange. Do not 
include personal identifiable information in submissions; you should 
submit only information that you wish to make available publicly. We 
may redact in part or withhold entirely from publication submitted 
material that is obscene or subject to copyright protection. All 
submissions should refer to file number SR-NYSEARCA-2025-19 and should 
be submitted on or before April 7, 2025.

    For the Commission, by the Division of Trading and Markets, 
pursuant to delegated authority.\24\
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    \24\ 17 CFR 200.30-3(a)(12).
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Sherry R. Haywood,
Assistant Secretary.
[FR Doc. 2025-04152 Filed 3-14-25; 8:45 am]
BILLING CODE 8011-01-P


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Indexed from Federal Register on March 17, 2025.

This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.