Subject: File No. SR-CboeBZX-2018-040

From: David A Perry

July 19, 2018

To the Commission and Staff of the SEC:

All securities held in US investment companies have at least one thing in common: they give their holders a legal claim on something of value, whether it be a company's assets, a debt, another security, or a physical commodity or property.

A bitcoin does not give its holder a legal claim on anything, and for this reason cannot be considered a "legitimate" financial asset.

The SEC can draw a clear line here. Please consider the dangerous precedent you will set if you approve this fund.