SEC Comment Letter 0000000000-23-012593 to Grayscale Ethereum Trust (ETH) (ETHE) (CIK 0001725210) (ETHE)
Grayscale Ethereum Trust (ETH) (ETHE) (CIK 0001725210)
Date: Nov. 16, 2023 · CIK: 0001725210 · Accession: 0000000000-23-012593
AI Filing Summary & Sentiment
File numbers found in text: 000-56193
Letter
United States securities and exchange commission logo November 16, 2023 Michael Sonnenshein Chief Executive Officer Grayscale Investments, LLC 290 Harbor Drive, 4th Floor Stamford, Connecticut 06902 Re:Grayscale Ethereum Trust (ETH) Form 10-K for the Fiscal Year Ended December 31, 2022 Filed March 1, 2023 File No. 000-56193 Dear Michael Sonnenshein: We have reviewed your October 6, 2023 response to our comment letter and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our September 14, 2023 letter. Form 10-K for the Fiscal Year Ended December 31, 2022 Item 1A. Risk Factors, page 47 1.We note your response to comment 2 and your undertaking to provide updated disclosure in future filings regarding the risks to the Sponsor and the Trust arising from any legal and financial difficulties of Digital Currency Group, Inc. that are material to the Trust. Subsequent to your October 6, 2023 response letter, we also note the recent lawsuit filed by the NY Attorney General against Digital Currency Group, Inc., among others. In light of this development, please tell us how you considered updating your disclosure in future filings to address the substance of comment 2. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
FirstName LastNameMichael Sonnenshein Comapany NameGrayscale Investments, LLC November 16, 2023 Page 2 FirstName LastName Michael Sonnenshein Grayscale Investments, LLC November 16, 2023 Page 2 Please contact David Irving at 202-551-3321 or Mark Brunhofer at 202-551-3638 if you have questions regarding comments on the financial statements and related matters. Please contact Jessica Livingston at 202-551-3448 or David Lin at 202-551-3552 with any other questions. Sincerely, Division of Corporation Finance Office of Crypto Assets
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United States securities and exchange commission logo
November 16, 2023
Michael Sonnenshein
Chief Executive Officer
Grayscale Investments, LLC
290 Harbor Drive, 4th Floor
Stamford, Connecticut 06902
Re:Grayscale Ethereum Trust (ETH)
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed March 1, 2023
File No. 000-56193
Dear Michael Sonnenshein:
We have reviewed your October 6, 2023 response to our comment letter and have the
following comment.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, our references to prior comments are to comments in our September 14, 2023
letter.
Form 10-K for the Fiscal Year Ended December 31, 2022
Item 1A. Risk Factors, page 47
1.We note your response to comment 2 and your undertaking to provide updated disclosure
in future filings regarding the risks to the Sponsor and the Trust arising from any legal and
financial difficulties of Digital Currency Group, Inc. that are material to the Trust.
Subsequent to your October 6, 2023 response letter, we also note the recent lawsuit filed
by the NY Attorney General against Digital Currency Group, Inc., among others. In light
of this development, please tell us how you considered updating your disclosure in future
filings to address the substance of comment 2.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
FirstName LastNameMichael Sonnenshein
Comapany NameGrayscale Investments, LLC
November 16, 2023 Page 2
FirstName LastName
Michael Sonnenshein
Grayscale Investments, LLC
November 16, 2023
Page 2
Please contact David Irving at 202-551-3321 or Mark Brunhofer at 202-551-3638 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jessica Livingston at 202-551-3448 or David Lin at 202-551-3552 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets