SEC Comment Letter for Grayscale Avalanche Trust (AVAX) (GAVA) (CIK 0002035053) — Feb 25, 2026
Grayscale Avalanche Trust (AVAX) (GAVA) (CIK 0002035053)
Date: Feb. 25, 2026 · CIK: 0002035053 · Accession: 0000000000-26-001976
AI Filing Summary & Sentiment
File numbers found in text: 333-289829
Letter
February 25, 2026 Edward McGee Chief Financial Officer Grayscale Avalanche Trust (AVAX) c/o Grayscale Investments Sponsors, LLC 290 Harbor Drive, 4th Floor Stamford, CT 06902 Re:Grayscale Avalanche Trust (AVAX) Amendment No. 4 to Registration Statement on Form S-1 Filed February 19, 2026 File No. 333-289829 Dear Edward McGee: We have reviewed your amended registration statement and have the following comments. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Amendment No. 4 to Registration Statement on Form S-1 General 1.We note your disclosure that the Trust Agreement provides that the Trust may engage in Staking, but only if the Staking Condition has been satisfied. Please tell us whether you expect the Staking Condition to be satisfied prior to, simultaneously with, or immediately after commencement of the offering and confirm that to the extent the Sponsor causes the Trust to engage in Staking prior to or in connection with the commencement of this offering, you will revise your disclosure accordingly prior to launch. 2.We note your disclosure throughout that "[t]he approximate percentage of the Trust's AVAX that is staked each day would be reported the following day" (emphasis added) on your website. Please confirm that the actual percentage of the Trust's AVAX that is staked will be disclosed on the Trust's website and revise your disclosure accordingly or explain.
February 25, 2026 Page 2 Please contact Mark Brunhofer at 202-551-3638 or Jason Niethamer at 202-551-3855 if you have questions regarding comments on the financial statements and related matters. Please contact David Lin at 202-551-3552 or Sandra Hunter Berkheimer at 202-551-3758 with any other questions. Sincerely, Division of Corporation Finance Office of Crypto Assets cc:Daniel P. Gibbons
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February 25, 2026
Edward McGee
Chief Financial Officer
Grayscale Avalanche Trust (AVAX)
c/o Grayscale Investments Sponsors, LLC
290 Harbor Drive, 4th Floor
Stamford, CT 06902
Re:Grayscale Avalanche Trust (AVAX)
Amendment No. 4 to Registration Statement on Form S-1
Filed February 19, 2026
File No. 333-289829
Dear Edward McGee:
We have reviewed your amended registration statement and have the following
comments.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Amendment No. 4 to Registration Statement on Form S-1
General
1.We note your disclosure that the Trust Agreement provides that the Trust may engage in
Staking, but only if the Staking Condition has been satisfied. Please tell us whether you
expect the Staking Condition to be satisfied prior to, simultaneously with, or immediately
after commencement of the offering and confirm that to the extent the Sponsor causes the
Trust to engage in Staking prior to or in connection with the commencement of this
offering, you will revise your disclosure accordingly prior to launch.
2.We note your disclosure throughout that "[t]he approximate percentage of the Trust's
AVAX that is staked each day would be reported the following day" (emphasis added)
on your website. Please confirm that the actual percentage of the Trust's AVAX that is
staked will be disclosed on the Trust's website and revise your disclosure accordingly or
explain.
February 25, 2026
Page 2
Please contact Mark Brunhofer at 202-551-3638 or Jason Niethamer at 202-551-3855 if
you have questions regarding comments on the financial statements and related matters. Please
contact David Lin at 202-551-3552 or Sandra Hunter Berkheimer at 202-551-3758 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets
cc:Daniel P. Gibbons