SEC Company Response from Invesco Galaxy Solana ETF (QSOL) — Dec 9, 2025
Invesco Galaxy Solana ETF
Date: Dec. 9, 2025 · CIK: 0002074409 · Accession: 0002071844-25-000624
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-288318
Letter
Re:
Invesco Capital Management LLC 3500 Lacey Road, Suite 700 Downers Grove, IL
December 9, 2025
VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Crypto Assets 100 F Street, NE Washington, D.C. 20549
Invesco Galaxy Solana ETF (the “Trust”)
Request for Acceleration of Effectiveness of Registration Statement on Form S-1,
Pre-Effective Amendment No. 3 Filed November 28, 2025 (File No. 333-288318)
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), the Trust and Invesco Capital Management LLC (the “Sponsor”) hereby request that the effective date of the above-captioned Registration Statement be accelerated so that the Registration Statement becomes effective at 4:00 p.m., Eastern Time on December 9, 2025, or as soon as practicable thereafter.
In requesting such acceleration, the Trust and the Sponsor acknowledge that (i) should the Commission or the Staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement, (ii) the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Trust or the Sponsor from its full responsibility for the adequacy or accuracy of the disclosure in the Registration Statement, and (iii) neither the Trust nor the Sponsor may assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
The Trust and the Sponsor hereby authorize J. Stephen Feinour, Jr., Esq. of Stradley Ronon Stevens & Young, LLP to orally modify or withdraw this request for acceleration. We request that we be notified of the acceleration and effectiveness of the Registration Statement by a telephone call to Mr. Feinour at (215) 564-8521.
Please direct questions or comments relating to this filing to J. Stephen Feinour, Jr., Esq. at (215) 564-8521.
Sincerely,
INVESCO GALAXY SOLANA ETF
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CORRESP 1 filename1.htm Invesco Capital Management LLC 3500 Lacey Road, Suite 700 Downers Grove, IL 60515 December 9, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Crypto Assets 100 F Street, NE Washington, D.C. 20549 Re: Invesco Galaxy Solana ETF (the “Trust”) Request for Acceleration of Effectiveness of Registration Statement on Form S-1, Pre-Effective Amendment No. 3 Filed November 28, 2025 (File No. 333-288318) Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), the Trust and Invesco Capital Management LLC (the “Sponsor”) hereby request that the effective date of the above-captioned Registration Statement be accelerated so that the Registration Statement becomes effective at 4:00 p.m., Eastern Time on December 9, 2025, or as soon as practicable thereafter. In requesting such acceleration, the Trust and the Sponsor acknowledge that (i) should the Commission or the Staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement, (ii) the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Trust or the Sponsor from its full responsibility for the adequacy or accuracy of the disclosure in the Registration Statement, and (iii) neither the Trust nor the Sponsor may assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. The Trust and the Sponsor hereby authorize J. Stephen Feinour, Jr., Esq. of Stradley Ronon Stevens & Young, LLP to orally modify or withdraw this request for acceleration. We request that we be notified of the acceleration and effectiveness of the Registration Statement by a telephone call to Mr. Feinour at (215) 564-8521. Please direct questions or comments relating to this filing to J. Stephen Feinour, Jr., Esq. at (215) 564-8521. Sincerely, INVESCO GALAXY SOLANA ETF By: Invesco Capital Management LLC, Sponsor of the Trust By: /s/ Adam Henkel Name: Adam Henkel Title: Secretary and Head of Legal, US ETFs INVESCO CAPITAL MANAGEMENT LLC By: /s/ Adam Henkel Name: Adam Henkel Title: Secretary and Head of Legal, US ETFs CC: Will McAllister, Invesco Capital Management LLC J. Stephen Feinour, Jr., Stradley Ronon Stevens & Young, LLP Miranda Sturgis, Stradley Ronon Stevens & Young, LLP Mark R. Greer, Stradley Ronon Stevens & Young, LLP