Subject: File No. S7-2026-09
From: Cihan dal

Re: File No. S7-2026-09 I am writing as an individual participant in the Kaspa ecosystem. I respectfully ask the Commission to provide clear guidance that decentralized proof-of-work networks such as Kaspa should be treated as non-security crypto assets when there is no centralized issuer, no premine or insider allocation, and no reliance on managerial efforts of a promoter. Kaspa operates as a permissionless proof-of-work network with open participation and decentralized consensus. It does not grant holders any ownership rights, claims on a business entity, or entitlement to profits generated by a centralized organization. In economic substance, it functions as a network commodity rather than an investment contract. Importantly, Kaspa's base layer (Layer 1) is limited to transaction ordering, data availability, and consensus, and does not provide smart contract execution. This distinguishes the underlying protocol asset from separate application layers or third-party systems that may introduce different risk profiles. I encourage the Commission to clearly distinguish between decentralized base-layer protocol assets and higher-layer applications or tokenized financial products built on top of them. The existence of such external systems should not determine the classification of the underlying decentralized network. Clear and objective guidance on these distinctions would improve regulatory certainty and support responsible innovation. Thank you for your consideration. Name:Cihan dal Country:Turkey