(Posted September 2023) A three-judge panel of the District of Columbia Court of Appeals in Washington, DC ruled recently that U.S Securities and Exchange Commission (SEC) was wrong to reject an application from Grayscale Investments to create a spot bitcoin exchange-traded fund (ETF) which would track its underlying market price, giving investors exposure to the digital asset, without having to buy the currency. The SEC has denied all proposed bitcoin ETFs, including Grayscale’s, on the grounds that they do not meet its bar for preventing market manipulation. Grayscale Investments sued the SEC for rejecting their application, in response to