This is why (sometimes) lawyers are worth it. They're right, you know. Given Grayscale was suggesting they had productive talks with the SEC prior to approval, and they had made extensive amendments to the rule proposal in line with those discussions, my guess is the Rule 431 application was a parting gift from Crenshaw acting unilaterally. SEC then had to deal with the mess. This is going to launch, its just a matter of when imo.