• DigitalX has been actively engaged in understanding digital asset laws for over a decade
• DigitalX's treasury strategy does not meet the definition of a managed investment scheme
• DigitalX's Bitcoin and Solana holdings are corporate assets, not investment products offered to investors

DigitalX Ltd (DCC.ASX) has provided a detailed response to an ASX query letter regarding its treasury asset management operations and treasury strategy. The company explains that it has been actively engaged in understanding the laws relating to the digital asset sector for over a decade, including through engagement with ASIC and legal advice. DigitalX states that the holding of Bitcoin and other digital assets is legal in almost all jurisdictions around the world, including Australia, and that its strategic allocation of cash assets into digital assets is undertaken in the same way a company may choose to convert some of its cash reserves into gold or other commodities. The company clarifies that it does not consider itself to be an issuer of an investment product that provides retail or other investors with exposure to crypto-assets. DigitalX's shareholders' rights attach only to their shares in the company, and do not extend to any entitlement to the company's Bitcoin or Solana holdings. The company also confirms that its treasury strategy does not meet the definition of a managed investment scheme under the Corporations Act. DigitalX's main undertaking remains businesses involved in the digital asset sector, including investing, product development and digital asset financial services, which has been the case since the company ceased its Bitcoin mining operations in 2016. The company outlines its objectives for increasing its Bitcoin holdings to 2,100 by 2027, including generating income through trading and monetization strategies, Bitcoin-backed lending and financing, and staking on the Bitcoin Lightning Network. DigitalX's board, senior management, and auditor collectively have deep cryptocurrency and digital asset expertise, with experience in overseeing an ASX-listed spot Bitcoin ETF and a corporate Bitcoin treasury program.

DigitalX aims to grow and monetize its Bitcoin holdings through the creation of Bitcoin-related products and services, as well as participating in the Lightning Network as a node staker. The company is evaluating opportunities such as trading and monetization of Bitcoin, Bitcoin-backed lending and financing, and staking on the Bitcoin Lightning Network.