Davis Polk advised Grayscale Investments, LLC, as sponsor, in connection with the registration of the common units of fractional undivided beneficial interest (“Shares”) of Grayscale Ethereum Trust (ETH). The Shares were registered pursuant to a registration statement on Form 10. Grayscale Ethereum Trust’s Shares are publicly quoted securities solely invested in and deriving value from the price of Ethereum. Grayscale Ethereum Trust enables investors to gain exposure to the price movement of Ethereum through a traditional investment vehicle, without the challenges of buying, storing and safekeeping Ethereum. The Shares are quoted on the OTCQX under the ticker symbol “ETHE”.

Grayscale Investments, LLC is the world’s largest digital currency asset manager, with more than $5.9 billion in assets under management, as of September 30, 2020. Grayscale is headquartered in New York City.

The Davis Polk capital markets team included partner Joseph A. Hall and associate Hillary A. Coleman. The tax team included partners Lucy W. Farr and Patrick E. Sigmon and associate Alexander J. Hendin. Partners Jai R. Massari and Zachary J. Zweihorn provided financial institutions advice. Partner Gregory S. Rowland provided 1940 Act advice. Members of the Davis Polk team are based in the New York and Washington DC offices.