How to make the current ATM even "Smarter" I've been thinking about this for a while, but yesterday’s RNS reinforced how responsive and nimble the SWC team is and they’re clearly open to feedback, which is great. I know they are in the constant process of evaluating the structure so this is just my feedback which may already have been considered in some format. TL;DR: The current ATM design feels too static. It should be more dynamic, designed to respond to real time volatility and price action, especially when the stock trades at elevated mNAV multiples. That flexibility could allow the company to capitalize on price spikes and reduce dependence on perfect daily timing. Volatility = Opportunity By my calculations, SWC’s 30-day realized volatility is over 300%, meaning it moves on average ~18% per day (absolute terms) making it the highest vol stock in the UK. As we know, "volatility is vitality" and this kind of price action is a feature, not a bug, but only if the ATM is structured to capture it. The current ATM framework Right now, the ATM has two main rules: 1) No selling below the previous day's close, 2) Capped at 20% volume. These constraints made sense initially, a cautious approach that avoids missteps in execution and incorrect FUD that $MSTR often saw (ATM is compounding pressure on down days). But with the current volatility, what we've learned since its launch and the evolving liquidity profile, this framework feels a little too rigid. It misses opportunities to issue into temporary over-extensions where the stock trades at significantly elevated mNAV multiples, even if just for a few hours or a single day. There is a lot of scope to amend it and make it super constructive. Let's walk through an example Say $SWC closes at 250p. The next day, due to broad market news (e.g. Fed cut interest rates more than expected), the stock jumps to 350p (+40%), trading well above recent mNAV levels. Under current rules, the company can sell into this strength. But if the following days assume the market can't hold the gains and the stock retraces 10% to 315p, then drops another 10% the next day to 283p, and then 255p the next day, we’ve been unable to sell, even though the stock was still trading above where it was before the rally. Why? Because we’ve hard-coded a rule that says, "only sell above the previous day's close." That means we've tied our own hands and missed the opportunistic window to issue equity at highly accretive levels. One of the best trading lessons I ever got was: “Trade when you can, not when you have to.” There will be moments when real liquidity appears, either on the order book or OTC, and Shard should have the flexibility to act. Taking the example above, if the stock closed at 350p and the next day opened with a 345/355 spread and we had a buyer bidding for a large block at 345 (bid side), the current rules would still prevent execution. That’s a missed opportunity. What's the solution? A more dynamic matrix that allows for flexibility A dynamic matrix that evaluates net price movements rather than just previous day closes. Example, If the stock was +30% the day before, maybe we can still sell even if it's -10% the next day (still +20% net). Or +10% yesterday, -5% today = still +5% overall. Consider mNAV multiples as the gating factor, not just price. For example: "Can sell so long as mNAV > 3x", regardless of day to day price shifts. Possibly allow limited volume issuance on down days if stock remains at attractive mNAVs. E.g., allow 5–10% issuance on lower days if accretion is high. Or there could be rules around the volume cap that allow us to be flexible around the 20% cap. E.g for OTC trades, there is no volume cap - taking the example above, if the closing price was 350p and we had an opportunity to do a 5m share block the next day at the open at 345p (based off a 345/355 spread), we should be allowed to capture that. Why this matters now? Right now, $SWC is in the critical stage of getting from 1000 to 10,000 BTC and reaching a level where the balance sheet is strong enough to issue other capital market instruments (e.g preferreds) that can take pressure off an ATM facility. Moreover, the stock is trading at ~3.5x mNAV, which is still extremely accretive. While increased flexibility might temporarily cap the share price, the ATM is our primary weapon and using it aggressively is part of the "growing pains" needed to get enough bitcoin at this crucial stage. Remember, the more Bitcoin we have on balance sheet, the more sustainable this path becomes towards reaching key milestones. As such, given the stock’s volatility, a more dynamic approach makes sense. Smarter Web have done an amazing job to date and shown they’re open to feedback given how quickly market conditions are changing and what we're learning each day. Moreover, this is definitely something they could explore with Shard and Tennyson, who are also incentivized to optimize execution and innovate around structure given the fees they receive. Happy to hear feedback, Jamie @asjwebley @Croesus_BTC