Core Viewpoint - Strategy (MSTR) has formally responded to MSCI's proposal to exclude companies with digital asset holdings representing 50% or more of total assets from MSCI Global Investable Market Indexes, arguing that such a move is unjust and detrimental to the industry [1][4]. Group 1: Company Positioning - Strategy asserts that it operates as a digital asset treasury company (DAT) that utilizes digital assets as productive capital rather than merely tracking price movements [2]. - The company emphasizes that it builds bitcoin-backed credit instruments, manages an active corporate treasury program, and maintains a global enterprise analytics software business, indicating a diversified operational model [2]. - Strategy claims that investors are buying into the company's strategy and management, not just a passive investment in bitcoin [2]. Group 2: Response to MSCI Proposal - The company argues that the proposed 50% threshold for exclusion is arbitrary and unworkable, noting that other industries with concentrated reserves, such as oil and real estate, remain eligible for MSCI indices [3]. - Strategy contends that the proposal injects policy views into index construction at a time when federal policy is shifting to support digital asset innovation, warning that exclusion could lead to significant passive capital outflows and hinder American competitiveness [4]. - The company urges MSCI to extend the consultation period and provide a more detailed rationale for any proposed changes, highlighting the potential negative impact on the expansion of new financial technologies [4]. Group 3: Company Structure - Strategy is organized as a conventional operating company and does not have a fund or exchange-traded product (ETP) structure [5]. - The company is not classified as an investment company under applicable laws and does not create fund-like tax treatment for investors [5]. - Strategy has a long history as an operating software business, reinforcing its identity as a traditional operating entity rather than an investment fund [5].