November 12, 2025
Grayscale Chainlink Trust (LINK)
c/o Grayscale Investments Sponsors, LLC
290 Harbor Drive, 4th Floor
Stamford, Connecticut 06902
Re: Grayscale Chainlink Trust (LINK)
Ladies and Gentlemen:
We have acted as special Delaware counsel to Grayscale Chainlink Trust (LINK) (the “Trust”), a Delaware statutory trust, in connection with the matters set forth herein. This opinion is being delivered to you at your request.
We have examined and relied upon such records, documents, certificates and other instruments as in our judgment are necessary or appropriate to enable us to render the opinions expressed below, including the following documents:
(a)The Certificate of Trust of the Trust, as filed with the Secretary of State of the State of Delaware (the “Secretary of State”) on December 18, 2020 (the “Certificate of Trust”);
(b)The Declaration of Trust and Trust Agreement of the Trust, dated as of December 18, 2020, between Grayscale Investments, LLC, as sponsor, and CSC Delaware Trust Company, as trustee (the “Trustee”);
(c)The Second Amended and Restated Declaration of Trust and Trust Agreement, dated as of November 10, 2025 (the “Amended and Restated Trust Agreement”, among the Trustee, Grayscale Investments Sponsors, LLC (as successor in interest to Grayscale Investments, LLC), as sponsor (the “Sponsor”), and the shareholders from time to time thereunder;
(d)A form of the Authorized Participant Agreement to be entered into by the Sponsor, acting in its capacity as Sponsor of the Trust, The Bank of New York Mellon, a New York Banking corporation acting in its capacity as transfer agent of the Trust, and each authorized participant (the “Authorized Participant Agreement”);
(e)Amendment No. 1 to the Registration Statement on Form S-1 (the