September 26, 2025
Grayscale Solana Trust (SOL)
c/o Grayscale Investments, LLC
290 Harbor Drive, 4th Floor
Stamford, Connecticut 06902
Re: Grayscale Solana Trust
Ladies and Gentlemen:
We have acted as special Delaware counsel to Grayscale Solana Trust (SOL) (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 November 8, 2021, as amended by the Certificate of Amendment to the Certificate of Trust, as filed with the Secretary of State on November 23, 2021 (collectively, the “Certificate of Trust”);
(b)The Declaration of Trust and Trust Agreement of the Trust, dated as of November 8, 2021, between Grayscale Investments, LLC, as sponsor, and CSC Delaware Trust Company (formerly known as Delaware Trust Company), as trustee (the “Trustee”);
(c)The Second Amended and Restated Trust Agreement, dated as of September 22, 2025 (the “Amended and Restated Trust Agreement”), among the Trustee, Grayscale Investments Sponsors, LLC, as sponsor (the “Sponsor”), and the shareholders from time to time thereunder;