Crypto and digital assets

The Registrant directs the Staff to the disclosure at the end of the first paragraph of the referenced risk factor, which is set forth below: Chainlink has exhibited a historical annualized volatility of 104.63% and maximum annual price decrease of 85.87% over the past five years. November 18, 2025 Page 3

The Registrant respectfully acknowledges the Staff’s comment and notes that, under normal circumstances, the Fund’s portfolio holdings are consistent with the Fund’s “Principal Investment Strategies” section of the Prospectus. The Registrant notes that the Fund’s portfolio holdings as of December 31, 2024 were a result of an unusual circumstance that the Fund does not believe will be repeated, which is that the Fund was required to distribute approximately 31% of its total net assets. The Fund utilizes a long-flat trend-following strategy in which its portfolio is rotated between 100% exposure to Bitcoin Futures Contracts and 100% exposure to U.S. Treasury Securities. Accordingly, the Fund will either be: (1) long Bitcoin Futures Contracts with approximately 100% exposure to Bitcoin Futures Contracts; or (2) flat Bitcoin Futures Contracts and long U.S. Treasury Securities with…

The Registrant respectfully notes that the Funds utilize a “long-flat” trend-following investing strategy pursuant to which the Funds’ exposure alternates between 100% exposure to crypto asset Futures Contracts and 100% exposure to U.S. Treasury Securities. A long-flat strategy takes a long position when a trend is detected, seeking to take advantage of an anticipated increase in an asset’s value. However, when a downward trend is detected, the strategy exits the position and remains in cash or cash equivalents. The Funds' strategy is based upon a quantitative, proprietary signal that compares the respective crypto assets' 10-day and 20-day exponential moving average price, with a focus upon the price movement of Ether. The exponential moving average applies a weighting factor to each price point to give more weight to recent data to respond to new price changes and trends. The…

We have revised the disclosure on page 5 to include the requested information. We note that the dollar amount involved in the transactions with the related party through the date hereof totals $12,377, which is less than the $120,000/1% of the average assets threshold threshold under Item 404(d) of Regulation S-K. Although this transaction is not disclosable as a related party transaction, with the inability to speak with the Staff, Beeline elected to include the requested information. Risk Factors The sale or issuance of our common stock to C/M will create dilution, page 7

Pursuant to the Staff’s comment, the Registration Statement has been updated to reflect the revisions referenced in the prior comment.

In response to the Staff’s comments, the Company has revised its disclosure to update its description of its CheerReal platform beginning on page 10 of Amendment No. 1 to Form F-3. The Company also clarifies that CheerReal is not a secondary trading market for NFT, but is a digital collection platform for the initial issuance of digital artwork NFTs. The CheerReal platform is designed as a digital art collection platform that is part of the Company’s CHEERS ecosystem, which aims to bring a new immersive experience of digital arts. The Company considers the use of NFTs as a means of authentication of the artwork and to display the rights of the digital artwork. The Company further clarifies that the NFT artworks on the CheerReal platform are sold by thirty-party artists which are authorized through license agreements entered into by the Company or are NFT artworks which are created by…

As discussed above in the Company’s response to the Staff’s comment 1, CheerReal is a platform for the initial issuance of digital artwork NFTs. While users are allowed to exchange NFTs with other users, no secondary transactions are allowed to be conducted on CheerReal and CheerReal is not a secondary market of NFTs. The Company respectfully submits that the issuance of NFTs on its CheerReal platform are not created for the purpose of investment of money in a common enterprise with the expectation of profits due to the efforts of others. June 24, 2024 Page 3 Currently the NFTs available on CheerReal are digital artwork collections which can be purchased and/or traded only on CheerReal. The Company charges (i) fees in RMB for the sale of original NFT artworks which was created by the Company, (ii) a commission fee in RMB for NFT artwork collections licensed by third-party artists to…

In response to the Staff’s comments, the Company has revised its risk factor disclosure on page 27 to remove such language.

In response to the Staff’s comments, the Company confirms that it does not hold any digital assets.

The Trust has made the requested change with respect to both the Ethereum Custodian and the Prime Broker. The Trust and the Sponsor, however, expect that the Trust’s ether transactions will be conducted over the counter with counterparties selected by the Execution Agent. As a result, neither the Sponsor nor the Execution Agent expects to utilize the Prime Broker to acquire and dispose of either on behalf of the Trust or in connection with paying the Trust’s expenses. Pre-Effective Amendment No. 3 includes the following as a new risk factor in the section titled “Risk Factors—Risks Related to the Trust and the Shares:” The Trust’s Prime Broker or Ethereum Custodian could become insolvent or become subject to a receivership or bankruptcy proceeding, which may result in a loss of or delay in access to Trust assets. In the event of an insolvency or bankruptcy of the Prime Broker (in the…

Pursuant to the Staff’s comment, the referenced disclosure has been revised as set forth below: On March 13, 2024, the Ethereum network underwent a planned fork called “Dencun” implementing a series of EIPs. EIP 4844, which some commentators perceive to be the most significant EIP within the Dencun series, is intended to improve the economics of Layer 2s by reducing transaction fees for Layer 2s who batch transactions executed on the Layer 2s and upload them as a batch (or as a single proof) onto the main Layer 1 Ethereum network. Among other objectives, the Dencun software upgrade was designed to provide Layer 2 scaling solutions a designated storage space on the Layer 1 Ethereum network, called Binary Large Objects (“blobs”), which attach large data chunks to transactions on the Layer 1 Ethereum network and are recorded on its blockchain. The data in blobs become inaccessible on the…

The Company acknowledges the Staff’s comment and has set forth below each item followed by the Company’s response. • Tell us when you began purchasing small amounts of cryptocurrency to support your business operations. The Company respectfully advises the Staff that it began purchasing small amounts of cryptocurrency in order to support its day-to-day business operations (as described below) in 2018, shortly after it launched its Robinhood Crypto feature. 1 The Company began to maintain a balance of USDC as a backup settlement method for weekend transactions (as described below) starting in May 2023 in response to the failure of several banks that had supported its cryptocurrency liquidity during weekend hours, although the Company had not then experienced (and has not since experienced) any failures in its routine cryptocurrency settlement transactions. • Tell us the dollar amounts…

The Company intends to revise the disclosure that appeared on page 60 of its Form 10-K for the fiscal year ended December 31, 2023 as follows (with additions shown as bold, underlined text): “Based on the terms of our user agreement, the structure of our crypto offerings, and applicable law, and, although we have not obtained a formal legal opinion on this matter, after consultation with internal and external legal counsel, we believe that the cryptocurrency we hold in custody for users of our platform should be respected as users’ property (and should not be available to satisfy the claims of our general creditors) in the event we were to enter bankruptcy.” Management’s Discussion and Analysis of Financial Condition and Results of Operations Key Performance Metrics, page 80

The Company respectfully acknowledges the Staff’s comment and advises the Staff that the statement is based on Devvio’s internal analysis, and it has removed the relevant disclosure from the Amended Registration Statement. Devvio Blockchain, page 227

We respectfully advise Staff that management of the Company has decided not to hold Ethereum (ETH) and has since sold all of its ETH. However, the Company may continue to hold USDC and/or USDT and may accept USDC and USDC from its investors and use such stablecoins to pay service providers. Please see amended disclosures on pages 23, 32 and 34. We are subject to risks related to holding cryptocurrencies, page 24

We respectfully advise the Staff that the Company has amended the disclosure on page 26 to address the above. LEWIS BRISBOIS BISGAARD & SMITH LLP www.lewisbrisbois.com June 6, 2024 Page 3 Management’s Discussion and Analysis Corporate Developments, page 32

In response to Staff’s comments regarding the cost basis for ETH, the Company has disclosed the number of units held, the cost basis and fair value for both ETH and USDT on page F-17 and F-40.

The Trust confirms that the requested disclosures are generally included in each Fund's Prospectus in response to Item 9 in a section entitled "Ether and Ether Futures Risk – Largely unregulated marketplace" but have been revised to fully address the Staff's comment (and Comment 76) as follows: 24 Largely unregulated marketplace – Ether, the Ethereum Network and digital asset trading venues are relatively new and, in most cases, largely unregulated and may be operating out of compliance with applicable regulations . As a result of this lack of regulation, individuals, or groups may engage in insider trading, fraud or market manipulation with respect to ether. Such manipulation could cause investors in ether to lose money, possibly the entire value of their investments. Over the past several years, a number of digital asset trading venues have been closed due to fraud, failure or…

The Trust confirms that the requested disclosures are included in each Fund's Prospectus in response to Item 9 in a section entitled "Ether and Ether Futures Risk – The regulatory environment relating to ether and ether futures" which states: The regulation of ether, digital assets, digital asset trading venues, and related products and services continues to evolve. The inconsistent and sometimes conflicting regulatory landscape may make it more difficult for ether businesses to provide services, which may impede the growth of the ether economy and have an adverse effect on adoption of ether. In addition, certain ether businesses may be operating out of compliance with regulations. Future regulatory changes or enforcement actions by regulatory authorities may alter, perhaps to a material extent, the ability to buy and sell ether and ether futures. Similarly, future regulatory changes or…

The Trust confirms that the requested disclosures are generally included in the summary section of the Prospectus for each Fund in the principal investment risk entitled "Ether Risk" which states: Ether is a relatively new innovation and is subject to unique and substantial risks. The market for ether is subject to rapid price swings, changes and uncertainty. A significant portion of the demand for ether may be the result of speculation. Such speculation regarding the potential future appreciation of the price of ether may artificially inflate or deflate the price of ether and increase volatility. Disclosures that "trading and investing in crypto assets generally may not be based on fundamental analysis" are provided in response to Item 9 in a section entitled "Ether and Ether Futures Risk – The regulatory environment relating to ether and ether futures" which states: Trading and…

The Trust confirms that the requested disclosures are generally included in the principal investment strategies described in the summary section of the Prospectus for each Fund which states: From time to time, the developers suggest changes to the Ethereum software. If a sufficient number of users and validators elect not to adopt the changes, a new digital asset, operating on the earlier version of the Ethereum software, may be created. This is often referred to as a "fork." The price of the ether futures contracts in which the Fund invests may reflect the impact of these forks. In addition, examples of such forks are included as a response to Item 9 in the risk entitled "Ether and Ether Futures Risk – Forks" which states: The open-source nature of the Ethereum Protocol permits any developer to review the underlying code and suggest changes. If some users and validators adopt a change…

The Trust has revised the Amendment as requested by adding the following to the "Ether Risk" included in the summary section of the Prospectus for each Fund: Legal or regulatory changes may negatively impact the operation of the Ethereum Network or restrict the use of ether. In addition, digital asset trading venues and other participants may have significant exposure to other digital assets. Instability in the price, availability or legal or regulatory status of those instruments may adversely impact the operation of the digital asset trading venues and the Ethereum Network. As a result, events that are not necessarily related to the security or utility of ether can nonetheless cause a significant decline in the price of ether (e.g., the collapse of TerraUSD in May 2022 and FTX Trading Ltd. in November 2022).

The Trust has revised the disclosure as requested.

The Trust has revised the disclosure on page 24 as requested as noted in response to Comment 45. In addition, the Trust has revised the "Ether Risk" in the summary section of the Prospectus for each Fund as follows: Unlike the exchanges for more traditional assets, such as equity securities and futures contracts, ether and ether trading venues are largely unregulated and may be operating out of compliance with applicable regulation . As a result of the lack of regulation, individuals or groups may engage in fraud or market manipulation (including using social media to promote ether in a way that artificially increases the price of ether). The Trust has made similar revisions to the section in Funds' SAI entitled "Ether Related Investments" including: Ether, the Ether Network and ether trading venues are relatively new. and not subject to the same regulations as regulated securities or…

The Company uses the term “on-chain” to refer to transactions that are initiated, negotiated, and settled on the Provenance Blockchain. The Company uses the term “off-chain” to refer to transactions that can be initiated, negotiated, or settled without using the Provenance Blockchain (by using a telephone or email, for example). We have revised the Registration Statement to reflect that settling transactions in Certificates will all take place on-chain and will delete language referring to off-chain transactions. These changes are needed because the technology underlying the Provenance Blockchain has developed such that functions originally designed to take place off-chain can now all be performed on-chain. As a result, there should never be situation where settling Certificate transactions occur off-chain. Transactions occurring on or through Figure Securities’ ATS can reasonably be…

The Company respectfully acknowledges the Staff’s comment and advises that it has considered the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP C&DIs (the “Non-GAAP C&DIs”). In Question 100.01 of the Non-GAAP C&DIs, the Staff notes that presenting a non-GAAP performance measure that excludes normal, recurring, cash operating expenses necessary to operate a registrant’s business is one example of a measure that could be misleading. Further, the Staff notes that when evaluating such non-GAAP adjustment, the Staff considers the nature and effect of the non-GAAP adjustment and how it relates to the company’s operations, revenue generating activities, business strategy, industry and regulatory environment. In 2022, the Company purchased digital assets (Bitcoin and Ethereum) as part of its treasury strategy and not as a revenue or operating income/loss…

Section 2(a)(1) Legal Analysis Section 2(a)(1) of the Securities Act of 1933, as amended (the "Securities Act"), defines a "security" as any note, stock, treasury stock, security future, security-based swap, bond, debenture, evidence of indebtedness, certificate of interest or participation in any profit-sharing agreement, collateral-trust certificate, preorganization certificate or subscription, transferable share, investment contract, voting-trust certificate, certificate of deposit for a security, ... or, in general, any interest or instrument commonly known as a "security." While digital tokens/coins are not specifically listed in the definition, it is possible that such assets could be considered investment contracts. The term "investment contract" is not defined in the Securities Act. In SEC v. W.J. Howey Co ., 328 U.S. 293 (1946), the U.S. Supreme Court determined that an…

The Trust respectfully notes that the Fund’s principal investment strategy disclosure states “The Fund will not directly invest in cryptocurrency and does not currently intend to invest in any entity whose primary business purpose is to provide exposure to cryptocurrency, but may have indirect exposure by investing in companies with exposure to cryptocurrency.” To seek to further clarify the Fund’s strategy, additional language has been added to the Prospectus. As a result, the entire reference will read substantially as follows: The Fund will not directly invest in cryptocurrency and does not currently intend to invest in any entity whose primary business purpose is to provide exposure to cryptocurrency, but may have indirect exposure by investing in companies with exposure to cryptocurrency. That is, the Fund may invest in companies whose businesses are related to crypto assets or…

In response to the Staff’s comment, we note the following: The SEALCOIN token features cannot yet be finalized for the reasons mentioned above (that is, completion of the technological PoC and development of service applications). Our R&D efforts involve an evolving PoC, leading to a proprietary Service Platform with ultimately a platform-dedicated cryptocurrency having the following potential attributes: - A utility feature intended to provide access digitally to an application or service provided on the proprietary platform by means of a blockchain-based infrastructure. - A payment feature intended to enable a means of payment for acquiring goods or services, as well as a means for transferring money or value. Based on the above R&D attributes of SEALCOIN cryptocurrency, we are studying the following Swiss FINMA guidelines…

In response to the Staff’s comment, we note the following: The SEALCOIN token features cannot yet be finalized for the reasons mentioned above (that is, completion of the technological PoC and development of service applications). Our R&D efforts involve an evolving PoC, leading to a proprietary Service Platform with ultimately a platform-dedicated cryptocurrency having the following potential attributes: - A utility feature intended to provide access digitally to an application or service provided on the proprietary platform by means of a blockchain-based infrastructure. - A payment feature intended to enable a means of payment for acquiring goods or services, as well as a means for transferring money or value. Based on the above R&D attributes of SEALCOIN cryptocurrency, we are studying the following Swiss FINMA guidelines…

The Trust confirms that the foregoing statement has been clarified accordingly.

The Trust confirms that references to cryptocurrency have been revised to “crypto asset” or “digital asset.” In addition, the Prospectus has been revised to include the foregoing clarifications. The Trust respectfully declines to add the crypto-asset related explanations to the Prospectus. However, such explanations have been added to the SAI. As noted above, the Fund’s investments in crypto asset-related futures contracts will be limited to 2% of the Fund’s total assets. As a result, including extensive crypto-asset related prospectus disclosures may potentially confuse investors about the extent to which the Fund may be exposed to such assets.

The Trust confirms that disclosure has been added indicating that the Fund will invest in crypto assets only indirectly through cash-settled futures contracts traded on the Chicago mercantile exchange. The Trust respectfully declines to include the other related disclosures in the Prospectus. As noted above, the Fund’s investments in crypto asset-related futures contracts will be limited to 2% of the Fund’s total assets. As a result, the Fund does not view such investments as rising to the level of a principal risk. The SAI has been revised to include the aforementioned information about the Fund’s crypto asset futures contracts and the additional descriptions noted above. Principal Investment Risks

The Trust respectfully declines to include the foregoing disclosures in the Prospectus. However, such disclosures have been added to the SAI. As noted above, the Fund’s investments in crypto asset-related futures contracts will be limited to 2% of the Fund’s total assets. As a result, the Fund does not view such investments as rising to the level of a principal risk, and has removed such disclosures from the Fund’s prospectus.

The Trust confirms that the foregoing clarifying language has been added to the Fund’s Prospectus.

In response to the Staff’s comment, the Company revised disclosure on page F-39 of the Amended Registration Statement to add the following: “Independent Reserve SG Pte Ltd (“Independent Reserve”), Philippine Digital Asset Exchange (“Pdax”), Betur, Inc. (“Coins.ph”) and Bitstamp Global Limited (“Bitstamp”) (collectively, the “Cryptocurrency Exchanges”) are centralized crypto exchanges which keep the cryptographic keys for each respective XRP wallet and provide the Company with its respective API access keys. The Company is the only party that holds the API access keys that grant it direct access to its XRP wallet maintained on the respective Cryptocurrency Exchange. The Cryptocurrency Exchanges maintain records of all assets deposited by its users and send statements to the Company. The Company reconciles its internal ODL transaction records to the statements received from the…

In response to the Staff’s comment, Seamless revised Note 21. “Related Party Transactions” beginning on page F-55 of the Amended Registration Statement to disclose both the nature of Tranglo’s Master XRP Commitment to Sell Agreement and GEA’s Master XRP Commitment to Sell Agreement. The amended disclosure also includes the balance of XRP deposits in Tranglo and GEA’s crypto wallets at each reporting period, as well as the maximum limit specified in each agreement. General

The Sponsor advises the Staff that, prior to the Record Date, it will declare an in-kind dividend on the GBTC Shares, in the form of a distribution to GBTC Shareholders as of the close of trading on the Record Date, with BTC Shares serving as a vehicle to distribute the underlying Bitcoin corresponding to the BTC Bitcoin Portion, which dividend will be conditional on the BTC Trust Registration Statement having been declared effective by the Staff on the Record Date. Assuming that such condition is satisfied as of the Record Date, then on the Distribution Date, GBTC will distribute BTC Shares to GBTC Shareholders as of the Record Date. In this regard, the Sponsor advises the Staff that Section 3805 of the Delaware Statutory Trust Act, to which the GBTC Trust is subject, states that “at the time a beneficial owner becomes entitled to receive a distribution, the beneficial owner has the…

The Sponsor has revised the disclosure on pages 22-24 of the Information Statement in response to the Staff’s comment. Incorporation of Certain Information by Reference, page 25

See attached Exhibit I.

The 10-K/A reflects the removal of this disclosure. 2 Revenue Recognition, page 34

The customer in our bitcoin mining transactions is our mining pool operator. Our Revenue Recognition disclosure has been revised in the 10-K/A and states, “[t]o generate revenue from mining bitcoin, the Company has entered into digital asset mining pools by executing contracts, as amended from time to time, with the mining pool operators to provide computing power to the mining pool.” · Confirm if mining pool in which you participate utilizes the Full Pay Per Share (FPPS) payout method;

The Sponsor has addressed each of the Staff’s comments as follows: • Revise the third paragraph of your introduction and the first paragraph of Note 1 to the unaudited pro forma financial statements to reflect the current requirements of Rule 11-02 of Regulation S-X. In this regard, pro forma financial statements are no longer limited to adjustments that are directly attributable to the transaction for which pro forma effect is being given, being factually supportable and, with respect to a statement of comprehensive income, expected to have a continuing impact; and The Sponsor has revised the disclosure on pages 60 and 64 of the Registration Statement in response to the Staff’s comment. • We are unable to recompute all the amounts presented in your pro forma financial statements based on the description of all pro forma adjustments in Note 3. Address the following: • Separately provide…

The Sponsor has addressed each of the Staff’s comments as follows: • Provide us with your accounting analysis and reference authoritative guidance to support your determination to account for the transaction as a sale under U.S. GAAP instead of a spinoff considering that you acknowledge that Grayscale Bitcoin Trust (GBTC) and Grayscale Bitcoin Mini Trust (BTC) will have a parent-subsidiary relationship immediately prior to the Initial Distribution on the Distribution Date; May 8, 2024 4 In accounting for the Initial Distribution, the Sponsor has primarily considered the following authoritative guidance: (i) ASC 350-60 – Intangibles – Goodwill and Other – Crypto Assets, (ii) ASC 610-20 – Other Income – Gains and losses from the derecognition of nonfinancial assets, (iii) ASC 606 – Revenue from contracts with customers, (iv) ASC 810 – Consolidations, (v) ASC 505 – Equity and (vi) ASC 805…

Below we outline responses to the Staff’s comments on 1) the process of non-custodial staking, 2) information included on our website, and 3) information included in our staking instructions. We believe the information we have provided in response to the Staff’s comment supports the accuracy and consistency of the disclosures we have made in our Form 10-Ks and in other public materials. Non-custodial Staking Process The following outline details the typical process involved in non-custodial staking, highlighting key steps and considerations. Each blockchain and digital wallet may have its nuances, so crypto asset holders are encouraged to familiarize themselves with specific guidelines and rules pertinent to their a specific blockchains, wallets and assets. 1. Crypto Asset Custody : Investors must hold their crypto assets in digital wallets that support staking. These assets cannot be…

We plan to revise the disclosure in future filings to remove mention of the number of Delegators, as follows: “a critical component of our growth strategy is to increase the number of Delegators and amount of crypto assets delegated to our validator nodes including our own” 5 Due to variations in blockchain explorers across blockchain networks, we often lack reliable historical data on the count of Delegators at any specific date. As a result, we have determined that the number of Delegators is not a material metric for us, in part because of the unreliability of this data. Consequently, we have ceased monitoring and tracking the number of Delegators internally, and we have decided it is appropriate to exclude the “number of Delegators” as a metric in our growth strategy disclosures. However, we note that we do have reliable data regarding the total number of delegated assets and their…

We plan to revise our accounting policy and disclosure to reflect the use of our principal market as our pricing source in our upcoming Form 10-Q, as well as in future filings, in consideration of the Staff’s comments. We will discontinue the use of CoinMarketCap as our primary pricing source, despite our belief in its reliability, and instead utilize pricing data from our primary and secondary markets, Kraken and Coinbase, respectively. The following enhanced disclosure will be included in the Crypto Assets – Fair Value Measurement section of Note 3 - Summary of Significant Accounting Policies: “The Company’s accounts for the fair value measurement for its crypto assets in accordance with ASC 820, Fair Value Measurement. ASC 820 defines fair value as the price that would be received for an asset in a current sale, assuming an orderly transaction between market participants on the…

The following accounting analysis evaluates whether the arrangements entered into between the Company and Foundry Digital LLC (“Foundry”) and the Company and Cantaloupe Digital LLC (“Canaan”) (collectively, the “Hosting Contracts”) contain a lease for the Bitcoin miners delivered to the Company’s Panther Creek power plant under ASC 842, Leases . In the context of this ASC 842 lease evaluation, please note the Company represents the customer, and Foundry and Canaan represent the suppliers (i.e., Foundry and Canaan supply the hosted Bitcoin miners to the Company). The first step in applying the lease accounting standard is to determine if the contract is or contains a lease. ASC 842-10-15-3 defines a lease as follows: “ A contract is or contains a lease if the contract conveys the right to control the use of identified property, plant, or equipment (an identified asset) for a period of…

Please refer to our comprehensive accounting analysis above that addresses each of the five steps outlined in ASC 606-10-05-4, including this specific comment on page 9 above. • With regards to step one in ASC 606-10-05-4: o Expand your analysis to more fully address ASC 606-10-25-1 through 25-9.

The following disclosure in the Fund’s prospectus has been amended as shown below: Bitcoin and ether are both digital assets that are designed to be alternative forms of payment. Although these digital assets are designed to be alternative forms of payment they have not widely been accepted as such.

The Trust responds by referring to the response to Comment 1 and also confirming that references to cryptocurrency have been amended.

The following disclosure in the Fund’s SAI has been amended as shown below: As a result of the lack of regulation, individuals or groups may engage in fraud or market manipulation and in some instances may be operating in violation of existing regulations (including using social media to promote bitcoin in a way that artificially increases the price of bitcoin or ether)

The following disclosure in the Fund’s prospectus has been revised as shown below: Bitcoin and Ether may experience very have been subject to high volatility and related investments, such as Bitcoin and Ether futures, may be affected by such volatility. Bitcoin and Ether are each a relatively new innovation and the market for Bitcoin and Ether is subject to rapid price swings, changes and uncertainty, which is also dependent on significant speculation. The further development of the Bitcoin and Ethereum networks and the acceptance and use of Bitcoin and Ether are subject to a variety of factors that are difficult to evaluate. * * * * I trust the above responses and revisions adequately address your comments. If you have any additional questions or require further information, please contact Ryan Charles at (480) 964-6008. Sincerely, /s/ Jon C. Essen Trustee, Treasurer and Principal…

The Registrant respectfully notes that Post-Effective Amendment No. 259 specifically related to two portfolios of the Registrant - Passport Overseas Equity Portfolio and Emerging Markets ex China Portfolio (each, a “Subject Fund”). The Registrant also respectfully notes that the Registrant’s Statement of Additional Information included in Post-Effective Amendment No. 259 included disclosure for all portfolios of the Registrant. As indicated in the “Investment Policies and Strategies” section of the Statement of Additional Information and in the “Bitcoin Exposure” disclosure, neither Subject Fund currently anticipates obtaining exposure to Bitcoin via cash-settled futures traded on the Chicago Mercantile Exchange or via other means. 2

The Registrant respectfully acknowledges the comment and, with respect to other portfolios of the Registrant that may obtain exposure to Bitcoin, will consider making the requested revision in connection with a future annual update. Please also refer to the response to Comment 3 above.

The Registrant respectfully acknowledges the comment and, with respect to other portfolios of the Registrant that may obtain exposure to Bitcoin, will consider making the requested revision in connection with a future annual update. Please also refer to the response to Comment 3 above. * * * If you would like to discuss any of these responses in further detail or if you have any questions, please feel free to contact me at (212) 698-3526 (tel). Thank you. Best regards, /s/ Allison Fumai Allison Fumai 3

The Company respectfully acknowledges the Staff’s comment and advises the Staff that it confirms its previous response—that there is no native coin that serves as the engine for the DevvX blockchain. The use of DevvX by DevvStream does not involve or require the integration of any token or other type of crypto asset to support its functionality. As disclosed in the Registration Statement, DevvStream intends to use DevvX as a SaaS product similar to Amazon's AWS technology product/service. DevvE is an ERC-20 token and is maintained on Ethereum. DevvStream does not utilize the DevvE token, or any token, in connection with DevvStream’s use of the DevvX blockchain, and DevvStream blockchain does not interact with nor is it interoperable with the DevvE token, or any token. Whenever DevvStream uses DevvX, DevvStream operates its own blockchain unrelated to any other DevvX user's blockchain.…

The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has amended its disclosure on pages 227 - 228 of the Amended Registration Statement to provide more detail regarding how DevvStream’s utilization of the DevvX blockchain works. The Company respectfully advises the Staff that DevvX provides an independent blockchain for any application. DevvStream will therefore have its own blockchain, which will be used in conjunction with DevvStream’s platform to store all relevant data related to the generation of carbon credits, including project design documents, quantification methodologies, validation and verification reports, project/program specific data and registry credit issuance. The consensus mechanism for validating transactions is permissioned (i.e., only DevvStream and algorithms managed by DevvStream are granted permission to participate in the…

The Company respectfully acknowledges the Staff’s comment and advises the Staff that DevvStream’s use of the DevvX blockchain can be thought of as a datastore (similar to a database, another type of datastore). The datastore maintains time-ordered immutable data. The use of the datastore does not involve any type of digital asset. The following is a step-by-step example that explains how data is written to DevvStream’s blockchain. 1. DevvStream determines the format of a required type of record. By way of example, the record could be of an Internet-of-Things (“IOT”) device ID and a related measurement from the device (“Measurement Value”). 2. DevvStream uses an API call to define a representation of that record structure, which is recorded in the JavaScript Object Notation format. To further illustrate the example above, the representation would be “IOT device ID: [variable id per…

The Company respectfully acknowledges the Staff’s comment and advises the Staff that one of the criticisms of blockchain software, as a category, is its high energy use and the resulting CO2 output, and that the Company compares the DevvX blockchain to the Bitcoin blockchain to point out that the DevvX blockchain’s approach does not face the same energy use and CO2 output concerns. The Company has chosen the Bitcoin blockchain in particular for comparison as it is one of the publicized applications of blockchain software (and is within one of the most publicized categories of applications of blockchain software, cryptocurrency), and as such, the Company believes that it serves as a helpful frame of reference for investors, given its familiarity. We respectfully request the Staff’s assistance in completing the review of the Registration Statement, as amended, as soon as possible. Please…