Crypto and digital assets

8. Refer to your response to prior comment 7. In your revised disclosure on page 231, you state that “dividends or other distributions to holders of blockchain stock through blockchain-based representations delivered to holders' wallets (including, at [your] election, in a dollar-based digital asset).” Please revise to clarify what you mean by “blockchain-based representations” and identify or further describe the characteristics of the “dollar-based digital asset” you may use for dividends or other distribution to holders of blockchain stock.

Comment 3. In the Purchase and Sale of Fund Shares section, the Fund’s prospectus states, “[a]lthough the Fund does not currently employ blockchain technology or invest in crypto or digital assets, DAP Class shares are expected to be purchased and held primarily through Financial Intermediaries that intend to use blockchain technology to maintain a record or a mirror record of share ownership for their customers.” Please supplementally explain the meaning of this disclosure and consider revising the disclosure as applicable. Please also explain whether the Fund anticipates tokenizing the DAP Class and whether the Fund intends to obtain reserve assets for stablecoin issuers.

Comment: Why does the Trust want to launch the Fund if it cannot track the S&P Cryptocurrency Top 10 Index?

Comment : Please review and revise the meme coin series and consider using consistent terminology when referencing meme coins rather than using tokens or cryptocurrencies.

Comment : The Staff notes the disclosure states that Bonk is the native meme cryptocurrency of the Solana blockchain. Please clarify whether it is THE native cryptocurrency of the Solana blockchain or if its merely built on Solana.

1. We note your disclosure that you have adopted a Treasury Policy under which the principal holding in your treasury reserve on the balance sheet will be allocated to digital assets, starting with SOL, as well as your disclosure that you do not intend to allocate treasury assets to other digital assets in the near term. We also note that the financial statements included in your Form 10-Q for the period ended September 30, 2025 include USDC and USDT holdings. Please revise your disclosure to: ● Provide greater details regarding any plans to acquire and hold digital assets, including in what proportions and the anticipated timeline. In addition, please revise to provide a definition or more detailed explanation for what you mean by the term “digital assets.” Please ensure that your revised disclosure clarifies the scope of the term and the type of digital assets it may cover, as well as…

2. Please revise to provide additional disclosure regarding SOL and your staking plans. For example purposes only: ● Disclose your policies and procedures regarding your plans to stake Solana, including how much of your SOL you intend to stake. ● Revise to provide greater detail explaining how agreements with staking providers will operate. ● If material, add a risk factor addressing any liquidity risks related to your staking plans. ● Identify the custodians that hold and will hold your digital assets and disclose the material terms of the custody arrangements, including the amount and limitations of any insurance coverage.

8. With respect to Defiance Daily Target 2X Short BITF ETF only (page 35), in its disclosure of risks, please include risks related to bitcoin, such as “bitcoin mining risk” “bitcoin supply risk”, “miner collusion risk” and bitcoin, blockchain and other digital assets risk.”

9. With respect to Defiance Daily Target 2X Short CLSK ETF only (page 45), the disclosure states that CLSK operates as a bitcoin mining company. Please include risks related to bitcoin mining companies in the Fund’s disclosure of risks.

2. In each Fund’s Principal Investment Strategies section, the term “Crypto Assets” refers to between 2 and 4 specific Crypto Assets for which each Fund’s Target Portfolio will seek daily leveraged investment results corresponding to two times (2X) the returns of such assets. However, the Staff notes that each Fund’s Target Portfolio Selection section states that the Fund intends that its Target Portfolio “gain exposure to up to 10 Crypto Assets.” Please clarify throughout the disclosure for each Fund the scope of the defined term “Crypto Assets.” As the Fund states it will not invest directly in Crypto Assets, please more clearly describe the distinction between “Crypto Assets” and the types of investments utilized in the Target Portfolio to gain exposure to such “Crypto Assets.”

4. In correspondence, please explain to the Staff how the Funds anticipate obtaining consistent exposure on a daily basis through swaps, options or other derivatives, which may have durations longer than a day, particularly in light of potentially material changes to market caps and weightings that may occur daily or otherwise on a frequent basis (e.g., as the result of large swings in the value or market cap of one Crypto Asset relative to others).

5. With respect to the Quantify 2X Daily AltAlt Season Crypto ETF, which includes only two identified Crypto Assets within its Target Portfolio – Solana and Ripple – provide an example of how exposure to such Crypto Assets will be allocated pursuant to the 50% market cap limit applied to the Target Portfolio.

Comment : Please explain the relevance of the section Description of Bitcoin, the Bitcoin Blockchain, relationship of Bitcoin to the Bitcoin Blockchain, or consider adding a heading for Information about Strategy that would include the 2 prior paragraphs of disclosure for Strategy. Consider adding a heading for Information about Strategy and including Description of Bitcoin, the Bitcoin Blockchain, relationship of Bitcoin to the Bitcoin Blockchain as a subheading.

Comment : The Staff requests that the risk be tailored for the Fund. The risk discusses Strategy’s reliance on sales of its products to cryptocurrency miners. Does Strategy sell anything? Does it apply?

Comment : The risk states that the Fund may have exposure to cryptocurrencies, please change “may” to “will” have exposure to cryptocurrency.

Comment : The Staff requests that the risk be tailored for the Fund. The risk discusses NVIDIA’s reliance on sales of its products to cryptocurrency miners. Does it apply?

Comment : The Staff requests that the risk be tailored to the Reference Asset. The risk discusses Coinbase’s reliance on sales of its products to cryptocurrency miners. Does it apply? The risk also discusses buying bitcoin but that is not part of Coinbase’s business.

Comment : On EDGAR page 37, in the sub-section titled: Industry Focus Risk - Digital Asset Sector Risk, the Staff notes in the third paragraph, the use of the term “digital asset exchanges.” Please do not refer to such trading platforms as “exchanges” to avoid confusion with regulated national securities exchanges.

14. Comment : Please add a discussion of the following additional risks associated with ETPs: (A) Ethereum ETPs are subject to management fees and other fees that may increase their costs versus the costs of owning ether directly. (B) Ethereum ETPs generally determine the price of ether by reference to a benchmark rate or index, and therefore may not reflect the global price of ether, or the price of ether on any one digital asset trading platform. (C) In the event the price used by the Ethereum ETP deviates from the global price of ether, the Fund’s returns may be adversely affected.

1. We note your disclosure that you have already launched your treasury reserve asset strategy using Ethena governance tokens ("ENA") as well as your disclosed existing holdings of 40 ETH and 12 BTC. Please expand your disclosure to describe whether you plan on integrating cryptocurrencies into your FlexTV operations. If so, please revise to state how you plan to treat the cryptocurrency received in connection with business operations, including, if applicable, how you plan on using digital assets to support your streaming customers. Lastly, please make corresponding changes to your Risk Factors, as appropriate.

2. We note your disclosure that as part of your Digital Asset treasury strategy, you will have significant investments in ENA, BTC, ETH, and other Digital Assets. Please expand your disclosure to: ● Provide a discussion of the material aspects of your treasury strategy and how you intend to generate profit through this strategy. ● Quantify the amount of Digital Assets the company intends to acquire and hold, and in what proportions. If the company has not yet identified all of the Digital Assets, disclose when and how the company plans to identify the particular Digital Assets it expects to acquire and hold. As appropriate, please also update your use of proceeds disclosure accordingly. ● Provide a discussion of “tokenomics” discussing the past and current supply of the Digital Assets you hold or intend to acquire and hold, how they are created, any burn mechanism, the amount locked up…

3. Please identify the third-party advisors, if any, involved in the execution of your ENA treasury strategy, how you determined to retain or engage with them, and describe their various roles and material terms of your arrangements with them. In addition, please disclose whether you will be relying on third-parties to hold ENAs or any other digital assets you hold or intend to hold in the future, such as Bitcoin. In this regard, we note a reference to your intent to use "established custodians, including Anchorage and Cactus Wallet," however it is not clear if you currently use such custodians.

4. We note your disclosure that you may engage in staking, re-staking or other permitted activities that involve the use of smart contracts or decentralized applications as part of your treasury management strategy. Please revise to: ● Describe the material aspects of your plans to stake digital assets that you hold. ● Disclose your policies and procedures regarding your staking plans. For example, state how much of your digital assets you intend to stake, and explain how your agreement with any staking provider will operate.

5. You state that as of the date hereof you hold 40 ETH and, as of June 25, 2025, you held 12 BTC. Confirm whether these amounts continue to represent all of your current Digital Asset holdings. Clarify how you used the proceeds of the offering you closed on July 24, 2025, the proceeds of which you disclose "will provide a solid capital foundation for [y]our digital asset treasury strategy."

6. Please revise to include quantitative examples of the historic prices for the Digital Assets that you plan to acquire.

7. We note your risk factor disclosure that addresses the novelty of digital assets and the resulting risks, including commercial and technical uncertainty. There or in a new risk factor, please revise to enhance your disclosure by describing any material financing, liquidity, or other risks you face related to the impact that a crypto asset market disruption may have, directly or indirectly, on the value of ENA (including the staked version) or other digital assets you hold or intend to hold.

8. We note your disclosure that the Company will safeguard its Digital Assets using custodians, including Anchorage and Cactus Wallet. Please revise to identify your custodians and disclose the material terms of your custody arrangements. Please also file your agreement(s) as exhibits to your registration statement if material. In addition, please revise to disclose the scope and limitations of the insurance coverage that your custodians provide and discuss whether coverage is shared by other custody customers, and whether that could result in the coverage being insufficient to compensate you for losses.

Comment : Please revise to discuss the Sponsor's experience sponsoring exchange-traded products and specifically its experience related to crypto asset markets. Revise your risk factors on page 45 as appropriate.

Comment 4 – Risk Factors – Risks Related to Digital Assets – The trading prices of many digital assets, page 11 Please revise to include quantitative examples of LINK’s historic price volatilities.

6. Please revise to include a materially complete description of HYPE, SOL and SUI and the Hyperliquid, Solana and Sui blockchains. For example purposes only, for each crypto asset, provide a description of its lifecycle, its use case, including its respective purpose, use and/or functions, its market cap, its circulating supply, its maximum supply, if any, its average trading volume, its launch date and the launch date of the respective blockchain, and the governance of its respective blockchain.

7. Please revise your risk factor disclosure so that it is tailored to risks specific to HYPE, SOL and SUI, and their respective blockchains. In this regard, we note references throughout to risks related to bitcoin.

Comment : In an appropriate location near the disclosure regarding the Fund having notional exposure to each of the Oil Strategy and the Bitcoin Strategy representing approximately 100% of the Fund’s net assets, please disclose that the Adviser reallocates the Fund’s portfolio holdings daily to seek to maintain a balanced notional exposure between the Oil Strategy and the Bitcoin Strategy.

Comment : In the “Bitcoin Strategy” disclosure, please clarify that the Fund will invest in these instruments through the Subsidiary.

Comment: On page 19, please explain the context for Digital Assets Risk and how it applies to NU.

Comment : On page 103, please explain the context for Digital Assets Risk and how it applies to GEMI.

Comment 2 – Form N-CSR – Summary of Holdings by Investment Type ( BITC ) The “Principal Investment Strategies” section of the Fund’s most recently filed prospectus (the “Prospectus”) provides that “[u]nder normal market conditions, the Fund will invest at least 80% of its assets in Bitcoin Futures Contracts and U.S. Treasury securities.” The Staff notes that as of December 31, 2024, approximately 70% of the Fund’s assets were invested in money market funds. Please supplementally explain how the Fund’s portfolio holdings as of December 31, 2024 were consistent with the Fund’s “Principal Investment Strategies” section of the Prospectus.

Comment 7 – Form N-CSR – Notes to Consolidated Financial Statements – Consolidation of Subsidiary ( BTOP, AETH ) Please supplementally explain why, as of December 31, 2024, the assets of Bitwise Bitcoin and Ether Equal Weight Strategy Cayman Subsidiary, LLC and Bitwise Ethereum Strategy Cayman Subsidiary, LLC, the wholly owned subsidiaries of BTOP and AETH, were $0.

Comment : Under the section titled “The Principal Investment Strategy of the Fund,” the disclosure states that the underlying funds may invest in “cryptocurrencies.” Supplementally, please advise the Staff of the extent ( e.g. , __%) to which the Funds intend to gain exposure to cryptocurrencies. Also please advise and describe whether the Funds intend to focus on any particular types of cryptocurrencies and then consider whether additional disclosure is warranted to reflect the risks of the particular types of cryptocurrencies.

3. We note your disclosure that you provide title insurance for real estate based cryptocurrency issued by a related party. Please clarify what revenues, if any, you have derived from this business. Describe any liability that you assume in favor of the related party, or the purchasers of the cryptocurrency, based on your title work. In addition, given that the agreement is with a related party, please make that clear here and add a related party transactions section describing this transaction.

Comment : The Staff notes that Bullish commenced its IPO in August 2025. (a) Please add disclosure related to investing in IPOs such as limited trading history, and that there is limited information which may subject the company’s stock price to abnormal returns and/or volatility and that there is a potential for dilution when insiders are free to sell shares. (b) Please consider confirming the market capitalization of the company. (c) The Staff notes the IPO was settled in stablecoin. Please confirm that the Fund may purchase or sell shares in US Dollars. (d) Please tailor the risk factors to the business of Bullish including cryptocurrency, market volatility, intense competition, and regulatory uncertainty.

Comment : In the last paragraph on page 3, please enhance the description of BLSH to make it more clear that BLSH is a global crypto exchange that allows customers to buy sell and exchange digital assets, including bitcoin and ether. Please also emphasize BLSH’s IPO, noting the company went public in August of 2025. Please consider the adequacy of the risk disclosure regarding the fact that the IPO was recent and we don’t know how it will trade.

1. We note your disclosure that Pubco will be highly dependent on the services of Anthony Pompliano and that he will spend a substantial portion of his business time and attention on Pubco, but that he does not devote his full time and attention to Pubco. We also note your disclosure that Anthony Pompliano is the founder and Chief Executive Officer of Professional Capital Management. Please clarify how much of Anthony Pompliano’s services will be provided through the Services Agreement with Professional Capital Management as opposed to his role as the Chief Executive Officer of Pubco. Please also factor into the discussion the term of the Services Agreement and the scope of his non-compete agreement, which is limited to becoming a Control Person of a public company with a Bitcoin treasury strategy focus until the earlier of (i) eighteen months after Closing and (ii) six months after he…

2. We note your revised disclosure in response to prior comment 7 on pages 249 and 250 that you have entered into non-exclusive agreements to advertise certain Bitcoin related products and services of third parties on your audio podcasts and video podcasts broadcasted on our YouTube channel and X account in exchange for fees. Please revise to disclose (i) the number of advertisers you have contracted with, (ii) the range of terms of these agreements and (iii) the aggregate revenues you have earned to date and expect to earn going forward pursuant to such current advertising services contracts. In addition, you state that the fee may be paid in a combination of fiat, Bitcoin, stablecoins or other crypto assets. Please revise to disclose whether you intend to hold such stablecoins or other crypto assets or whether you intend to exchange these for fiat currency or Bitcoin. In addition,…

3. We note your response to prior comment 8 that the subscribed share obligations are equity-linked instruments classified in equity, with no gain or loss recognized in earnings. We also note your response to prior comment 9 that the future purchase of bitcoin under the PIPE Bitcoin Sale and Additional PIPE Bitcoin Sale agreements would be accounted for as derivative instruments under ASC 815 with changes in fair value of the derivative, rather than of the underlying bitcoin, recognized through the statement of operations. Please tell us your consideration of reflecting the transactions described in your response within your Pro Forma Statements of Operations. Your adjustments CC to the pro forma statement of operations for the period ended June 30, 2025, and adjustments EE and JJ to the pro forma statement of operations for the year ended December 31, 2024 appear to reflect the receipt…

Comment: The “Blockchain Technology Risk” disclosure states “[a]lthough the Fund does not currently employ blockchain technology or invest in crypto assets, the financial intermediaries through whom shareholders purchase and redeem Digital Shares intend to employ blockchain technology to maintain a record of share ownership for their customers.” Please explain supplementally the Fund’s, and more broadly, the JPMorgan Funds’ intent, if any, to employ 1 blockchain technology or invest in crypto assets, and discuss the time frame for employing these innovations. Additionally, please explain how the introduction of blockchain technology with this share class changes how the Fund and/or intermediary record share ownership account for potential loss or other risks associated with the use of blockchain technology.

1. You disclose that your new treasury policy updated your treasury management to “include digital assets, starting with SOL” and that “[m]anagement intends to focus on accumulating digital assets, focusing on SOL, and holding it long-term.” Please expand to discuss your intentions to acquire other crypto assets, if any. To the extent you intend to acquire a material amount of other crypto assets, please add a section that addresses the characteristics of such crypto assets and the network on which they exist as well as any material risks related to your investment therein. If management does not currently have any such plans, please so state.

2. We note your disclosure that “[w]e derive revenue from our digital asset treasury strategy through delegating a portion of our digital asset holdings with third-party validators… Additionally, we earn validator revenue from participating in the Solana network through creating and validating transactions using our owned validators.” Please revise to address the following points: ● Quantify the portions of your crypto asset holdings that are allocated to your owned validator nodes and to third-party nodes, respectively. ● Expand your disclosure to quantify the costs of operating your own validator nodes and address how and whether such operations have a material impact on your profitability. ● Quantify the amount of SOL that is staked to your owned validator nodes by third parties.

3. We note your disclosure that “[i]n exchange for staking our digital assets, we receive approximately 10% of the validators’ total earned rewards in the form of SOL, net of commission fees.” Please revise to discuss how such amount that you receive is determined. Also, please revise to explain how the validators’ total earned rewards in the form of SOL is determined and calculated and quantify the approximate amount of the validators’ commission fees you reference.

4. Please expand your disclosure to describe your plan of operation for the next 12 months by disclosing: ● The amount and proportions of SOL and/or other crypto assets you have purchased or intend to purchase; ● The amount of capital you intend to raise through equity issuances and debt financing for such acquisitions. In this regard, we note your disclosure on page 27 that you use proceeds primarily from financing activities that consist of equity issuances and debt financing to acquire SOL; and ● An estimated timeline for building your digital asset treasury over this time period.

5. We note your disclosure that “[w]e delegate (’stake’) a portion of our digital assets, primarily locked SOL, with third party validators… In some cases, we jointly own and operate validators alongside ecosystem partners to further align our treasury strategy with the broader Solana network.” Please revise to provide a materially complete description of your staking program. In this regard, please address each of the following points with respect to your (i) delegated staking activities with third party providers and (ii) staking activities conducted through your owned validators that you operate, as applicable: ● State whether you have any target percentage of your SOL holdings that you stake. ● Describe in greater detail the mechanics of the staking process. ● Disclose the material terms of your agreements with your staking providers, and summarize the responsibility and duties of…

6. Please expand your disclosure to describe the policies and procedures you have in place or intend to adopt that govern when you exchange cash for crypto assets and when you monetize your crypto assets. Disclose whether you have policies or will establish policies governing the percentage of your treasury holdings that will be SOL. In addition, please disclose whether you intend to hedge your exposure to SOL and, if so, please describe your hedging strategy. Further, provide related risk factor disclosure, if material and to the extent applicable.

7. On page 27, you disclose that you “rely on various counterparties which includes, among others, Kraken, BitGo and Galaxy, to safeguard [your] digital asset holdings and execute trading on [your] behalf.” Please supplementally confirm whether you have disclosed the identities of the material counterparties in this regard. With respect to each material counterparty, please describe the material terms of your agreement(s), including, without limitation, the term and termination provisions, and file the same as exhibits to your registration statement, if required by Item 601 of Regulation S-K. For any material counterparty that provides custodial services for your crypto assets, please also disclose: ● The proportion of private keys that are held in hot, warm or cold storage; ● Whether your assets are held in segregated accounts; ● The identity of entities that have access to the…

8. We note your disclosure on page 27 that, “Kraken accounts for approximately 95% of our trading volume and approximately 30% of our digital assets holding are at both BitGo and Galaxy.” Please revise to clarify the approximate percentage of your crypto asset holdings that are held at each material third party custodian, respectively.

10. We note your disclosure that the Solana network enables users to instantly send money globally, trade digital assets, utilize smart contracts, and buy or sell fungible and non-fungible tokens. Please revise to quantify or otherwise describe the nature and level of activity for each of these identified use cases, and quantify the number of active developers on the Solana network as of the most recent practicable date, to the extent known.

1. You disclose that your new treasury policy updated your treasury management to "include digital assets, starting with SOL" and that "[m]anagement intends to focus on accumulating digital assets, focusing on SOL, and holding it long-term." Please expand to discuss your intentions to acquire other crypto assets, if any. To the extent you intend to acquire a material amount of other crypto assets, please add a section that addresses the characteristics of such crypto assets and the network on which they exist as well as any material risks related to your investment therein. If management does not currently have any such plans, please so state.

2. We note your disclosure that "[w]e derive revenue from our digital asset treasury strategy through delegating a portion of our digital asset holdings with third-party validators… Additionally, we earn validator revenue from participating in the Solana network through creating and validating transactions using our owned validators." Please revise to address the following points: ● Quantify the portions of your crypto asset holdings that are allocated to your owned validator nodes and to third-party nodes, respectively. ● Expand your disclosure to quantify the costs of operating your own validator nodes and address how and whether such operations have a material impact on your profitability. ● Quantify the amount of SOL that is staked to your owned validator nodes by third parties.

3. We note your disclosure that "[i]n exchange for staking our digital assets, we receive approximately 10% of the validators' total earned rewards in the form of SOL, net of commission fees." Please revise to discuss how such amount that you receive is determined. Also, please revise to explain how the validators' total earned rewards in the form of SOL is determined and calculated and quantify the approximate amount of the validators' commission fees you reference.

4. Please expand your disclosure to describe your plan of operation for the next 12 months by disclosing: ● The amount and proportions of SOL and/or other crypto assets you have purchased or intend to purchase; ● The amount of capital you intend to raise through equity issuances and debt financing for such acquisitions. In this regard, we note your disclosure on page 14 that you use proceeds primarily from financing activities that consist of equity issuances and debt financing to acquire SOL; and ● An estimated timeline for building your digital asset treasury over this time period.

5. We note your disclosure that "[w]e delegate ('stake') a portion of our digital assets, primarily locked SOL, with third party validators… In some cases, we jointly own and operate validators alongside ecosystem partners to further align our treasury strategy with the broader Solana network." Please revise to provide a materially complete description of your staking program. In this regard, please address each of the following points with respect to your (i) delegated staking activities with third party providers and (ii) staking activities conducted through your owned validators that you operate, as applicable: ● State whether you have any target percentage of your SOL holdings that you stake. ● Describe in greater detail the mechanics of the staking process. ● Disclose the material terms of your agreements with your staking providers, and summarize the responsibility and duties of…

6. Please expand your disclosure to describe the policies and procedures you have in place or intend to adopt that govern when you exchange cash for crypto assets and when you monetize your crypto assets. Disclose whether you have policies or will establish policies governing the percentage of your treasury holdings that will be SOL. In addition, please disclose whether you intend to hedge your exposure to SOL and, if so, please describe your hedging strategy. Further, provide related risk factor disclosure, if material and to the extent applicable.