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    Richard
                           Coyle

Partner

        Chapman and Cutler LLP

        320 South Canal Street, 27th Floor

        Chicago, Illinois 60606

        T 312.845.3724

        rcoyle@chapman.com

December 4, 2023

Via EDGAR Correspondence

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

 Re: Bitwise Bitcoin ETF

            File No. 333-260235

Dear Ms. Bednarowski and Mr. Dobbie:

This letter responds
to your comments regarding the registration statement filed on Form S-1 for the Bitwise Bitcoin ETF (formerly
Bitwise Bitcoin ETP Trust) (the “Trust”) with the staff of the Securities and Exchange Commission (the “Staff”)
on October 25, 2023 (the “Registration Statement”). Capitalized terms used herein, but not otherwise defined,
have the meanings ascribed to them in the Registration Statement.

Comment 1 –
General

To the extent that
you intend to use a fact sheet, please provide us with a copy for our review.

Response to Comment
1

The Trust’s fact
sheet has been provided to the Staff under separate cover.

Comment 2 –
General

Please describe the
AML, KYC and any other procedures conducted by the Trust or Sponsor to determine, among other things, whether the counter-party
in any transactions is not a sanctioned entity. To the extent that the Trust, Sponsor, Authorized Participant or Custodian may
not know a counter-party, please add risk factor disclosure regarding the potential risk of transactions with a sanctioned entity
and the impact if such a transaction occurs.

Charlotte     Chicago     New
York     Salt Lake City     San
Francisco     Washington, DC

December 1, 2023

Page 2

Response to Comment 2

The Sponsor maintains
a process for approving and monitoring bitcoin trading counterparties, which is overseen by the Bitwise Portfolio Oversight Committee,
which is responsible for investment activities and related risk, as well as counterparty risk. All bitcoin trading counterparties
must be approved by the Bitwise Portfolio Oversight Committee before the Sponsor, on behalf of the Trust, will engage in transactions
with the entity. The Bitwise Portfolio Oversight Committee continuously reviews all approved bitcoin trading counterparties at
its quarterly meetings and will reject the approval of any previously approved bitcoin trading counterparty if new information
arises regarding the entity that puts the appropriateness of that entity as an approved bitcoin trading counterparty in doubt.

In considering which
bitcoin trading counterparties to approve, the Bitwise Portfolio Oversight Committee has instituted rigorous policies and procedures
that include, but are not limited to, (i) a review of all sanctioned entities, including but not limited to, the various categories
of sanctioned persons and entities identified by the Office of Foreign Assets Control; (ii) a review of all publicly available
information regarding the entity, including a review of all information that has been filed pursuant to the requirements of U.S.
or non-U.S. regulators, with a particular emphasis on the identity of the entity’s owners, disclosure events and reports
of disciplinary action; and (iii) a review of the entity’s policies and procedures regarding various topics, including, but
not limited to, anti-money laundering and “know-your-customer” requirements, trade surveillance, auditing and testing
and cybersecurity capabilities.

In addition, the Bitcoin
Custodian has adopted and implemented an anti-money laundering and sanctions compliance program, which provides additional protections
to ensure that the Sponsor and the Trust do not transact with a sanctioned party. Notably, the Bitcoin Custodian performs Know-Your-Transaction
(“KYT”) screening using blockchain analytics to identify, detect, and mitigate the risk of transacting with a sanctioned
or other unlawful actor. Pursuant to the Bitcoin Custodian’s KYT program, any bitcoin that is delivered to the Trust’s
custody account will undergo screening to ensure that the origins of that bitcoin are not illicit.

December 1, 2023

Page 3

Pursuant to the Staff’s
comment, the Registration Statement has been revised to include the following disclosure (emphasis added):

Anonymity and illicit financing
risk.

Although transaction details of peer-to-peer
transactions are recorded on the Bitcoin blockchain, a buyer or seller of digital assets on a peer-to-peer basis directly on the
Bitcoin network may never know to whom the public key belongs or the true identity of the party with whom it is transacting. Public
key addresses are randomized sequences of alphanumeric characters that, standing alone, do not provide sufficient information to
identify users. In addition, certain technologies may obscure the origin or chain of custody of digital assets. The opaque nature
of the market poses asset verification challenges for market participants, regulators and auditors and gives rise to an increased
risk of manipulation and fraud, including the potential for Ponzi schemes, bucket shops and pump and dump schemes. Digital assets
have in the past been used to facilitate illicit activities. If a digital asset was used to facilitate illicit activities, businesses
that facilitate transactions in such digital assets could be at increased risk of potential criminal or civil lawsuits, or of having
banking or other services cut off, and such digital asset could be removed from digital asset exchanges. Any of the aforementioned
occurrences could adversely affect the price of the relevant digital asset, the attractiveness of the respective blockchain network
and an investment in the Shares. If the Trust or the Sponsor were to transact with a sanctioned entity, the Trust or the
Sponsor would be at risk of potential criminal or civil lawsuits or liability.

The Trust takes measures with the objective
of reducing illicit financing risks in connection with the Trust’s activities. However, illicit financing risks are present
in the digital asset markets, including markets for bitcoin. There can be no assurance that the measures employed by the Trust
will prove successful in reducing illicit financing risks, and the Trust is subject to the complex illicit financing risks and
vulnerabilities present in the digital asset markets. If such risks eventuate, the Trust, the Sponsor or their affiliates
could face civil or criminal liability, fines, penalties, or other punishments, be subject to investigation, have their assets
frozen, lose access to banking services or services provided by other service providers, or suffer disruptions to their operations,
any of which could negatively affect the Trust’s ability to operate or cause losses in value of the Shares.

The Sponsor and the Trust have adopted
and implemented policies and procedures that are designed to ensure that they do not violate applicable AML and sanctions laws
and regulations and to comply with any applicable KYC laws and regulations. The Sponsor and the Trust will only interact with known
third party service providers with respect to whom it has engaged in a due diligence process to ensure a thorough KYC process,
such as the Authorized Participants and the Bitcoin Custodian. Authorized Participants, as broker-dealers, and the Bitcoin Custodian,
as a limited purpose trust company subject to New York Banking Law, are subject to the U.S. Bank Secrecy Act (as amended) (“BSA”)
and U.S. economic sanctions laws.

December 1, 2023

Page 4

In addition, the Trust will only accept
creations and redemption requests from regulated Authorized Participants who themselves are subject to applicable sanctions and
anti-money laundering laws and have compliance programs that are designed to ensure compliance with those laws.

The Bitcoin Custodian has adopted and
implemented an anti-money laundering and sanctions compliance program, which provides additional protections to ensure that the
Sponsor and the Trust do not transact with a sanctioned party. Notably, the Bitcoin Custodian performs Know-Your-Transaction (“KYT”)
screening using blockchain analytics to identify, detect, and mitigate the risk of transacting with a sanctioned or other unlawful
actor. Pursuant to the Bitcoin Custodian’s KYT program, any bitcoin that is delivered to the Trust’s custody account
will undergo screening to ensure that the origins of that bitcoin are not illicit.

There is no guarantee that such procedures
will always be effective. If the Authorized Participants have inadequate policies, procedures and controls for complying
with applicable anti-money laundering and applicable sanctions laws or the Trust’s diligence is ineffective, violations of
such laws could result, which could result in regulatory liability for the Trust, the Sponsor, or their affiliates under such laws,
including governmental fines, penalties, and other punishments, as well as potential liability to or cessation of services by the
Bitcoin Custodian. Any of the foregoing could result in losses to the Shareholders or negatively affect the Trust’s ability
to operate.

December 1, 2023

Page 5

Comment 3 –
General

Please revise your
disclosure to provide consistent use of terminology throughout. For example purposes only, if you intend for the following terms
to have different meanings, please revise to disclose or, to the extent you use the following terms interchangeably, please revise
to use one term: (i) “Constituent Platforms” and “Constituent Exchanges” (ii) “CME CF Cryptocurrency
Pricing Products Oversight Committee” and “CME Oversight Committee” and (iii) “CME CF Reference Rate”
and “BRRNY” and (iv) “Sponsor’s management fee” and “Sponsor’s Fee.”

Response to Comment
3

The Registration Statement
has been revised in accordance with the Staff’s comment.

Comment 4 –
Cover Page

Please revise your
disclosure here to identify the initial Authorized Participant as an underwriter, disclose the initial price per Share, and disclose
the termination date of the offering, if any.

Response to Comment
4

Pursuant to the Staff’s
comment, the Sponsor, on behalf of the Trust, represents that in a future amendment to the Registration Statement, disclosure regarding
the initial price per Shares will be included.

However, the Sponsor
respectfully declines to identify the Authorized Participant as an underwriter of the Shares. A determination of whether a particular
market purchaser is an underwriter must take into account all the facts and circumstances pertaining to the activities of the broker-dealer
or its client in the particular case. The Sponsor believes that a statement identifying the initial Authorized Participant is not
required by the Form S-1 requirements and therefore the Sponsor does not anticipate making such disclosure. The Sponsor refers
the Staff to the section of the Registration Statement entitled “Plan of Distribution – Authorized Participants”
which discloses the circumstances under which an Authorized Participant or dealer may be deemed an underwriter and the implications
to Shareholders of such designation.

Comment 5 –
Statement Regarding Forward-Looking Statements

We note your disclosure
that “[t]his prospectus contains ‘forward-looking statements’ within the meaning of Section 27A of the Securities
Act of 1933 and Section 21E of the Securities Exchange Act of 1934 and within the Private Securities Litigation Reform Act of 1995.”
Section 27A(b)(2)(D) of the Securities Act and Section 21E(b)(2)(D) of the Exchange Act expressly state that the safe harbor for
forward looking statements does not apply to statements made in connection with an initial public offering. Please either remove
any reference to the Private Securities Litigation Reform Act or clarify that the safe harbor does not apply to this offering.

December 1, 2023

Page 6

Response to Comment
5

Pursuant to the Staff’s
comment, the first paragraph of the referenced disclosure has been revised as set forth below:

This Prospectus includes “forward-looking
statements” that generally relate to future events or future performance. In some cases, you can identify forward-looking
statements by terminology such as “may,” “will,” “should,” “expect,” “plan,”
“anticipate,” “believe,” “estimate,” “predict,” “potential,” or the
negative of these terms or other comparable terminology. All statements (other than statements of historical fact) included in
this Prospectus that address activities, events, or developments that will or may occur in the future, including such matters as
movements in the digital asset markets, the Trust’s operations, the Sponsor’s plans, and references to the Trust’s
future success and other similar matters, are forward-looking statements. These statements are only predictions. Actual events
or results may differ materially. These statements are based upon certain assumptions and analyses the Sponsor has made based on
its perception of historical trends, current conditions, and expected future developments, as well as other factors appropriate
in the circumstances.

Comment 6 –
Prospectus Summary

Please revise to disclose
whether the Trust is a passive or active investment vehicle and that Shareholders do not have voting rights.

Response to Comment
6

Pursuant to the Staff’s
comment, the following disclosure has been added to the Registration Statement:

The Trust is passively managed and does
not pursue active management investment strategies, and the Sponsor does not actively manage the bitcoin held by the Trust. This
means that the Sponsor does not sell bitcoin at times when its price is high or acquire bitcoin at low prices in the expectation
of future price increases. It also means that the Sponsor does not make use of any of the hedging techniques available to professional
bitcoin investors to attempt to reduce the risks of losses resulting from price decreases.

December 1, 2023

Page 7

Additionally, the section
of the Registration Statement entitled “Risk Factors” has been revised to include the following disclosure:

The Trust is a passive investment
vehicle. The Trust is not actively managed and will be affected by a general decline in the price of bitcoin.

The Sponsor does not actively manage
the bitcoin held by the Trust. This means that the Sponsor does not sell bitcoin at times when its price is high, or acquire bitcoin
at low prices in the expectation of future price increases. It also means that the Sponsor does not make use of any of the hedging
techniques available to professional bitcoin investors to attempt to reduce the risks of losses resulting from price decreases.
Any losses sustained by the Trust will adversely affect the value of the Shares.

Disclosure regarding
Shareholders lack of voting rights is included in the sections of the Registration Statement entitled “Risk Factors –
Shareholders do not have the rights enjoyed by investors in certain other vehicles and may be adversely affected by a lack of statutory
rights and by limited voting and distribution rights” and “Management; Voting By Shareholders.”

Comment 7 –
The Trust’s Fees and Expenses

We note your disclosure
that the “Sponsor’s management fee is based on a percentage of the adjusted NAV of the Trust” and that the Sponsor’s
Fee is paid in bitcoin. Please disclose how the value of the bitcoin for the Sponsor’s Fee is determined, including how the
NAV of the Trust is adjusted. In addition, please disclose whether the Trust is responsible for paying any costs associated with
the transfer of bitcoin to the Sponsor or the sale of bitcoin for costs not included in the Sponsor’s Fee. Also disclose
whether any of the Trust’s expenses payable by the Sponsor from the Sponsor’s Fee are capped.

December 1, 2023

Page 8

Response to Comment
7

Pursuant to the Staff’s
comment, the referenced disclosure has been revised as set forth below:

The Trust will pay the unitary Sponsor
Fee of 0.__% per annum o