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CORRESP
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December 29, 2023

VIA EDGAR

Division of Corporation Finance

Office of Crypto Assets

U.S. Securities and Exchange Commission

Washington, DC 20549

 Re: WisdomTree Bitcoin Trust

Amendment No. 4 to Registration
Statement on Form S-1

Filed December 18, 2023

File No. 333-254134

Dear Mses. Tillan and Miller:

 This response is provided on behalf of WisdomTree
Bitcoin Fund (formerly, WisdomTree Bitcoin Trust) (the “Trust” or the “Registrant”) with respect to Staff comments
received on December 27, 2023, regarding Amendment No. 4 to the Trust’s Registration Statement on Form S-1 (the “Filing”),
which was filed with the U.S. Securities and Exchange Commission (“SEC”) on December 18, 2023, for the purpose of registering
shares of the Trust. The Staff’s comments and the Trust’s responses are set forth below. Capitalized terms used, but not defined
herein have the same meaning given to them in the Trust’s registration statement.

Cover Page

 1. Comment: We note your response to prior comment 5 and re-issue in part. Please revise your disclosure
here to identify the initial Authorized Participant as an underwriter. Refer to Section 2(a)(11) of the Securities Act. In addition, please
disclose that you are offering an indeterminate number of shares.

Response: The language below
has been added to the front cover of the prospectus (emphasis added for the purpose of this response to indicate the identification of
the initial Authorized Participant as an underwriter):

Because new Shares can be created and
issued on an ongoing basis, at any point during the life of the Trust, a “distribution,” as such term is used in the 1933
Act, will be occurring. Authorized Participants, other broker-dealers and other persons are cautioned that some of their activities may
result in their being deemed participants in a distribution in a manner that would render them statutory underwriters and subject them
to the prospectus-delivery and liability provisions of the 1933 Act. For example, the initial Authorized Participant will be a statutory
underwriter with respect to the initial purchase of Baskets when purchased from the Trust with a view towards distribution of such Shares.

      WisdomTree Bitcoin Fund  250 West 34th Street, 3rd Floor, New York, NY 10119 | 212-801-2080 Tel

Prospectus Summary

Net Asset Value

 2. Comment: In response to prior comment 8, you told us for purposes of your financial reporting under
U.S. GAAP, all activities will be reflected on the trade date. Please tell us why your disclosure continues to state your "... daily
activities are generally not reflected in the NAV determined for the Business Day on which the transactions are effected (the trade date),
but rather on the following Business Day."

Response: The referenced
disclosure has been removed.

Risk Factors

 3. Comment: To the extent material, please include risk factor disclosure that addresses the risks
related to your Bitcoin Custodian and Prime Broker acting in the same capacity for several competing products.

Response: The following risk
factor disclosure titled “Coinbase serves as the bitcoin custodian and prime execution agent for several competing exchange-traded
bitcoin products, which could adversely affect the Trust's operations and ultimately the value of the Shares” has been added:

The Prime Execution Agent and Bitcoin
Custodian are both affiliates of Coinbase Global. As of the date hereof, Coinbase Global is the largest publicly traded digital asset
company in the world by market capitalization and is also the largest digital asset custodian in the world by assets under custody. By
virtue of its leading market position and capabilities, and the relatively limited number of institutionally-capable providers of digital
asset brokerage and custody services, Coinbase serves as the bitcoin custodian and prime execution agent for several competing exchange-traded
bitcoin products and, as such, plays a critical role in supporting the U.S. spot bitcoin exchange-traded product ecosystem. If Coinbase
were to favor the interests of certain exchange-traded products over others, it could result in inadequate attention or comparatively
unfavorable commercial terms to less favored products, which could adversely affect the Trust's operations and ultimately the value of
the Shares, particularly given the limited number of qualified alternative providers.

 4. Comment: Please revise to add disclosure clarifying whether the Authorized Participant bears the
risk of bitcoin price movements with respect to cash creations and redemptions. Please add related risk factor disclosure as appropriate.

Response: The following has
been added as a new disclosure, which is also responsive to Comment 14:

      2

The use of cash creations and redemptions,
as opposed to in-kind creations and redemptions, could cause delays in trade execution due to potential operational issues arising from
implementing a cash creation and redemption model, which involves greater operational steps (and therefore execution risk) than the originally
contemplated in-kind creation and redemption model, or the potential unavailability or exhaustion of the Trust’s ability to borrow
bitcoin or cash as trade credits (“Trade Credits”), which the Trust would not be able to use in connection with in-kind creations
and redemptions. Such delays could cause the execution price associated with such trades to materially deviate from the Reference Rate
used to determine the NAV, particularly when considering that the trading prices for bitcoin have exhibited high levels of volatility
and may continue to do so. Even though the Authorized Participant is responsible for the dollar cost of such difference in prices, Authorized
Participants could default on their obligations to the Trust, or such potential risks and costs could lead to Authorized Participants,
who would otherwise be willing to purchase or redeem Baskets to take advantage of any arbitrage opportunity arising from discrepancies
between the price of the Shares and the price of the underlying bitcoin, to elect to not participate in the Trust's Share creation and
redemption processes. This may adversely affect the arbitrage mechanism intended to keep the price of the Shares closely linked to the
price of bitcoin, and as a result, the price of the Shares may fall or otherwise diverge from NAV. If the arbitrage mechanism is not effective,
purchases or sales of Shares on the secondary market could occur at a premium or discount to NAV, which could harm Shareholders by causing
them buy Shares at a price higher than the value of the underlying bitcoin held by the Trust or sell Shares at a price lower than the
value of the underlying bitcoin held by the Trust, causing Shareholders to suffer losses.

Additionally, the following disclosure
has also been added to the first paragraph of the section titled “Creation and Redemption of Shares”:

The price of bitcoin, the Trust’s
NAV and the price of a Basket could rise or fall substantially between the time a creation order or redemption order is submitted and
the time the amount of the purchase price in respect thereof is determined, and the risk of such price movements will be borne solely
by the Authorized Participant.

Risk Factors Associated with bitcoin and
the Bitcoin Network Bitcoin exchanges on which bitcoin trades are relatively new

 5. Comment: We note your response to prior comment 12 and re-issue in part. Please revise to add a
separate risk factor that discusses the risk of wash trading.

Response: The following risk
factor disclosure titled “Spot markets may be exposed to wash trading” has been added:

Spot markets on which bitcoin trades
may be susceptible to wash trading. Wash trading occurs when offsetting trades are entered into for other than bona fide reasons, such
as the desire to inflate reported trading volumes. Wash trading may be motivated by non-economic reasons, such as a desire for increased
visibility on popular websites that monitor markets for digital assets so as to improve their attractiveness to investors who look for
maximum liquidity, or it may be motivated by the ability to attract listing fees from token issuers who seek the most liquid and high-volume
exchanges on which to list their coins. Results of wash trading may include unexpected obstacles to trade and erroneous investment decisions
based on false information. Any actual or perceived false trading in the digital asset  markets,
and any other fraudulent or manipulative acts and practices, could adversely affect the value of bitcoin and/or negatively affect the
market perception of bitcoin. To the extent that wash trading either
occurs or appears to occur in spot markets on which bitcoin trades, investors may develop negative perceptions about bitcoin and the digital
assets industry more broadly, which could adversely impact the price bitcoin and, therefore, the price of Shares. Wash trading also may
place more legitimate digital asset platforms  at a relative competitive disadvantage.

      3

Bitcoin, Bitcoin Market, Bitcoin Exchanges
and Regulation of Bitcoin

Bitcoin Protocol

 6. Comment: We note your response to prior comment 21 and re-issue in part. Please revise your disclosure
to clarify:

 • Whether there is any circumstance under which the Trust would retain or hold any Incidental Rights;

 • Whether there would be any difference in how the Trust handles Incidental Rights
via fork as compared to airdrops;

 • The specifics of how the Sponsor will arrange to sell the new cryptocurrency and
distribute proceeds to the Shareholders, including whether and under what circumstances the Sponsor will utilize an affiliate or third-party
to sell the cryptocurrency; and

 • Whether any entity will be responsible for verifying the instructions that are
in place with the Trustee and the Sponsor regarding forks and airdrops.

Response: The following disclosure
has been added after the third paragraph of the section titled “Bitcoin Protocol”:

The actions which the Sponsor may,
in its sole discretion, determine the Trust shall take include (i) arranging for the sale of Incidental Rights and/or IR Virtual Currency,
which may arise out of a fork, airdrop or similar event, and distributing the cash proceeds (net of expenses and any applicable withholding
taxes) to the Depository Trust Company (“DTC”), (ii) using Incidental Rights and/or IR Virtual Currency to pay the Sponsor’s
Fee and/or additional Trust expenses not assumed by the Sponsor, or (iii) electing not to acquire, claim, or obtain, and permanently and
irrevocably abandoning, Incidental Rights or IR Virtual Currency for no consideration. The Sponsor is under no obligation to realize any
economic benefit from any Incidental Rights or IR Virtual Currency on behalf of the Trust.

      4

With respect to any fork, airdrop or
similar event, the Sponsor shall, in its sole discretion, determine what action the Trust shall take. In the event of a fork, the Sponsor
will determine which network it believes is generally accepted as the Bitcoin network and should therefore be considered the appropriate
network, and the associated asset as bitcoin, for the Trust’s purposes. The Sponsor may decide to cause the Trust to sell any Incidental
Rights or IR Virtual Currency for cash (including, as determined by the Sponsor, in the case of a fork, the asset that is not generally
accepted as bitcoin, or in the case of an airdrop, the airdropped asset) and distribute the cash proceeds or distribute them in-kind to
DTC, and registered holders of Shares are entitled to receive such distributions in proportion to the number of shares owned. However,
the Sponsor may instead determine, in its sole discretion, to permanently and irrevocably abandon such Incidental Rights or IR Virtual
Currency for no consideration. In the case of abandonment of Incidental Rights or IR Virtual Currency, the Trust would not receive any
direct or indirect consideration for the Incidental Rights or IR Virtual Currency and thus the value of the Shares will not reflect the
value of the Incidental Rights or IR Virtual Currency.

The Sponsor may choose to evaluate
any event giving rise to Incidental Rights or IR Virtual Currency on a case-by-case basis in consultation with the Trust’s legal
advisors, tax consultants, the Trustee, the Bitcoin Custodian, and the Prime Execution Agent. In determining whether to attempt to acquire
and/or retain any Incidental Rights and IR Virtual Currency, the Sponsor expects to take into consideration whatever factors it deems
relevant in its sole discretion, including, without limitation:

 · the Bitcoin Custodian’s agreement (or
not) to provide access to the Incidental Rights or IR Virtual Currency;

 · the availability of a safe and practical way
to custody the Incidental Rights or IR Virtual Currency;

 · the costs or operational burden of taking
possession and/or maintaining ownership of the Incidental Rights or IR Virtual Currency and whether such costs or burden exceed the benefits
of owning such Incidental Rights or IR Virtual Currency or the proceeds that would be realized for the Trust or Shareholders from a sale
thereof;

 · whether there are any legal or regulatory
restrictions on or risks or consequences arising from, or tax implications (including any impact on the Trust’s ability to qualify
as a grantor trust for tax purposes) with respect to the ownership, sale or disposition of the Incidental Right or IR Virtual Currency,
regardless of whether there is a safe and practical way to custody and secure such Incidental Right or IR Virtual Currency. The legal
and regulatory analysis regarding an Incidental Right or IR Virtual Currency is not expected to be different between forks and airdrops;

      5

 · whether pricing data for such Incidental Right
or IR Virtual Currency is readily available;

 · the existence of a suitable market into which
the Incidental Right or IR Virtual Currency may be sold; and

 · whether claiming, owning, selling, or otherwise
taking any action in respect of Incidental Rights or IR Virtual Currency may create legal or regulatory risks, liability, or burdens of
any kind for the Trust, Sponsor, or Shareholders (including, without limitation, if such Incidental Rights or IR Virtual Currency is,
or may be, a security under federal securities laws).

In the event that an Incidental Right
or IR Virtual Currency reaches a threshold at which the Trust determines to recognize it following the assessment as described above,
and that such asset had a value that was deemed material to the Trust, it could impact the NAV of the Trust. In such scenario, the Trust
would take the asset into account for purposes of calculating NAV, relying on fair value in accordance with the fair value policies approved
by the Trustee.

The Trust may in the future abandon
any Incidental Rights and IR Virtual Currency.

Calculation of NAV

 7. Comment: We acknowledge your response to prior comment 28. Please note that we are continuing to
consider your response.

Response: Acknowledged.

The Trust’s Service Providers

 8. Comment: We note your response to prior comment 37 and re-issue. Please provide a separately captioned
section to describe the Prime Broker, including without limitation the material provisions of any material agreement between any transaction
party and the Prime Broker, the Prime Broker’s experience and operating history, the Prime Broker 's policies and procedures with
respect to any assets held by it on behalf of the Trust, how the Prime Broker will be compensated, and who will be responsible for any
fees associated with bitcoin transactions between the Authorized Participants, Bitcoin Custodian and Prime Broker. Please also disclose
whether or not assets of the Trust held at the Prime Broker will be held in segregated accounts, how much of the Trust's assets will be
held at the Prime Broker, and whether