SecProbe.io

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 December 6, 2022

VIA EDGAR

Timothy Worthington

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

 Re: WisdomTree Digital Trust

File Nos. 333-255575 and
811-23659

Dear Mr. Worthington:

This response is provided on behalf of WisdomTree
Digital Trust (the “Trust” or the “Registrant”) with respect to Staff comments received by phone on November 16,
2022, regarding post-effective amendments to the Trust’s Registration Statement on Form N-1A in order to register nine new series
of the Trust (the “A Filings”), which were filed with the U.S. Securities and Exchange Commission (“SEC”) on September
29, 2022. In creating nine new series of the Trust, the A Filings seek to register shares of the nine new funds of the Trust (each a “Fund”,
and collectively, the “Funds”) set forth below:

 · WisdomTree Floating Rate Treasury Digital Fund;

 · WisdomTree 3-7 Year Treasury Digital Fund;

 · WisdomTree 7-10 Year Treasury Digital Fund;

 · WisdomTree 500 Digital Fund;

 · WisdomTree Long-Term Treasury Digital Fund;

 · WisdomTree S&P 500 Twitter Sentiment Digital
Fund;

 · WisdomTree Short-Duration Income Digital Fund;

 · WisdomTree Technology and Innovation 100 Digital
Fund; and

 · WisdomTree TIPS Digital Fund.

The Staff’s comments and the Trust’s
responses are set forth below. Any text citation refers to text that will be included in 485(b) filings, which will be sent to the Staff
via email correspondence prior to the Funds’ effective date and filed via EDGAR on or before the Funds’ effective date. Capitalized
terms used, but not defined herein have the same meaning given to them in the A Filings.

WisdomTree Digital Management, Inc.  250 West 34th Street, 3rd
Floor, New York, NY 10119 | 212-801-2080 Tel 212-801-2081 Fax

WisdomTree Floating Rate Treasury Digital
Fund

Summary Prospectus- Principal Investment Strategies
of the Fund

 1. Comment: Page 1 - The following sentences of the section entitled “Principal Investment Strategies
of the Fund” state:

The Fund employs a “passive
management” – or indexing – investment approach designed to track the performance of the U.S. Treasury Floating Rate
Bond Index (the “Index”) through the use of a representative sampling strategy. Under normal circumstances, at least 80%
of the Fund’s net assets, plus the amount of any borrowings for investment purposes, will be invested in U.S. Treasury securities.

Please revise the “80%”
test to include floating rate bonds of the U.S. Treasury as opposed to only U.S. Treasuries.

Response: The Registrant
has revised the disclosure to refer to the component securities of the Index, whereby the disclosure now reads:

…at least 80% of the Fund’s
net assets, plus the amount of any borrowings for investment purposes, will be invested in component securities of the Index.

 2. Comment: Page 1 - The following sentence of the section entitled “Principal Investment Strategies
of the Fund” states:

The floating coupon rates of the FRNs
included in the Index are initially expected to reset weekly according to the result of the most recent 13-week T-bill auction, plus a
spread, subject to a minimum net yield of zero percent.

Please clarify the “spread”
this sentence is referring to and how the spread fits into the reset determination.

Response: For clarity,
the term “spread” has been revised to “fixed spread”, with the following new sentence added at the end of the
existing sentence:

The fixed spread is a percentage rate
based on supply and demand for the FRNs at time of issuance and is added to the floating base coupon rate of the FRN.

 3. Comment: Page 2 - The following sentence of the section entitled “Principal Investment Strategies
of the Fund” states:

A multiple-tiered screening process
is performed, as described in the Fund’s Prospectus.

Please provide a summary of what the
“multiple-tiered screening process” is.

Response: The preceding
sentence, which begins “At each reconstitution…”, together with the noted sentence, have been revised as follows, resulting
in removal of the reference to “multi-tiered screening process”:

At each reconstitution of the Index,
certain securities (i.e., FRNs meeting the aforementioned criteria) are eligible for inclusion in the Index.

     2

 4. Comment: Page 2 - The following sentence of the section entitled “Principal Investment Strategies
of the Fund” states:

At each reconstitution of the Index,
certain securities are eligible for inclusion in the Index.

Please confirm that “certain
securities” is referring to floating rate securities. If not, please elaborate on what this is referring to.

Response: Confirmed.
Please also see the response immediately above.

WisdomTree 3-7 Year Treasury Digital Fund

Summary Prospectus - Principal Investment Strategies
of the Fund

 5. Comment: Page 1 - There is a period missing at the end of the first sentence of the section entitled
“Principal Investment Strategies of the Fund.”

Response: The Registrant
has added a period to the end of this sentence.

 6. Comment: Page 1 - The following sentences of the section entitled “Principal Investment Strategies
of the Fund” state:

The Fund employs a “passive management”
– or indexing – investment approach designed to track the performance of the U.S. 3-7 Year Treasury Bond Index (the “Index”)
through the use of a representative sampling strategy. Under normal circumstances, at least 80% of the Fund’s net assets, plus the
amount of any borrowings for investment purposes, will be invested in U.S. Treasury securities.

Please confirm and disclose that the
dollar weighted average maturity is used for purposes of the 80% Test.

Response: The Registrant
has revised the disclosure to refer to the component securities of the Index, whereby the disclosure now reads:

…at least 80% of the Fund’s
net assets, plus the amount of any borrowings for investment purposes, will be invested in component securities of the Index.

Statement of Additional Information - Investment
Limitations - Concentration of Investments

 7. Comment: Page 11 - The following sentence of the subsection entitled “Concentration of Investments”
in the section entitled “Investment Limitations” of the Statement of Additional Information states:

Government securities, municipal securities
and bank instruments will not be deemed to constitute an industry.

Please confirm that the Fund will look
through for any private activity of the “municipal securities” whose principal and interest are derived principally from assets
and revenues of non-governmental entities in order to determine the industry to which the investments should be allocated when determining
the Fund’s concentration of investments within industries.

     3

Response: Investment
Company Act Release 9785 (May 31, 1977) states that the concentration policy required by Section 8(b)(1)(E) of the Investment Company
Act of 1940 does not apply to “investments in tax-exempt securities issued by governments or political subdivisions of
governments since such issuers are not members of any industry.” (emphasis added). To the extent that the Fund invests
in a private activity municipal debt security issued by a non-governmental entity, the Fund will, to the extent practicable,
look through to such non-governmental issuer’s industry for purposes of applying the Fund’s concentration policy.
In any event, for all practical purposes, due to the Fund’s and 80% policy to invest in applicable U.S. Treasury securities, it
could not, by definition, concentrate its investments in municipal securities without changing its objective and name.

WisdomTree 7-10 Year Treasury Digital Fund

Summary Prospectus - Principal Investment Strategies
of the Fund

 8. Comment: Page 1 - The following sentences of the section entitled “Principal Investment Strategies
of the Fund” state:

The Fund employs a “passive management”
– or indexing – investment approach designed to track the performance of the U.S. 7-10 Year Treasury Bond Index (the “Index”)
through the use of a representative sampling strategy. Under normal circumstances, at least 80% of the Fund’s net assets, plus the
amount of any borrowings for investment purposes, will be invested in U.S. Treasury securities.

Please confirm and disclose that the
dollar weighted average maturity is used for purposes of the 80% Test.

Response: The Registrant
has revised the disclosure to refer to the component securities of the Index, whereby the disclosure now reads:

…at least 80% of the Fund’s
net assets, plus the amount of any borrowings for investment purposes, will be invested in component securities of the Index.

WisdomTree 500 Digital Fund

Summary Prospectus - Principal Investment Strategies
of the Fund

 9. Comment: Page 1 - The following sentences of the section entitled “Principal Investment Strategies
of the Fund” states:

The Index is maintained by WisdomTree
Investments, Inc. (“WisdomTree Investments”) and consists of the 500 largest companies domiciled and listed in the U.S. To
be eligible for inclusion in the Index, a company must meet the following criteria as of the annual Index screening date: (i) market capitalization
of at least $100 million; and (ii) average daily dollar trading volume of at least $200,000 for each of the preceding six months. The
Index is reconstituted annually, and constituents are weighted using modified market capitalization.

     4

The index provider “WisdomTree
Investments, Inc.” appears to be an affiliate of WisdomTree Digital Management, Inc. If confirmed, please disclose that the index
provider is an affiliate and further disclose any conflicts of interest that arise as a result of such affiliation.

Response: The Registrant
confirms that WisdomTree Investments, Inc. is an affiliate of WisdomTree Digital Management, Inc. The Registrant has made the requested
changes to this section and the section entitled, “Additional Non-Principal Risk Information” in order to disclose that WisdomTree
Investments, Inc. is an affiliate of WisdomTree Digital Management, Inc. and to disclose the relevant conflicts of interest.

Statement of Additional Information - Investment
Limitations - Concentration of Investments

 10. Comment: Page 14 - The following sentence of the subsection entitled “Concentration of Investments”
in the section entitled “Investment Limitations” of the Statement of Additional Information” states:

The Fund will not make investments
that will result in the concentration of its investments in the securities of issuers primarily engaged in the same industry.

Please revise to clarify that the Fund
will concentrate its investments to the extent that the Index will be concentrated and align with existing disclosure in the Prospectus.

Response: The Registrant
has made the requested changes to the section of the Statement of Additional Information entitled, “Concentration of Investments.”

WisdomTree Long-Term Treasury Digital Fund

Summary Prospectus - Principal Investment Strategies
of the Fund

 11. Comment: Page 1 - The following sentences of the section entitled “Principal Investment Strategies
of the Fund” state:

The Fund employs a “passive management”
– or indexing – investment approach designed to track the performance of the U.S. 20+ Year Treasury Bond Index (the “Index”)
through the use of a representative sampling strategy. Under normal circumstances, at least 80% of the Fund’s net assets, plus the
amount of any borrowings for investment purposes, will be invested in U.S. Treasury securities.

 Please confirm and disclose
that the dollar weighted average maturity is used for purposes of the 80% Test.

Response: The Registrant
has revised the disclosure to refer to the component securities of the Index, whereby the disclosure now reads:

…at least 80% of the Fund’s
net assets, plus the amount of any borrowings for investment purposes, will be invested in component securities of the Index.

     5

WisdomTree S&P 500 Twitter Sentiment
Digital Fund

Summary Prospectus - Principal Investment Strategies
of the Fund

 12. Comment: Page 1 - The following sentence of the section entitled “Principal Investment Strategies
of the Fund” states:

Sentiment scores are derived from an
analysis of a daily feed of Tweets containing “cash-tags” that reference the equity symbol of a company, which is filtered
to exclude Tweets identified as spam and to take into account minimum account age, number of followers, minimum number of Tweets per day,
and other criteria based on the judgment of an S&P Dow Jones Indices’ Index Committee (the “Index Committee”) and
market conditions.

Please explain in this section what
is meant by “cash-tags”.

Response: The sentence
has been revised as follows, with explanatory language added as new sentences:

Sentiment scores are derived from an
analysis of a daily feed of Tweets containing “cash-tags”. A “cash-tag” is a company’s ticker symbol preceded
by the U.S. dollar sign. For example, $HPE is the “cash-tag” for Hewlett Packard, with a ticker symbol of HPE. The cash-tag
is a way for Twitter users to click on a company’s ticker symbol and see related Tweets. The cash-tag data is filtered to exclude
Tweets identified as spam and to take into account minimum account age, number of followers, minimum number of Tweets per day, and other
criteria based on the judgment of an S&P Dow Jones Indices’ Index Committee (the “Index Committee”) and market conditions.

 13. Comment: Page 1 - With regards to the sentence referenced in Comment 12 above, please clarify the
meaning of “equity symbol”. For instance, is this referring to a ticker symbol or the name of a company?

Response: The reference
to “equity symbol” has been changed to “ticker symbol.” The revised language is also included in the response
immediately above.

 14. Comment: Page 1 - With regards to the phrase in the sentence referenced in Comment 12 above that
reads, “. . . which is filtered to exclude Tweets identified as spam and to take into account minimum account age, number of follows,
minimum number of Tweets per day, and other criteria based on the judgment of an S&P Dow Jones Indices’ Index Committee (the
“Index Committee”) and market conditions”, please address the following comments:

 a. Redraft this phrase for clarity and in plain English.

 b. Disclose the minimum account age and the minimum number of Tweets.

 c. Explain the meaning of “other criteria” as used in the phrase quoted above.

 d. Explain the meaning of “market conditions” in the Index’s methodology. In addition,
how does “market conditions” relate to the remainder of the Index’s conditions listed in this phrase?

     6

Response: Please see
the Registrant’s responses to each of these comments in turn:

 a. The Registrant has redrafted this phrase for clarity and in plain English as follows:

. . . which is filtered to exclude
Tweets identified as spam and to exclude Tweets from accounts that do not meet criteria for minimum account age, minimum number of followers,
minimum number of Tweets per day, maximum (excessive) cash tags in a Tweet and other criteria, which may change from time to time based
on the judgment of the S&P Dow Jones Indices’ Index Committee, including based on market conditions (the “Index Committee”).
The goal of the foregoing filters is to seek to ensure that the sentiment score appropriately captures the sentiment expressed by users
Tweeting about companies in the S&P 500 Index.

 b. The actual minimums and maximum are proprietary to the model employed by S&P Dow Jones Indices
LLC. The Registrant believes that the pertinent information for the prospectus and Fund shareholders is to understand the overall methodology
employed, including general filters in place, in seeking to determine the 50 companies for inclusion in the Index out of the 500 companies
in the S&P 500 Index.

 c. “Other criteria” is primarily intended to capture Tweets included in cer