SecProbe.io

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November 2, 2023

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 September
29, 2023, regarding post-effective amendments to the Trust’s Registration Statement on Form N-1A (the “B Filings”),which
were filed with the U.S. Securities and Exchange Commission (“SEC”) on June 2, 2023in relation to completing the registration
of three new series of the Trust (each a “Fund”, and collectively, the “Funds”) set forth below:

 · WisdomTree Siegel Longevity Digital Fund

 · WisdomTree Siegel Global Equity Digital Fund

 · WisdomTree Siegel Moderate Digital Fund (together with the WisdomTree Siegel Longevity Digital Fund, and
WisdomTree Siegel Global Equity Digital Fund, each a “Siegel Fund” and together, the “Siegel Funds”)

The Staff’s comments (which include comments
to draft prospectuses and SAIs provided to the Staff via e-mail) and the Trust’s responses are set forth below. Although the Funds
are currently effective, the Funds have not commenced operations and will be changing their objective (among other changes) pursuant to
485(a) filings. Any text citation refers to text that will be included in 485(a) filings, which will be filed via EDGAR. Capitalized terms
used, but not defined herein have the same meaning given to them in the A Filings.

Global Comments

 1. Comment: To the extent applicable, please apply comments given to the WisdomTree Sigel Longevity
Digital Fund to other Siegel Funds.

Response: The Registrant confirms
that, as applicable, global comments have been incorporated into the amended filings.

WisdomTree Digital Management, Inc.

 2. Comment: Please confirm supplementally that the Registrant will change the names of the Siegel
Funds if Dr. Siegel is no longer involved with WisdomTree or if the Adviser no longer takes into account his economic research and insights.

Response: The Registrant confirms
that if Dr. Siegel becomes no longer associated with the Adviser as an economic consultant, Dr. Siegel’s name will be removed from
the names of the Siegel Funds.

WisdomTree Longevity Digital Fund

Summary Prospectus – Principal Investment
Strategies of the Fund

 3. Comment: The first paragraph of the section entitled “Principal Investment Strategies of
the Fund,” states:

Professor Siegel’s most widely
read work, Stocks for the Long Run, provided investors with a paradigm for investing and building wealth in the 21st century. Professor
Siegel has written and lectured extensively about the economy and financial markets, and Professor Siegel is a regular contributor to
the financial news media providing his views on such matters.

Please delete this language as it is
not particularly relevant to the Fund’s strategy, or revise to explain how Dr. Siegel’s research specifically ties to the
longevity focus strategy utilized by the Adviser.

Response: The Registrant confirms
that it has deleted the referenced language as requested by the Staff.

 4. Comment: The second paragraph of the section entitled “Principal Investment Strategies of
the Fund,” states:

The Fund’s asset allocation
approach, leveraging the Siegel Insights and Research, is designed to challenge the more traditional 60/40 allocation (i.e., 60% equities/40%
fixed income) by focusing on attributes designed for increased longevity to reflect that people are generally living longer.

Please explain what the referenced “attributes”
are and how such attributes affect the Adviser’s determination of the Fund’s asset allocation. Are these attributes of a particular
equity or fixed income mix, or attributes of individual issuers?

Response: The Registrant has
removed the word “attributes” and revised the disclosure to make clear that the focus is instead on a greater allocation to
equities. The reference disclosure now states as follows:

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The Fund’s asset allocation approach,
leveraging the Siegel Insights and Research, is designed to challenge the more traditional 60/40 allocation (i.e., 60% equities/40% fixed
income) by weighting the allocation more toward equities. This approach seeks to improve the potential for outperformance over a longer
time horizon (i.e., greater than ten years) in order to address increased longevity as people are generally living longer.

 5. Comment: The second paragraph of the section entitled “Principal Investment Strategies of
the Fund” states:

Accordingly, under normal circumstances,
the Fund provides a greater than 60% allocation to equity investments (including U.S. and international, and may include emerging markets),
which exhibit higher dividend yields, in seeking to outperform the market by achieving higher income generation and/or lower valuation
ratios ( a valuation ratio helps in assessing whether a particular company or companies may be undervalued when comparing the value of
such company or companies with a fundamental financial metric, such as company earnings (price-to-earnings), book value (price-to-book),
sales (price-to-sales) or cash flow (price-to-cash flow)). Accordingly, the Adviser seeks to include such undervalued companies in its
asset allocation process.

Please explain how the Fund’s
longevity strategy affects the Adviser’s analysis of “undervalued companies” in its asset allocation process and the
relative weight given to any of “financial metric[s].”

Response: The Registrant has
revised the disclosure to make clear that the longevity focus is addressed through the greater allocation to equities, not through a specific
financial metric nor inclusion of undervalued companies. The reference disclosure now states as follows:

Accordingly, under normal circumstances,
the Fund provides a greater than 60% allocation to equity investments (including U.S. and international, and may include emerging markets).
In addition, in generally seeking higher income generation and market outperformance potential, the allocation to equities also focuses
on including equities that exhibit higher dividend yields and/or lower valuation ratios (a valuation ratio helps in assessing whether
a particular company or companies may be undervalued when comparing the value of such company or companies with a fundamental financial
metric, such as company earnings (price-to-earnings), book value (price-to-book), sales (price-to-sales) or cash flow (price-to-cash flow)).

 6. Comment: The second paragraph of the section entitled “Principal Investment Strategies of
the Fund” states:

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With respect to its investment in
fixed income securities, the Fund may invest in domestic or foreign securities, corporate or sovereign, and of any quality, maturity or
duration.

Please consider adding appropriate principal
risks associated with “corporate or sovereign” securities.

Response: The Registrant has
removed the reference to sovereign debt securities as the Fund will not have exposure to such securities as part of its principal investment
strategies. With respect to the corporate debt securities, the Registrant has added the following additional fixed income related risk
language in the section entitled “Principal Risks of Investing in the Fund”:

Income Risk. The
Fund is subject to the risk that its income will decline because of falling interest rates. Income risk is generally high for short-term
bond funds, so investors should expect the Fund’s income to fluctuate.

Interest Rate Risk. Interest
rate risk is the risk that fixed income securities will decline in value because of an increase in interest rates and changes to other
factors, such as perception of an issuer’s creditworthiness. Funds with higher durations generally are subject to greater interest
rate risk. For example, the price of a security with a three-year duration would be expected to drop by approximately 3% in response to
a 1% increase in interest rates.

Issuer Credit Risk. The
financial condition of an issuer of a debt security or other instrument may cause such issuer to default, become unable to pay interest
or principal due or otherwise fail to honor its obligations or cause such issuer to be perceived (whether by market participants, rating
agencies, pricing services or otherwise) as being in such situations. The value of an investment in the Fund may change quickly and without
warning in response to issuer defaults, changes in the credit ratings of the Fund’s portfolio investments and/or perceptions related
thereto.

 7. Comment: The third paragraph of the section entitled “Principal Investment Strategies of
the Fund” states:

The ETFs in which the Fund invests
shall be referred to as the “Underlying Funds.” Since the strategies of a significant portion of the ETFs made available by
WisdomTree Asset Management, Inc. (“WisdomTree ETFs”), an affiliate of the Adviser, track indexes or have strategies that
are grounded in the Siegel Insights and Research, it is anticipated that a significant portion of the Underlying Funds (i.e., greater
than 50% of the allocation) will include WisdomTree ETFs.

Please change the phrase “are
grounded in” to “incorporate.”

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Response: The Registrant has
changed the phrase from “are grounded in” to “are consistent with” as it believes that is more accurate than using
the word “incorporate.”

 8. Comment: The third paragraph of the section entitled “Principal Investment Strategies of
the Fund” states:

Asset allocations may fluctuate over
time and may occur with different frequencies.

Please clarify the statement to explain
that the Adviser may change the allocation to Underlying Funds in its discretion. Also, please add disclosure separately to explain how
the Adviser determines the equity-fixed income allocations at any particular time.

Response: The Registrant confirms
that it has made such changes as requested by the Staff, and the reference disclosure now states:

Asset allocations may fluctuate over
time and may occur with different frequencies and the Adviser may change the asset class allocations, Underlying Funds or the target weightings
in the Underlying Funds in its discretion and without notice to, or approval by, shareholders, although it is anticipated that the Fund
will have less overweight to equities to the extent the Adviser views the equity markets as being less favorable for outperformance.

The Registrant also refers the Staff
to the additional disclosure added in response to comments 4 and 5 above.

 9. Comment: The last paragraph of the section entitled “Principal Investment Strategies of the
Fund” states:

WisdomTree currently uses Standard
& Poor’s Global Industry Classification Standards (“S&P GICS”) to define equity securities within a sector.

Please supplementally confirm that the
Fund will not concentrate in a particular industry and that when running the concentration test, the Fund will look through the Underlying
Funds.

Response: The Registrant confirms that the Fund
will not concentrate in a particular industry and has removed such language. Although the Registrant is not aware of any written SEC or
Staff requirement to look through to an Underlying Fund’s holdings when determining compliance with a fund’s industry concentration
limit, the Registrant confirms that the Fund will monitor the holdings in the WisdomTree ETFs to ensure compliance when determining industry
concentration and, as part of such monitoring, the Fund will treat investments in the WisdomTree ETFs as if held directly by the Fund
for purposes of determining industry concentration.

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Summary Prospectus – Principal Risks
of Investing in the Fund

 10. Comment: With regards to the disclosure “Underlying Fund Risk” in the section entitled
“Principal Risks of Investing in the Fund,” please explain potential conflict of interest with respect to the fact that the
Fund will be investing primarily in Underlying Funds that are affiliated with the Adviser. Also, please add disclosure that states to
the effect that not withstanding such conflicts, the Adviser has a fiduciary duty to the Fund and must act in the best interest of the
Fund.

Response: In response to the
request regarding the potential conflicts of interest, the Registrant has inserted the below disclosure into the section entitled “Principal
Risks of Investing in the Fund.”

Conflicts of Interest Relating to
Investment in Affiliated Funds Risk. The Fund’s asset allocation is constructed by the Fund’s Adviser and implemented
by the Sub-Adviser and Underlying Funds are expected to consist primarily of Underlying Funds managed by an affiliate of the Adviser unless
there is no such ETF that is consistent with the desired asset allocation within the Fund’s strategy. As a result, the Adviser is
subject to a potential conflict of interest in doing so because the Adviser is affiliated with the investment manager to such Underlying
Funds and the advisory fees paid by such Underlying Funds managed by the affiliated investment manager may be higher than fees paid by
other funds managed by unaffiliated investment managers. Further, the Adviser and Sub-Adviser have an incentive to allocate investments
to the WisdomTree ETFs in order to generate additional fees for themselves or their affiliate.

Additionally, the Registrant has
inserted the below sentence into the introductory paragraph of the same section.

Because the Fund invests primarily
in Underlying Funds, the Fund is subject to the risks associated with the Underlying Funds in which it invests.

With respect to the request regarding
fiduciary duty, the Registrant respectively declines to add language that the Adviser has a fiduciary duty to the Fund and must act in
the best interest of the Fund as it does not believe it is required or standard in the industry to include such language.

 11. Comment: In the section entitled “Principal Risks of Investing in the Fund,” please
change the name of the disclosure “Manger Risk” to “Active Management Risk.”

Response: The Registrant confirms
that it has made such change as requested by the Staff.

 12. Comment: With regards to the disclosure “Foreign Securities Risk” in the section entitled
“Principal Risks of Investing in the Fund,” please include the risk associated with emerging markets’ foreign sovereign
debt as it is mentioned in the strategy section.

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Response: As the Registrant,
in response to Comment 6, has removed the reference to sovereign debt securities from the section entitled “Principal Investment
Strategies,” the Registrant respectfully declines to make any further change in the reference risk disclosure. Additionally, in
the section entitled “Additional Principal Risk Information About the Fund,” the Registrant includes disclosure named “Emerging
Markets Risk” as a subset of “Foreign Securities Risk.”

* * * * *

    Sincerely,

    /s/Ryan Louvar

    Ryan Louvar, Esq.

    cc:
    Todd Zerega, Esq. (Perkins Coie LLP)

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