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CORRESP
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[Chapman
and Cutler LLP Letterhead]

February
7, 2024

VIA
EDGAR CORRESPONDENCE

Lisa
N. Larkin

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: Valkyrie
ETF Trust II (the “Trust”)

  File
Nos. 333-258722; 811-23725

Dear
Ms. Larkin:

This
letter responds to your comments received by email on June 28, 2023, regarding the Post-Effective Amendment No. 18 under the Securities
Act of 1933, as amended, and Amendment No. 22 under the Investment Company Act of 1940, as amended, filed as an amendment to Valkyrie
ETF Trust II’s (the “Trust”) Registration Statement (collectively, the “Amendment”) with
the staff of the Securities and Exchange Commission (the “Staff”) on May 15, 2023. The Amendment relates to the Valkyrie
Bitcoin Futures Leveraged Strategy ETF (the “Fund”), a series of the Trust. Capitalized terms used herein, but not
otherwise defined, have the meanings ascribed to them in the Registration Statement.

Comment
1 – Bitcoin and Bitcoin Futures

Disclosure
in the section titled, “Important Information About the Fund” states that the Fund does not attempt to replicate an index
or any multiple or inverse of an index for a single day or any other time period.” Disclosure in the section titled, “Principal
Investment Strategies” states that the Fund “seeks to achieve its investment objective by investing its assets in futures
contracts on bitcoin and other Financial Instruments . . . that provide investment exposure to the price of bitcoin. . .” Please
tell us how the Fund determines “the price of bitcoin.”

Response
to Comment 1

The
Fund’s investment strategy has been revised such that it seeks daily investment results, before fees and expenses, that correspond
to two times (2x) the return of the S&P CME Bitcoin Futures Index Excess Return (the “Index”) (the “Index”).
Accordingly, the Fund does not determine the “price of bitcoin” and rather is has exposure to the value of bitcoin through
the value of futures contracts that track the level of the Index. Any accompanying disclosure to the contrary has been revised, as reflected
in the revised preliminary prospectus attached hereto as Exhibit A.

Comment
2 – Bitcoin and Bitcoin Futures

Please
explain in greater detail to the Staff how the Fund intends to obtain the targeted 1x-2x exposure. Does the Fund intend to do that solely
via investment in U.S. exchange-traded bitcoin futures (“bitcoin futures”) through the commodity subsidiary (the “Subsidiary”)?
In your explanation to the Staff, please discuss the impact of high margin requirements associated with bitcoin futures on the Fund’s
ability to obtain the targeted 1x-2x exposure via investments in bitcoin futures.

Response
to Comment 2

As
noted above, the Fund’s investment strategy no longer seeks performance of 1x-2x exposure, and rather uses a fixed daily sought-after
return of 2x the return of the Index. The Fund will seek its daily 2x return of the Index primarily through its investment in bitcoin
futures, which is effectuated through the Subsidiary. As the Staff notes, there are margin requirements associated with the investment
in bitcoin futures, and the Fund will invest in “Collateral Investments” in order to meet such requirements. Collateral Investments
consist of high-quality securities, including:

(1)
U.S. Government securities, such as bills, notes and bonds issued by the U.S. Treasury; (2) money market funds; and/or (3) corporate
debt securities, such as commercial paper and other short-term unsecured promissory notes issued by businesses that are rated investment
grade or determined by the Adviser to be of comparable quality.”

In
accordance with the tax laws applicable to regulated investment companies (“RICs”) the Fund’s investment in
the Subsidiary will not exceed 25% of the fund’s total assets at or around each quarter end of the Fund’s fiscal year. At
other times, the Fund’s investments in the Subsidiary may significantly exceed 25% in order to meet its sought-after exposure.
When it needs to reduce its investment in the Subsidiary to comply with the RIC Asset Diversification Test, it will invest in reverse
repurchase agreements, other investment companies, bitcoin-linked ETPs and other investments as disclosed in the prospectus. Disclosure
has been added to the preliminary prospectus that details that there can be no guarantee that the Fund will ever meet its targeted 2x
daily return, and during days its portfolio is changed due to the tax laws this risk is greater. This management of the Fund’s
assets, including with respect to the high margin requirements associated with bitcoin futures, is consistent with other currently effective
ETFs that seek exposure to bitcoin futures, and seek leveraged bitcoin futures, that have presented this same issue.

Comment
3 – Bitcoin and Bitcoin Futures

Please
describe how you would expect the Fund to perform during significant daily downturns in the price of bitcoin and bitcoin futures, such
as those that occurred on June 13, 2022 and November 8 and 9, 2022.

 a. Would
                                            such price changes impact the Fund’s operations, including the Fund’s creation
                                            process and/or its ability to meet its investment objective and execute on its principal
                                            strategies?

    2

 b. Would
                                            margin requirements during the months of June and November 2022 have prevented the Fund from
                                            carrying out its strategy?

 c. What
                                            would you expect to occur in terms of discounts or premiums in response to significant changes
                                            in secondary market demand for Fund shares? For example, describe the potential impact on
                                            the Fund’s premium (or discount) if a large number of investors (e.g., more than 50%
                                            of net assets) were to buy (or sell) shares.

Response
to Comment 3

The
Fund does not anticipate that its operations would be materially affected by price dislocations in the bitcoin and bitcoin futures markets
such as occurred on June 13, 2022 (a 16% decline in the value of bitcoin), November 8, 2022 (a 12.6% decline in the value of bitcoin)
and/or November 9, 2022 (a 6.16% decline in the value of bitcoin). Bitcoin futures trading volumes, which have ranged between $500 billion
and $1.5 trillion over the past twelve months (Jan 2023 to Jan 2024 (https://www.theblock.co/data/crypto-markets/futures/volume-of-bitcoin-futures-monthly),
indicates liquidity sufficient for normal operation of the Fund. Margin requirements during the dates noted would not be a hindrance
to the Fund carrying out its strategy.

On
days of extraordinary buying or selling demand for the Fund’s Shares, it is possible that premiums or discounts to the Fund’s
NAV may be larger than would normally be that case. However, the Fund expects that Authorized Participants and other market makers will
detect arbitrage opportunities which would have the effect of lessening those premiums or discounts and reducing that time that any significant
premium or discount exists.

Comment
4 – Bitcoin and Bitcoin Futures

Please
provide simulated performance for a hypothetical $10,000 invested in the Fund on January 1 through December 31, 2022. Please include
projected daily, weekly, monthly, and annual performance data for the simulated period.

Response
to Comment 4

The
requested information will be provided to Staff under separate cover.

Comment
5 – Bitcoin and Bitcoin Futures

Please
provide a VaR calculation as required under rule 18f-4 under the 1940 Act for the simulated portfolio for each day in the months of June
and November 2022. Also include the same calculation for the index the Fund will use as the designated reference portfolio.

Response
to Comment 5

The
Fund will use the relative VaR test for compliance with Rule 18f-4, and the designated reference portfolio will be the Index. Given that
the Fund’s investment objective is to achieve 2x the performance of the Index, before fees and expense, it is not expected that
the VaR of the Fund would
exceed 200% of the VaR of the Index in the ordinary course. The Fund will comply with the Derivatives Risk Management Program approved
by the Board, including the required reporting to the Board of any exceedances of the Program’s guidelines and, in the case of
an event specified in Form N-RN, reports with the Commission on such Form.

    3

Comment
6 – Bitcoin and Bitcoin Futures

Please
supplementally indicate when the Fund expects to launch.

Response
to Comment 6

We
have been advised by the Fund’s investment adviser that it anticipates launching the Fund as soon as practicable.

Comment
7 – Bitcoin and Bitcoin Futures

Please
consider including “Daily” in the Fund’s name inasmuch as the Fund seeks up to 2x returns for a single day and not
any other period.

Response
to Comment 7

After
consideration, the Fund respectfully declines the Staff’s comment. In its consideration, it noted that another daily 2x leveraged
bitcoin ETF, the “2x Bitcoin Strategy ETF” does not include “Daily” in its name. The Fund believes that “Valkyrie
Bitcoin Futures Leveraged Strategy ETF” remains consistent with the requirements of the Investment Company Act of 1940, as amended
(the “1940 Act”) and the rules promulgated thereunder.

Comment
8 – Bitcoin and Bitcoin Futures

Please
inform us whether the Fund anticipates any capacity constraints in the bitcoin futures market that would limit the size of the Fund’s
exposure to bitcoin futures, and explain to us how the Fund will monitor market capacity as new participants enter the market.

Response
to Comment 8

The
Fund does not anticipate any capacity constraints with respect to the bitcoin futures market. Bitcoin futures trading volumes, which
have ranged between $500 billion and $1.5 trillion over the past twelve months (Jan 2023 to Jan 2024 (https://www.theblock.co/data/crypto-markets/futures/volume-of-bitcoin-futures-monthly),
indicates liquidity sufficient for normal operation of the Fund. To the extent any position limits are imposed by the Fund’s FCM’s
and/or the exchanges on which the Fund’s bitcoin futures contracts change or there are any liquidity issues in the bitcoin futures
markets, the Fund may be unable to achieve its investment objective. The Fund notes it has risk factors in its prospectus disclosing
this risk.

Comment
9 – Bitcoin and Bitcoin Futures

    4

Please
explain the Fund’s plans for Liquidity Management, including during both normal and reasonably foreseeably stressed conditions.
Given the inability of exchange-traded funds to close to new investors, please explain in the Summary Prospectus how the Fund will manage
liquidity should the Fund become so large as to require more liquidity than the market can provide to meet potential redemptions. In
your response, please address the impact of exceeding certain thresholds, such as Futures Commission Merchant (“FCM”)-imposed
capacity limits or the Chicago Mercantile Exchange’s (“CME’s”) position limits for a given contract, and whether
these circumstances (or others) may cause the Fund to reduce its leverage to less than 1x-2x.

Response
to Comment 9

The
Fund has added the requested disclosure in accordance with the Staff’s comment.

Comment
10 – Bitcoin and Bitcoin Futures

Please
supplementally confirm whether the Fund has lined up an FCM and who that FCM is.

Response
to Comment 10

Marex
will serve as the Fund’s FCM.

Comment
11 – Bitcoin and Bitcoin Futures

Please
provide the Staff with an outline of the Fund’s plans for complying with rule 18f-4 under the 1940 Act, including a preliminary
overview of the key elements of the derivatives risk management program. In responding to this comment, please confirm that the Fund
will use relative VaR to comply with the rule given the Fund’s expected leverage and provide the designated reference portfolio.
As part of your answer, please discuss whether the designated index is unleveraged.

Response
to Comment 11

The
Fund, as described in its investment objective, seeks to provide daily investment results that, before fees and expenses, correspond
to two times (2x) the daily performance of the Index (the S&P CME Bitcoin Futures Index Excess Return (the “Index”))
(the “Designated Index”). Rule 18f04(a) provides that “if the fund’s investment objective is to track
the performance (including a leverage multiple or inverse multiple) of an unleveraged index, the fund must use that index
as its designated reference portfolio” (emphasis added). Accordingly, the Fund is required by Rule 18f-4 to use the Designated
Index as the designated reference portfolio. Page 103 of the Rule 18f-4 adopting release states “[a] few commenters requested clarification
regarding when an index would be “leveraged.” These commenters urged that an index should be considered leveraged if it seeks
a multiple of returns, but not solely because it includes derivative instruments. . . We agree that whether a particular index is ‘leveraged’
would depend on the economic characteristics of the index constituents, and not just whether some or all of the constituents are derivatives.
An index would be levered if, for example, the derivatives included in the index multiply the returns of the index or index constituents,
as suggested by these commenters.” The Designated Index does not seek a multiple of returns and accordingly is not considered leveraged.
The Fund is required to use the Relative VaR test to test its compliance with Rule 18f-4.

    5

The
Fund’s portfolio transactions will be conducted pursuant to a written derivatives risk management program, which includes policies
and procedures that are reasonably designed to manage the risks of such Fund’s usage of derivatives, as required by Rule 18f-4.
The program is administered and overseen by a committee that has been designated by the Fund’s board of trustees as the derivatives
risk managers.1 The program will identify and provide an assessment of the Fund’s derivatives usage and risks as they
pertain to the Fund’s usage of futures contracts. The program will provide risk guidelines that, among other things, consider and
provide for (1) limits on the Fund’s derivatives exposure; (2) monitoring and assessment of the Fund’s exposure to illiquid
investments (if any); (3) monitoring and assessment of the credit quality of the Fund’s counterparties; and (4) monitoring of margin
requirements, position limits and position accountability levels. Additionally, the program will provide for stress testing, back-testing,
internal reporting and escalation, and periodic review in compliance with Rule 18f-4. Data relating to such functions will be made available
by a third-party service provider engaged by the Fund, for analysis and monitoring by the Fund’s derivatives risk manager.

Comment
12 – Bitcoin and Bitcoin Futures

Please
supplementally discuss how the Fund would value its bitcoin futures positions if the CME halted the trading of bitcoin futures due to
price limits or otherwise.

Response
to Comment 12

If
the CME halted the trading of bitcoin futures, the Adviser, as valuation designee, would be responsible for fair valuing the bitcoin
futures held by the Fund.

Comment
13 – Bitcoin and Bitcoin Futures

Please
confirm that the Fund’s code of ethics applies to transactions in bitcoin and bitcoin futures and that all employees will be required
to pre-clear such transactions.

Response
to Comment 13

The
Fund confirms that the code of ethics of the Trust, which the Fund is a series thereof, applies to such transactions.

Comment
14 – Bitcoin and Bitcoin Futures

Please
supplementally provide to Staff information about the Fund’s discussions with po