SecProbe.io

CORRESP
1
filename1.htm

April
4, 2025

Via
EDGAR Correspondence

Christopher
R. Bellacicco

United States Securities and Exchange Commission

Division of Investment Management

100
F Street, N.E.

Washington, D.C. 20549

    Re:
    Valkyrie
    ETF Trust II

File
    Nos. 333- 258722; 811- 23725

Dear
Mr. Bellacicco:

This
letter responds to your comments delivered telephonically on April 3, 2025 regarding the registration statement filed on Form N-1A
for Valkyrie ETF Trust II (the “Registrant”) with the staff of the Securities and Exchange Commission (the “Staff”)
on January 17, 2025 (the “Registration Statement”). The Registration Statement relates to the CoinShares Digital Asset
ETF (the “Fund”), a series of the Registrant. Capitalized terms used herein, but not otherwise defined, have the meanings
ascribed to them in the Registration Statement.

Comment
1 – Principal Investment Strategies

The
Staff notes the revisions made in response to prior Comment 5. Please supplementally discuss the consequences of removing asset and liquidity
thresholds and consider whether additional principal risk disclosure is necessary as a result.

Response
to Comment 1

The
Fund notes that each of the Digital Asset ETPs is offered on a continuous basis and offers daily liquidity according to their own operations.
Accordingly, the Fund does not believe that any particular liquidity threshold is necessary, which is why it was struck from the original
investment strategy. Given the expected liquidity of the assets, the Fund does not believe any additional risk disclosure is necessary.

Comment
2 – Risk Factors

The
Staff notes your response to prior Comment 11. Please supplementally explain the use of a 20% threshold for updating prospectus disclosure
for specific risks regarding a “non-significant” position in a digital asset.

Response
to Comment 2

After
considering the Staff’s comments, the Fund will undertake to update the prospectus disclosure if a position equals or exceeds 10%
of the assets of the Fund.

Comment
3 – General

The
Staff notes your response to prior Comment 22. Please supplementally confirm that the “Covered Securities” require pre-clearance.

Response
to Comment 3

The
Fund confirms that the “Covered Securities” require pre-clearance.

Comment
4 – Prospectus Summary

The
Staff notes the completed fee table provided in Exhibit A in response to prior Comment 2 includes an expense waiver that is set to expire
on December 31, 2025. Pursuant to Instruction 3(e) to Item 3 of Form N-1A, an expense waiver must be in place for at least one year to
be included in a fee table.

Response
to Comment 4

Pursuant
to the Staff’s comment, the expense waiver has been removed from the fee table.

* * * * * * * *

Please
call me at (312) 845-3484 or my colleague James Audette at (312) 845-3421 if you have any questions or issues you would like to discuss
regarding these matters.

    Sincerely yours,

    Chapman and Cutler llp

    By:
    /s/
    Morrison C. Warren

    Morrison
    C. Warren

 cc: James
Audette, Esq., Chapman and Cutler LLP

Exhibit
A

CoinShares Digital Asset ETF

Annual
Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)

    Management Fees
    0.40%

    Distribution and Service (12b-1) Fees
    0.00%

    Other Expenses(1)
    0.00%

    Tax Expense(2)
    0.00%

    Acquired Fund
    Fees and Expenses
    0.00%

    Total Annual Fund Operating Expenses
    0.40%

    1.      Estimate based on the expenses the Fund expects to incur for the current fiscal year.

    2.      Tax Expense is based on actual performance of the Fund and not possible to estimate.

Example

This
example is intended to help you compare the cost of investing in the Fund with the cost of investing in other funds.

This
example assumes that you invest $10,000 in the Fund for the time periods indicated and then sell all of your Shares at the end of those
periods. The example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain
at current levels. This example does not include the brokerage commissions that investors may pay to buy and sell Shares.

    1
    Year
    3
    Years

    Although
    your actual costs may be higher or lower,  your costs, based on these assumptions, would be:
    $41
    $128