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    Chapman and Cutler LLP
 1801 K Street NW
 7th Floor
 Washington, DC. 20006

                           T 202-478-6492

May 20, 2025

VIA EMAIL AND EDGAR CORRESPONDENCE

Michael Rosenberg

Division of Investment Management

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: Volatility Shares Trust; File Nos. 333-263619; 811-23785

Dear Mr. Rosenberg:

This letter responds to your
additional comments, provided by phone on May 15, 2025, regarding Post-Effective Amendment Nos. 65-67 under the Securities Act of 1933
and Amendment Nos. 67-69 under the Investment Company Act of 1940 to the registration statement filed on Form N-1A by Volatility
Shares Trust (the “Registrant”) with the U.S. Securities and Exchange Commission (the “Commission”)
on March 7, 2025 (each, a “Registration Statement” and collectively, the “Registration Statements”).
The Registration Statements relate to the XRP ETF, -1x XRP ETF, and 2x XRP ETF (each, a “Fund” and collectively, the
“Funds”), each a series of the Registrant. Capitalized terms used herein, but not otherwise defined, have the meanings
ascribed to them in the Registration Statements. Copies of each Fund’s statutory prospectus reflecting the changes made in response
to your comments will be emailed to you under separate cover.

Comment 1

In
the fee table for the Funds, please change the date from which the fee waiver will at least run through, from March 7, 2026 to the date
that the Fund’s shares are publicly offered, i.e., May 22, 2026.

Response:
The Registrant has made the requested change.

Comment 2

With regard to the prospectus
for XRP ETF, on page 2, please define the term “Subsidiary” in a manner similar to the way that term is defined in the prospectus
for 2x XRP ETF.

Response: The Registrant
has made the requested change.

Comment 3

On page 12 of the marked version
of the prospectus for each Fund previously provided to us, please make the following change:

“Risks Related to
the Regulation of XRP – Any final determination by a court that XRP or any other digital asset may be offered and sold as a
“security” or investment contract may adversely affect the
value of XRP and the value of the Shares, and, if XRP is not, or cannot, be registered as a security, result in a potential termination
of the Fund.

Response: The Registrant
has made the requested change.

Comment 4

Please disclose the “tokenomics”
of the XRP blockchain, including how many tokens have been issued, whether there is a limit on how many may be issued and the burn schedule,
to the extent not already addressed.

Response: On pages 5-6
of the marked version of the Funds’ prospectuses previously sent to you, the following is already disclosed and appears to address
the comment:

“Unlike other digital assets such as bitcoin or ether,
XRP was not and is not mined gradually over time. Instead, all 100 billion XRP tokens were created at the time of the XRP Ledger’s
launch in 2012. This means that every XRP token that exists today was generated from the outset, without the need for a mining process.
Of the 100 billion XRP generated by the XRP Ledger’s code, the founders of Ripple Labs retained 20 billion XRP and the rest, nearly
80 billion XRP, was provided to Ripple Labs. In 2017, Ripple Labs introduced an escrow mechanism to control the release of its XRP holdings.
Under this mechanism, Ripple Labs placed 55 billion XRP (55% of the total supply) into a series of time-locked escrow accounts that release
1 billion XRP per month over 55 months.”

    -2-

Comment 5

In the “Principal Risks” section
of the Funds’ prospectuses, please make the change reflected below:

“If the Fund is unable to buy or sell XRP Futures Contracts
as a result of position limits being hit or price limits that result in a halted or closed market—or for other reasons including
limited liquidity in the XRP futures market, a disruption to the XRP futures market, or as a result of margin requirements, accountability
levels, or other limitations imposed by the Fund’s FCMs, the listing exchanges, or the CFTC—the Adviser would take such action
as it believes appropriate and in the best interest of the Fund in consideration of the facts and circumstances at such time, including:
(i) investing in XRP-Linked Instruments that are not XRP Futures Contracts; (ii) requiring that Authorized Participants purchase and redeem
creation units through an exchange for related position (EFRP) method rather than in cash; (iii) applying increased Authorized Participant
variable transaction fees for purchases or redemptions of Creation Units made in cash; or (iv) de-levering the Fund, relative to its investment
objective, by an amount reflecting prevailing price limits. In addition, the Fund generally may suspend the issuance of Creation Units
only for a limited time and only due to extraordinary circumstances, such as when the markets on which the ETF’s portfolio holdings
are traded are closed for a limited period of time; that is to say, when the Fund is unable to increase its exposure to underlying
assets.”

Response: The Registrant has made the requested change.

*  *  *  *  *  *  *

Please call me at (202) 478-6492
if you have any questions or issues you would like to discuss regarding these matters.

    Sincerely yours,

    By:
    /s/ Barry Pershkow

    Barry Pershkow

    -3-