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    Chapman
                           and Cutler LLP

320
South Canal Street, 27th Floor

Chicago,
Illinois 60606

T
312.845.3000

F
312.701.2361

March 1, 2023

VIA EDGAR CORRESPONDENCE

Ashley Vroman-Lee

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 Ms. Vroman-Lee:

This letter responds
to your comments, provided by telephone regarding the registration statements filed on Form N-1A for Volatility Shares Trust
(the “Trust”) with the Securities and Exchange Commission (the “Commission”) on December 13,
2022 (the “Registration Statements”). The Registration Statements relate to the 1x Long VIX Futures K-1 Free
ETF and -1x Short VIX Mid-Term Futures ETF (each, a “Fund” and collectively, the “Funds”),
each 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 – Cover Page

The staff of the Commission
(the “Staff”) asks the Funds to include cover page disclosure that covers applicable risks for investors.

Response to Comment 1

The cover page of the
prospectus for each of the Fund’s has been updated to include the risk disclosure suggested by the Staff, as applicable to
each Fund.

Comment 2 – VaR Analysis

The Staff requests
the Funds please advise and provide hypothetical value-at-risk (“VaR”) calculations demonstrating how each Fund
anticipates being able to achieve its objective, while remaining in compliance with the VaR test under Rule 18f-4 of the Investment
Company Act of 1940, as amended (the “1940 Act”). Please disclose to the Staff the designated reference portfolio
(the index that the fund plans to use) and please discuss how the index meets the definition of designated reference portfolio
and is in accordance with the requirements under Rule 18f-4.

Response to Comment 2

Each of the 1x Long
VIX Futures K-1 Free ETF and -1x Short VIX Mid-Term Futures ETF will, as described in their respective investment objective, seek
to track the performance of the Long VIX Futures Index and the S&P 500 VIX Mid Term Futures Inverse Daily Index,1
respectively (each a “Designated Index” and collectively, the “Designated Indices”).
Rule 18f-4(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). Each Fund seeks to track the performance of an unlevered index.2
Accordingly, the Funds are required by Rule 18f-4 to use their respective Designated Index as the designated reference
portfolio.

Each Fund will use
the Relative VaR test to test its compliance with Rule 18f-4. Because each Fund’s investment objective is to track the performance
of its Designated Index, it is expected that Relative VaR calculated in accordance with Rule 18f-4 would normally be approximately
100%, subject to de minimis deviations attributable to financing costs embedded in the Funds’ usage of derivatives
and any valuation differences between the Funds’ portfolios and the applicable Designated Indices.3
Except under extraordinary circumstances, the Relative VaR of each Fund would not approach the 200% limitation of Rule 18f-4. The
Relative VaR calculations for each of the Funds are being sent to the Staff under separate cover.

 1 The investment objective of the -1x Short VIX Mid-Term Futures ETF has been revised such that Fund
will now track the S&P 500 VIX Mid Term Futures Inverse Daily Index instead of the S&P 500 VIX Mid-Term Futures Index Excess
Return. Appropriate revisions have been made throughout the Fund’s prospectus and SAI.

 2 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 Indices do not seek a multiple
of the returns of the CBOE Volatility Index, the index constituents, or any other index.

 3 Pages 183-84 of the Rule 18f-4 adopting release acknowledges that such de minimis deviations
may occur and do not independently give rise to remediation requirements should they result in non-compliance with the VaR test.

    -2-

Comment 3 – Fund Name

Please include “daily”
in each Fund’s name. Additionally, the Staff believes the Funds should have an 80% policy such that each Fund maintains an
80% exposure to the term in its name.

Response to Comment 3

The Funds respectfully
decline to change each Fund’s name. Each Fund has clear and prominent disclosure in their respective prospectus
and SAI regarding their daily investment objective.

Comment 4 – Important Information About the
Fund

The Staff notes the
disclosure under the section “Important Information About the Fund” and requests the following disclosure be added
to this section:

“The Fund presents different risks
from other funds, may only be suitable for knowledgeable investors who understand how the Fund operates, the Fund is not intended
to be used by, and not appropriate for investors who do not intend to actively monitor and manage their portfolios, and an investor
in the Fund could potentially lose the full principal value of their investment within a single day.”

Response to Comment 4

The prospectus for
each Fund has been updated in accordance with the Staff’s comment.

Comment 5 – Investment Objective

The Staff notes that
the Fund is a 1x fund and does not believe there is a multiplier effect with 1x. If so, please include disclosure in the strategy
that there is no multiplier to avoid confusion.

Response to Comment 5

The prospectus for
each Fund has been updated in accordance with the Staff’s comment.

Comment 6 – Fee Table

Please include any
applicable acquired fund fees and expenses in the fee table, as each Fund invests in money market funds.

    -3-

Response to Comment 6

Pursuant to Instruction
3(f)(i), acquired fund fees and expenses will be included in “Other Expenses.”

Comment 7 – Fee Table

Please confirm that
“Other Expenses” is properly reflected as 0.00%.

Response to Comment 7

The Funds confirm the
Fee Table is correct.

Comment 8 – Portfolio Turnover

Do the Funds intend
to actively turnover its portfolio? If yes, please disclose.

Response to Comment 8

It is expected that
each Fund will actively turnover its portfolio in order to meet their daily investment objectives of tracking their respective
indexes. The prospectus for each Fund includes risk disclosure acknowledging the risks and expenses of frequent turnover of their
respective portfolios. We note per Instruction 4(c)(ii) to Item 13 of Form N-1A, the calculation of Portfolio Turnover Rate requires
the exclusion from the calculation amounts relating to all securities, including options, whose maturities or expiration dates
at the time of acquisition were one year or less, which would likely exclude all of the VIX futures contracts in which the Funds
will invest. Accordingly, while the Portfolio Turnover Rate calculated pursuant to Form N-1A is expected to be relatively low,
actual portfolio turnover is expected to be frequent. Therefore, the Funds respectfully decline to revise the disclosure in the
prospectuses in accordance with the Staff’s comment.

Comment 9 – Principal Investment Strategies

Please explain and
disclose how each Fund achieves the 1x (or -1x) return for a single day. The Staff does not believe it is clear from the disclosure
provided.

Response to Comment 9

The
Funds will seek to replicate their respective index or invest in other financial instruments that replicate the performance of
the respective index. Each Fund will rebalance its portfolio on each day such that the performance of each Fund will track the
performance of its respective index on such day. If, for any reason, a Fund is unable to perfectly track the performance of its
respective index on any given day, such over- or under-performance will not impact the way in which the Fund is managed on any
subsequent day (e.g., if a Fund underperforms its index on day 1, it will not seek to “make-up” for such underperformance
on day 2 or any subsequent day).

    -4-

Comment 10 – Principal Investment Strategies

The Staff asks the
1x Long VIX Futures K-1 Free ETF to briefly describe how its name relates to the strategy, especially with respect to the “K-1
Free” portion of the Fund’s name.

Response to Comment 10

The
prospectus for the 1x Long VIX Futures K-1 Free ETF has been updated with the following disclosure:

“The Fund is called “K-1 Free”
because it is designed to operate differently than commodity-based investments that distribute a “Schedule K-1” to
shareholders. Schedule K-1 is a tax form containing information regarding a fund’s income and expenses, which shareholders
may find complicates tax return preparation, thus requiring additional time, or the help of a professional tax adviser, at additional
cost. By comparison, the Fund is designed to be taxed like a conventional exchange traded fund and shareholders will instead receive
a Form 1099 from the broker-dealer or other financial intermediary through which they invest, from which income, gains, and losses
can be entered onto the shareholder’s tax return.”

Comment 11 – Principal Investment Strategies

The Staff notes the
following disclosure, and asks that the Funds disclose what the “similar instruments and transactions” are specifically,
or remove the extraneous reference.

“‘Financial Instruments’
are instruments whose value is derived from the value of an underlying asset, rate or benchmark and include futures contracts,
options transactions, swap agreements, forward contracts and similar instruments or transactions.”

Response to Comment 11

The reference to “similar
instruments or transactions” has been removed from the disclosure. The Funds confirm that use of the remaining disclosed
Financial Instruments is possible in certain circumstances.

    -5-

Comment 12 – Principal Investment Strategies

The Staff requests
the Funds disclose what is “a theoretical portfolio” in the following disclosure:

“The Long VIX Futures Index is
an excess return index designed to express the performance of a theoretical portfolio of long positions in first- and second-month
VIX Futures Contracts that are rolled daily.”

Response to Comment 12

The references in the
disclosure to a “theoretical” portfolio have been removed.

Comment 13 – Principal Investment Strategies

In the referenced disclosure
in Comment 12, please also clarify what “express the performance” means or revise the disclosure to be more specific.
For example, does it mean to replicate or track?

Response to Comment 13

The prospectus has
been updated to replace “express” with “track” in accordance with the Staff’s comment.

Comment 14 – Principal Investment Strategies

The Staff finds the
second paragraph in the Principal Investment Strategies to be confusing. Please further explain the benefits of the strategy when
rolling daily first- and second-month VIX futures contracts, or how maintaining a constant weighted average time to maturity of
one-month benefits investors. Ultimately, the disclosure about the index is unclear, or potentially unclear in the Staff’s
view. Please revise and consider including a plain English definition or an example.

Response to Comment 14

The prospectus for
each Fund has been updated in accordance with the Staff’s comment.

Comment 15 – Principal Investment Strategies

The Staff believes
it would be helpful to include an example of how the Funds will use or track VIX implied volatility measurement versus the actual
index.

    -6-

Response to Comment 15

The Fund's respectfully
decline to make the change. The Funds believe the existing disclosure regarding VIX and Index volatility adequately expresses how
implied volatility may be different between the measures.

Comment 16 – Principal Investment Strategies

The Staff notes the
following disclosure:

“Collateral Investments may also
be invested in as Secondary Investments, as described below.”

Does this disclosure
mean that the Collateral Investments are secondary investments, or may also be invested in secondary investments? Please revise.

Response to Comment 16

Collateral Investments
are the category of cash and cash equivalents the Funds will invest to the extent their assets not invested in VIX Futures Contracts.
In addition, should applicable limitations restrict either Fund’s ability to purchase additional VIX Futures Contracts when
the applicable investment strategy would otherwise call for it, such Fund will invest in additional Collateral Investments, which
we refer to as “Secondary Investments” in the Funds’ prospectuses. The disclosure in the prospectuses has been
revised to clarify this distinction.

Comment 17 – Subsidiary

Please include disclosure
regarding the following with respect to the Subsidiary:

 (a) Each Fund complies with the provisions of the 1940 Act governing investment policies (Section 8)
and capital structure and leverage (Section 18) on an aggregate basis with the Subsidiary.

 (b) That any investment adviser to the Subsidiary complies with provisions of the 1940 Act relating
to investment advisory contracts (Section 15) as if it were an investment adviser to each Fund under Section 2(a)(20)
of the 1940 Act. Any investment advisory agreement between the Subsidiary and its investment adviser is a material contract that
should be included as an exhibit to the registration statement.

 (c) That the Subsidiary complies with provisions relating to affiliated transactions and custody (Section 17).
Identify the custodian of the Subsidiary, if any, as it is currently in brackets.

    -7-

Response to Comment 17

The prospectus for
each Fund has been updated in accordance with the Staff’s comment.

Comment 18 – Subsidiary

Please confirm supplementally
to the Staff, whether:

 (a) the financial statements of the Subsidiary will be consolidated with those of each Fund and, if
not, why not;

 (b) the Subsidiary’s management fee (including any performance fee), if any, will be included
in “Management Fees” and the Subsidiary’s expenses will be included in “Other Expenses” in each Fund’s
prospectus fee table;

 (c) the Subsidiary and its board of directors will agree to inspection by the staff of the Subsidiary’s
books and records, which will be maintained in accordance with Section 31 of the 1940 Act and the rules thereunder;

 (d) the Subsidiary and its board of directors will agree to designate an agent for service of process
in the United States; and

 (e) that the Funds do not currently intend to create or acquire primary control of any entity which
engages in investment activities in securities or other assets, other than entities wholly-owned by such Fund.

Response to Comment 18

In accordance with
the Staff’s comment, please see the Funds responses below:

 (a) The Funds confirms that financial statements of their respective Subsidiary will be consolidated
with those of the applicable Fund.

 (b) The Funds confirm that the respective Subsidiary’s management fee (including any performance
fee), if any, will be included in “Management Fees” and the respective Subsidiary’s expenses will be included
in “Other Expenses” in the applicable Fund’s prospectus fee table.

 (c) The Funds confirm that each Sub