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CORRESP
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  Richard J. Coyle

Partner

  320 South Canal Street

Chicago, Illinois 60606

T 312.845.3724

rcoyle@chapman.com

March 4, 2025

VIA EDGAR CORRESPONDENCE

Ashley Vroman-Lee

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Re: Bitwise Funds Trust

  File Nos. 333-264900; 811-23801

Dear Ms. Vroman-Lee:

This letter responds to your
comments delivered telephonically regarding the registration statements filed on Form N-1A for Bitwise Funds Trust (the “Registrant”)
with the staff of the Securities and Exchange Commission (the “Staff”) on December 26, 2024 (the “Registration
Statements”). The Registration Statements relate to the Bitwise COIN Option Income Strategy ETF, Bitwise MARA Option Income
Strategy ETF, Bitwise MSTR Option Income Strategy ETF and Bitwise Bitcoin Standard Corporations ETF (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
Statement.

Comment
1 – General

The Staff reminds the Registrant
and its management that they are responsible for the accuracy and adequacy of the disclosures, notwithstanding any review, comments, action
or absence of action by the Staff. Where a comment is made in one location, it is applicable to all similar disclosures appearing elsewhere
in the Registration Statements. Please ensure that corresponding changes are made to any similar disclosure.

Response
to Comment 1

The Registrant confirms that
corresponding changes made in response to the Staff’s comments have been made to any similar disclosure throughout the Registration
Statements and that it will provide the Staff with a response letter in the form of correspondence at least five business days before
effectiveness. The Registrant will indicate in its responses if the revisions only apply to certain of the Funds.

Comment 2 – Principal Investment Strategies

Please supplementally explain
to the Staff the following:

(a) Whether sold call options
will be covered with purchased call options;

(b) Whether notional principal
of the purchased call options will always be equal or larger than the sold call options the Fund is covering;

(c) Whether the purchased
call options will always be equal to or longer than the sold call options the Fund is covering; and

(d) Whether the strike of
the purchased call options would ever be higher than that of the sold call options the Fund covers and, if so, what would the maximum
difference in strikes be.

Response to Comment 2

Please refer to the
Registrant’s responses below:

(a) Yes, sold call options
will be covered with purchased call options.

(b) Yes, the notional principal
of the purchased call options will always be equal or larger than the sold call options the Fund is covering.

(c) Yes, the purchased call
options will always be equal to or longer than the sold call options the Fund is covering.

(d) Additional call options
can be purchased at higher strike prices than the strike prices of the sold call options but not to replace the existing call options
at the lower strike price.

Comment 3 – Principal Investment Strategies

The Staff notes that the disclosure
in the Bitwise COIN Option Income Strategy ETF states, “This strategy effectively converts a portion of the potential upside price
return growth of COIN into current income. It is expected that the call options the Fund will sell to generate options premiums will generally
have expirations of approximately one year or less and will be held to or close to expiration.” If accurate, please revise the above
referenced disclosure to state that the strategy seeks to offset a portion of the potential upside in return for income that may be less
than the upside return on the underlying asset.

Response to Comment 3

Pursuant to the Staff’s
comment, the referenced disclosure has been revised as set forth below.

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This strategy effectively converts a portion
of the potential upside price return growth of COIN into current income. Such income may be less than the upside return of COIN.

Comment 4 – Principal Investment Strategies

In the prospectus for the
Bitwise COIN Option Income Strategy ETF, please disclose that the Fund intends to continuously maintain indirect exposure to COIN through
the use of options contracts. If the option contracts the Fund holds are exercised or expire, it may enter into new options contracts.
A practice referred to as “rolling.” The Fund’s practice of rolling options may result in high portfolio turnover.

Response to Comment 4

Pursuant to the Staff’s
comment, the referenced disclosure has been revised as set forth below.

The Fund intends to continuously maintain exposure
to COIN through the use of options. When such options expire or are exercised, the Fund will enter into new options. This is a practice
referred to as “rolling.” The Fund’s practice of rolling options may result in higher levels of portfolio turnover.

Comment 5 – Principal Investment Strategies

Please briefly describe the
term “crypto asset” including how they are issued and transferred through public permissionless blockchain technology and
related technologies (e.g., so-called smart contracts) as well as their intended use cases and applications.

Response to Comment 5

Pursuant to the Staff’s
comment, the section entitled “Principal Investment Strategies” has been revised to include the disclosure set forth below.
Please note that the “crypto asset” has been replaced with “digital asset.”

A digital asset is a digital representation
of value or rights that utilizes cryptographic technology and is typically issued and transferred via a public, permissionless blockchain,
ensuring decentralized and transparent transactions without the need for intermediaries. These assets can be created through various mechanisms,
including mining, staking, or smart contracts, which automate and enforce agreements on the blockchain. Digital assets serve multiple
use cases, such as digital currencies (e.g., bitcoin), decentralized finance (DeFi), non-fungible tokens (NFTs), and enterprise applications,
enabling secure and efficient peer-to-peer transactions, programmable financial services, and digital ownership verification.

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Comment 6 – Principal Investment Strategies

Please disclose that the Bitwise
COIN Option Income Strategy ETF may hold substantial amounts of bitcoin and the risks associated therewith. As part of this discussion,
please state, if applicable, that these holdings are significant. In an appropriate location in the prospectus, briefly discuss the bitcoin
blockchain and its proof-of-work consensus mechanism, including mining and the block rewards and transaction fees earned through mining,
the relationship of bitcoin to the bitcoin blockchain and the application that the bitcoin blockchain and bitcoin have been specifically
designed to support, including the fact that bitcoin is not presently widely accepted as a means of payment.

Response to Comment 6

The Registrant respectfully
directs the Staff’s attention to the introduction to “Digital Assets Risk” in the section entitled “Principal
Risks” which states: “COIN may have substantial holdings of bitcoin and other digital assets.” In addition, “Digital
Assets Risk – Bitcoin Risk” contains the other disclosure requested by the Staff.

Comment 7 – Principal Investment Strategies

In addition to stating that
COIN, MARA and MSTR are registered under the Securities Exchange Act of 1934, please include a statement that the underlying issuer is
subject to the informational requirements of the Securities Exchange Act of 1934 and in accordance therewith, files reports and other
information with the SEC. Include a statement that the information filed with the SEC and available at the website includes reports, proxy
and information statements and other information regarding the underlying issuer. Please also disclose where investors can locate information
provided to, or filed with, the commission by the underlying issuer regarding financial statements.

Response to Comment 7

Pursuant to the Staff’s
comment, the referenced portion of the disclosure has been revised as set forth below.

Information provided to or filed with the Securities
and Exchange Commission by Coinbase Global, Inc. pursuant to the Exchange Act, including financial reports, proxy and information statements,
and other information regarding Coinbase Global, Inc. can be located by reference to the Securities and Exchange Commission file number
001-40289 through the Securities and Exchange Commission’s website at www.sec.gov.

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Comment 8 – Principal Risks

The Staff notes the inclusion
of “Financial Companies Risk” in the section of the Bitwise COIN Option Income Strategy ETF prospectus entitled “Principal
Risks – COIN Investing Risk.” Please include a risk for the Diversified Financial Industry, an industry comprising the financial
sector.

Response to Comment 8

The Registrant has thoughtfully
considered the Staff’s comment but believes that the highly robust disclosure already set forth in “Financial Companies Risk,”
set forth below, addresses the risks associated with “diversified financial companies.” The diversified financials industry
is an industry comprising the financial sector. Accordingly, “Financial Companies Risk” has been drafted to cover risks pertaining
to the diversified financial industry.

Financial Companies
Risk. Companies in the financials sector are subject to extensive governmental regulation and intervention, which may adversely
affect the scope of their activities, the prices they can charge, the amount of capital and liquid assets they must maintain and, potentially,
their size. Governmental regulation may change frequently and may have significant adverse consequences for companies in the financials
sector, including effects not intended by such regulation. Increased risk taking by financial companies may also result in greater overall
risk in the U.S. and global financials sector. The impact of changes in capital requirements, or recent or future regulation in various
countries, on any individual financial company or on the financials sector as a whole cannot be predicted.

Certain risks may
impact the value of investments in the financials sector more severely than those of investments outside this sector, including the risks
associated with companies that operate with substantial financial leverage. Companies in the financials sector are exposed directly to
the credit risk of their borrowers and counterparties, who may be leveraged to an unknown degree, including through swaps and other derivatives
products. Financial services companies may have significant exposure to the same borrowers and counterparties, with the result that a
borrower’s or counterparty’s inability to meet its obligations to one company may affect other companies with exposure to
the same borrower or counterparty. This interconnectedness of risk may result in significant negative impacts to companies with direct
exposure to the defaulting counterparty as well as adverse cascading effects in the markets and the financials sector generally. Companies
in the financials sector may also be adversely affected by increases in interest rates and loan losses, decreases in the availability
of money or asset valuations, credit rating downgrades, adverse public perception and adverse conditions in other related markets. Insurance
companies, in particular, may be subject to severe price competition and/or rate regulation, which may have an adverse impact on their
profitability. The financials sector is particularly sensitive to fluctuations in interest rates. The financials sector is also a target
for cyberattacks. Cybersecurity incidents and technology malfunctions and failures have become increasingly frequent and have caused significant
losses to companies in this sector, which may negatively impact the Fund. The extent to which the Fund may invest in a company that engages
in securities-related activities or banking is limited by applicable law.

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Comment 9 – Principal Risks

The Staff notes the inclusion
of “Concentration Risk” in the section entitled “Principal Risks.” Please disclose the industry and applicable
risks.

Response to Comment 9

Pursuant to the Staff’s
comment, “Concentration Risk” has been revised as set forth below.

As of December 1, 2024, COIN is assigned to
the “diversified financials” industry group of the financial sector. Please see “Financial Companies Risk” for
a discussion regarding the risks of an investment in such companies.

Comment 10 – General

In supplemental correspondence,
please advise the Staff which broad-based market index the Bitwise COIN Option Income Strategy ETF, Bitwise MARA Option Income Strategy
ETF and Bitwise MSTR Option Income Strategy ETF propose to use for the purpose of performance.

Response to Comment 10

The Registrant expects the
broad-based index for the Funds to be the S&P 500 Index.

Comment 11 – Principal Risks

Please include “Special
Tax Risk” in the Registration Statements.

Response to Comment 11

Pursuant to the Staff’s
comment, the following risk disclosure has been added to the section entitled “Principal Risks.”

Special Tax Risk. The Fund intends
to qualify as a “regulated investment company” or “RIC.” If, in any year, the Fund fails to qualify as a regulated
investment company under the applicable tax laws, the Fund would be taxed as an ordinary corporation. The Fund intends to treat any income
it may derive from the FLEX Options as “qualifying income” under the provisions of the Code applicable to RICs. In addition,
based upon language in the legislative history, the Fund intends to treat the issuer of the FLEX Options as the referenced asset, which
may allow the Fund to qualify for special rules in the RIC diversification requirements. If the income is not qualifying income or the
issuer of the FLEX Options is not appropriately the referenced asset, the Fund may lose its own status as a RIC if tax positions reflected
by such options are large enough.

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Comment 12 – Principal Investment Strategies

With respect to the MSTR FLexible
EXchange options (“FLEX Options”) referenced in the Bitwise MSTR Option Income Strategy ETF:

(a) Please supplementally
discuss whether the Fund anticipates any capacity constraints in the MSTR options market that would limit the size of the Fund’s
exposure to MSTR and explain how the Fund will monitor market capacity as new participants enter the market;

(b) Please supplementally
discuss the Fund’s plans for liquidity management including during both normal and reasonably foreseeable stressed conditions; and

(c) Please disclose the impact
of exceeding certain thresholds, such as options exchange position limits for a given contract, and whether these circumstances or others
may cause the Fund to reduce its exposure to MSTR.

Response to Comment 12

Please refer to the
Registrant’s responses below:

(a) Given the capability to
create a custom FLEX Option contract for any strike and any expiration, the Adviser believes there is a very low likelihood that the MSTR
options market would limit the size of the Fund’s exposure. The Adviser will seek to monitor existing FLEX Option positions such
as to ensure diversification of liquidity wherever possible in the interest of the Fund investors.

(b) The Adviser will look
to monitor existing FLEX Options to ensure diversification of strikes and expirations where possible in the interest of the Fund investors
to avoid liquidity issues. The Adviser does not expect that the Fund would be adversely affected due to liquidity related issues that
require forced selling/buying given that the Fund is fully collateralized.

(c) Given that the Fund’s
strategy is fully collateralized at all times, the Adviser does not believe