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CORRESP
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    Richard J. Coyle

320 South Canal Street

Chicago, Illinois 60606

T 312.845.3724

rcoyle@chapman.com

January 31, 2023

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 made telephonically regarding the registration statement filed on Form N-1A for Bitwise Funds Trust (the “Registrant”)
with the staff of the Securities and Exchange Commission (the “Staff”) on November 23, 2022 (the “Registration
Statement”). The Registration Statement relates to the Bitwise Bitcoin Strategy Optimum Roll ETF (previously Bitwise Bitcoin
Strategy Optimum Yield 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 – General

Please supplementally disclose
the Fund’s intended launch date.

Response to Comment 1

The Registrant currently
intends to launch the Fund on or about March 1, 2023.

Comment 2 – General

Please supplementally discuss
how the Fund would value its bitcoin futures positions if the Chicago Mercantile Exchange (the “CME”) halted the trading
of bitcoin futures due to price limits or otherwise.

Response to Comment 2

If the CME bitcoin futures
contracts held by the Fund were still subject to a trading halt at the close of the trading day when the Fund determined its net asset
value, then such assets would be fair valued pursuant to the Trust’s valuation procedures that have been developed in accordance
with Rule 2a-5 of the 1940 Act. As set forth in those procedures, such fair valuation would be done by the Adviser. In conducting that
fair valuation, the Adviser would rely on a number of relevant factors, including but not limited to, pricing history, current market
level, supply and demand of the asset, comparison to the values and current pricing of assets that have comparable characters (which
in this instance would likely be bitcoin itself, as it trades continuously and is not subject to trading halts), knowledge of historical
market information and any other factors deemed relevant by the Adviser.

Comment 3 – General

Please supplementally confirm
with the Staff that the Trust’s code of ethics applies to transactions in bitcoin and bitcoin futures and whether employees are
required to pre-clear such transactions.

Response to Comment 3

The Registrant represents
that it will amend its code of ethics as soon as is practicable to include pre-clearance procedures for bitcoin and bitcoin futures transactions.

Comment 4 – General

Please supplementally provide
a completed fee table.

Response to Comment 4

A completed fee table has
been attached hereto as Exhibit A.

Comment 5 – General

The Staff notes that the
Fund has a subsidiary. Please confirm whether the Fund will include any subsidiary-related expenses in the fee table.

Response to Comment 5

The Registrant confirms
that subsidiary-related expenses will be included in the fee table.

Comment 6 – Principal Investment Strategies

The Staff notes the phrase
“highest implied roll yield” is used in the section entitled “Principal Investment Strategies.” Please explain
what this phrase means in plain English.

Response to Comment 6

Pursuant to the Staff’s
comment, the section entitled “Principal Investment Strategies” has been revised to include the following disclosure:

The expected change between the price at
which a Bitcoin Futures Contract trades and the current spot price — expressed on an annualized basis — is considered the
“implied roll yield.” The Fund, in seeking the “highest implied roll yield,” will choose the contract out of all
available contracts that offers the largest positive or smallest negative implied roll yield on an annualized basis if held to expiration.

Comment 7 – Principal Investment Strategies

Please confirm that, other
than exchange-traded futures contracts, the Fund will not obtain bitcoin exposure in other investments (e.g., Canadian bitcoin
ETFs or bitcoin trusts).

Response to Comment 7

The Registrant confirms
that the Fund currently intends to only obtain bitcoin exposure through exchange-traded futures contracts and not through investments
in Canadian bitcoin ETFs or bitcoin trusts.

Comment 8 – Principal Investment Strategies

Please supplementally discuss
the Fund’s investment strategy if CME position limits are triggered with respect to the Fund’s bitcoin futures investments.

Response to Comment 8

If the Fund reaches a position
limit on one of the available bitcoin futures contracts, the Adviser will select a different futures contract or contracts in which to
invest based on the next highest implied roll return.

Comment 9 – Principal Investment Strategies

Please supplementally
confirm to the Staff whether:

 (a) the financial statements of the Subsidiary will
be consolidated with those of the 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 whether the Subsidiary’s expenses will be included
in “Other Expenses” set forth in the table entitled “Fees and Expenses of the Fund”;

 (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 Investment Company Act of 1940, as amended (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) the Fund does 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 the Fund.

Response to Comment 9

Pursuant to the Staff’s
comment, the Registrant confirms the following:

 (a) the financial statements of the Subsidiary will
be consolidated with those of the Fund;

 (b) the Subsidiary’s management fee (of which
there is none) will be included in “Management Fees,” and the Subsidiary’s expenses will be included in “Other
Expenses” set forth in the table entitled “Fees and Expenses of the Fund”;

 (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;

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

 (e) the Fund does 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 the Fund.

Comment 10 – Principal Investment Strategies

 (a) Please include disclosure regarding the Fund’s compliance 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) Please also include disclosure regarding how 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 the Fund under Section 2(a)(20)
of the 1940 Act.

 (c) Please also include as an exhibit to the Registration Statement any investment advisory agreement between
the Subsidiary and its investment adviser, as such is a material contract.

Response to Comment 10

Pursuant to the Staff’s
comment, the Registrant’s corresponding responses are set forth below:

 (a) The requested disclosure is set forth in the section entitled “Management of the Subsidiary.”

 (b) The requested disclosure is set forth in the section entitled “Management of the Subsidiary.”

 (c) The Registrant will include as an exhibit to the Registration Statement any investment advisory agreement
between the Subsidiary and its investment adviser, as such is a material contract.

Comment 11 – Principal Investment Strategies

The Staff notes the sixth
paragraph set forth in the section entitled “Principal Investment Strategies.” Please add disclosure specifying a range or
upper limit of the Fund’s assets that will be invested given that these investments are listed as a principal investment strategy
and are not temporary defensive measures.

Please also disclose the
percentage of the Fund’s exposure that will be in bitcoin futures.

Response to Comment 11

Pursuant to the Staff’s
comment, the first sentence of the sixth paragraph of the section entitled “Principal Investment Strategies” has been revised
as set forth below:

While the Fund intends to achieve its investment
objective primarily through its investment in Bitcoin Futures Contracts, the Fund expects
to invest its remaining assets (up to 75%) in any one or more of the following …

The Registrant also believes
that the following disclosure set forth in the section entitled “Principal Investment Strategies” is responsive to the Staff’s
request to include disclosure regarding what percentage of the Fund’s assets will be invested in the Bitcoin Futures Contracts/the
Subsidiary:

…[t]he size of the Fund’s investment
in the Subsidiary will not exceed 25% of the Fund’s total assets at each quarter end of the Fund’s fiscal year.

Comment 12 – Principal Investment Strategies

The Staff notes “Frequent
Trading Risk” set forth in the section entitled “Principal Risks.” Please include an applicable strategy discussion
in the section entitled “Principal Investment Strategies.”

Response to Comment 12

Pursuant to the Staff’s
comment, the following disclosure has been added to the second paragraph of the section entitled “Principal Investment Strategies”:

The Fund’s regular purchases and sales
of individual Bitcoin Futures Contracts throughout the year may cause the Fund to experience higher than normal portfolio turnover.

Comment 13 – Principal Investment Strategies

The Staff notes “Additional
Information About Bitcoin” set forth in the section entitled “Principal Investment Strategies.” Please tailor this discussion
of bitcoin to be specific to the Fund and bitcoin futures and move any remaining disclosure to the section entitled “Additional
Information About the Fund’s Principal Investment Strategies.”

Response to Comment 13

The referenced disclosure
has been removed from the section entitled “Principal Investment Strategies” and relocated to the section entitled “Additional
Information About the Fund’s Principal Investment Strategies.”

Comment 14 – Principal Risks

The Staff notes “Borrowing
Risk” set forth in the section entitled “Principal Risks.” Please explain how the Fund is using reverse repurchase agreements.

Additionally, please confirm
that the Fund is not intending to use such instruments in seeking to provide a multiple of a return on the reference asset.

Lastly, please discuss
reverse repurchase agreements in the section entitled “Principal Investment Strategies.”

Response to Comment 14

Pursuant to the Staff’s
comment, the Fund has added the following as the final sentence of the final paragraph of the section entitled “Principal Investment
Strategies”:

Due to the high margin requirements that
are unique to Bitcoin Futures Contracts, the Fund may also utilize reverse repurchase agreements during certain times of the year to help
maintain the desired level of exposure to Bitcoin Futures Contracts.

Additionally, the Registrant
confirms that it does not intend to use reverse repurchase agreements to provide returns that are either inverse or the multiple of the
underlying reference asset.

Comment 15 – Principal Risks

The Staff notes “Futures
Contracts Risk” set forth in the section entitled “Principal Risks,” specifically the reference to margin at the end
of the paragraph. Please discuss the impact and risk of particularly high margin requirements of Bitcoin Futures Contracts.

Response to Comment 15

Pursuant to the Staff’s
comment, the following disclosure has been added to “Principal Risks – Bitcoin Futures Risk”:

Additionally, due to the high margin requirements
that are unique to Bitcoin Futures Contracts, the Fund may experience difficulty maintaining the desired level of exposure to Bitcoin
Futures Contracts.

Comment 16 – Principal Risks

The Staff notes “Money
Market Instruments Risk” set forth in the section entitled “Principal Risks.” Please confirm supplementally that any
“acquired fund fees and expenses” will be included as a separate line item in the table entitled “Fees and Expenses
of the Fund,” if applicable.

Response to Comment 16

The Registrant confirms
that any “acquired fund fees and expenses” will be included as a separate line item in the table entitled “Fees and
Expenses of the Fund,” if applicable.

Comment 17 – Principal Risks

The Staff notes “Leverage
Risk” set forth in the section entitled “Principal Risks.” Please confirm whether the Fund intends to take on leverage
through futures investing or otherwise (e.g., reverse repurchase agreements).

Response to Comment 17

The usage of derivatives
contracts (such as Bitcoin Futures Contracts), by their nature, inherently utilize leverage as a smaller amount of money (the margin requirement)
may be used to achieve a larger economic effect. Beyond the use of Bitcoin Futures Contracts and the occasional use of reverse repurchase
agreements, the Fund confirms that it does not currently intend to utilize other forms of leverage.

Comment 18 – Principal Risks

Please make “Bitcoin
Futures Contracts Risk” the first risk in the section entitled “Principal Risks.”

Response to Comment 18

Pursuant to the Staff’s
comment, the prospectus has been revised accordingly.

Comment 19 – Additional Risks of Investing in the
fund

The Staff notes the following
statement from “Credit Risk” set forth in the section entitled “Principal Risks”:

High yield and comparable unrated debt securities,
while generally offering higher yields than investment grade debt with similar maturities, involve greater risks, including the possibility
of dividend or interest deferral, default or bankruptcy, and are regarded as predominantly speculative with respect to the issuer’s
capacity to pay dividends or interest and repay principal.

Please remove this sentence
or explain its relevance given that the Fund only invests in investment grade securities.

Response to Comment 19

Pursuant to the Staff’s
comment, the referenced disclosure has been deleted.

Comment 20 – Additional Risks of Investing in the
fund

The Staff notes “Frequent
Trading Risk” set forth in the sections entitled “Principal Risks” in the summary prospectus and the statutory prospectus.
Please make reference to the fact that the Fund will engage in frequent trading in the section entitled “Principal Investment Strategies.”

Response to Comment 20

The prospectus has been
revised in accordance with this comment.

Comment 21 – Additional Risks of Investing in the
fund

The Staff notes the following
statement from “Cash Transactions Risk” in “Structural ETF Risks” set forth in the section entitled “Principal
Risks”:

Cash purchases and redemptions may increase
transaction costs.

Please disclose that these
costs could be imposed on the Fund and thus decrease the Fund’s net asset value to the extent the costs are not offset by a transaction
fee payable by an authorized participant.

Please also consider revising
the last sentence of “Cash Transactions Risk” to the following:

Additionally, cash purchases and redemptions
may cause the Fund to recognize a taxable gain or loss.

Response to Comment 21

Pursuant to the Staff’s
comment, “Cash Transactions Risk” has been revised as set forth below:

Cash purchases and redemptions may increase
transaction costs which