SEC Comment Letter 0000000000-24-002582 to Hashdex Commodities Trust (DEFI)
Hashdex Commodities Trust
Date: March 8, 2024 · CIK: 0001985840 · Accession: 0000000000-24-002582
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File numbers found in text: 333-276254
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United States securities and exchange commission logo
March 8, 2024
Guillermo Trias
Chief Executive Officer/President of the Sponsor
Tidal Commodities Trust I
c/o Toroso Investments, LLC
234 West Florida Street, Suite 203
Milwaukee, WI 53204
Re:Tidal Commodities Trust I
Amendment No. 5 to Registration Statement of Form S-1
Filed March 5, 2024
File No. 333-276254
Dear Guillermo Trias:
We have reviewed your amended registration statement and have the following
comments.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our February 27, 2024 letter.
Amendment No. 5 to Registration Statement on Form S-1
General
1.Refer to your response to comment 1 in our January 17, 2024 comment letter. While we
do not have any further comments at this time regarding your response, please confirm
your understanding that our decision not to issue additional comments should not be
interpreted to mean that we either agree or disagree with your response, including any
conclusions you have made, positions you have taken and practices you have engaged in
or may engage in with respect to this matter.
FirstName LastNameGuillermo Trias
Comapany NameTidal Commodities Trust I
March 8, 2024 Page 2
FirstName LastName
Guillermo Trias
Tidal Commodities Trust I
March 8, 2024
Page 2
Please contact Kate Tillan at 202-551-3604 or Michelle Miller at 202-551-3368 if you
have questions regarding comments on the financial statements and related matters. Please
contact Sonia Bednarowski at 202-551-3666 or Justin Dobbie at 202-551-3469 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets