SecProbe.io

CORRESP
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July 31, 2025

Via EDGAR Correspondence

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Crypto Assets

100 F Street, N.E.

Washington, D.C. 20549

  Re:
  Canary Marinade Solana ETF

  File No. 333-282903

	Dear Mr. Sundwall, Mr. Niethamer, Ms. Paik and Ms. Berkheimer:

This letter responds to your
comments regarding Amendment No. 2 to the registration statement filed on Form S-1 for Canary Marinade Solana ETF (the “Trust”)
with the Staff of the Securities and Exchange Commission (the “Staff”) on June 13, 2025 (the “Registration
Statement”). Capitalized terms used herein, but not otherwise defined, have the meanings ascribed to them in the Registration
Statement.

Comment 1 – General

To the extent that you intend
to use a fact sheet, please provide us with a copy for our review.

Response to Comment 1

The
Trust has no current intention to use a fact sheet. To the extent the Trust decides to use a fact sheet prior to the effectiveness of
the Registration Statement, a copy of the fact sheet will be provided to the Staff under separate cover.

Comment 2 – General

Please identify the exchange
on which the Shares will be listed and traded and tell us the status of the exchange’s plans to submit an application under Rule
19b-4, and revise your disclosure throughout the prospectus as appropriate. Please be advised that the Staff may have additional comments
once the Rule 19b-4 application is filed.

Response to Comment 2

The Trust confirms that the
Shares will be listed and traded on Cboe BZX Exchange, Inc. and has revised disclosure throughout the prospectus, as appropriate. The
Trust will also inform the Staff of the status of the exchange’s plan to submit an application under Rule 19b-4 when determined.

Comment 3 – General

Please direct us to any publicly
available information about the Pricing Benchmark or tell us why you are unable to do so.

Response to Comment 3

Information regarding the
Pricing Benchmark can be found in the publicly available CoinDesk Indices publications dated March 2025 entitled “TWAP
Settlement Rate Methodology” and dated June 2025 entitled “TWAP Settlement Rate Annexes.”

Comment 4 – Cover
Page

It appears you intend to allow
for creations and redemptions in-cash and in-kind. If true, please revise the third and fourth sentences in the second paragraph of the
prospectus cover page to make this clear. In addition, please make corresponding revisions to similar disclosure providing only descriptions
of cash creations and redemptions throughout the prospectus, including but not limited to your disclosure on pages 10, 70, and 73.

Response to Comment 4

Pursuant to the Staff’s
comment, the referenced disclosures, and the prospectus generally, have been revised accordingly.

Comment 5 – Cover
Page

The Staff notes your disclosure
here and throughout the prospectus that “[t]he portion to be staked will be fixed on or before the start date of the Trust.”
Please confirm that you will disclose the percentage to be staked in a pre-effective amendment.

Response to Comment 5

Pursuant to the Staff’s
comment, the referenced disclosures, and the prospectus generally, have been revised accordingly.

Comment 6 – Statement
Regarding Forward-Looking Statements, page ii

The Staff notes your disclosure
that “neither the Trust, the Sponsor, nor any other person assumes responsibility for the accuracy and completeness of any of these
forward-looking statements.” Please delete this statement as it is not appropriate to disclaim responsibility for disclosure in
your registration statement.

Response to Comment 6

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

Comment 7 – Prospectus
Summary – Overview of the Trust, page 1

Please disclose the “limited
circumstances” under which Shareholders have voting rights under the Trust Agreement.

Response to Comment 7

Pursuant to the Staff’s
comment, the referenced disclosure has been deleted in its entirety and replaced with the following:

The Shareholders of the Trust take no part in
the management or control, and have no voice in, the Trust’s operations or business. Shareholders have very limited voting rights
as set forth in the Trust Agreement. However, certain actions, such as amendments or modifications that appoint a new sponsor (upon the
withdrawal, removal or the adjudication or admission of bankruptcy or insolvency of the Sponsor) require the consent of Shareholders owning
a majority (over 50%) of the outstanding Shares of the Trust (not including Shares held by the Sponsor or its Affiliates).

Comment 8 – Prospectus
Summary – Overview of the Trust, page 1

The Staff notes your disclosure
that the Custodian carries insurance provided by private insurance carriers. Please disclose, if accurate, that the insurance maintained
by the Custodian is shared among all of such Custodian’s customers, is not specific to the Trust, and may not be available or sufficient
to protect the Trust from all possible losses or sources of losses.

Response to Comment 8

Pursuant to the Staff’s
comment, the referenced disclosure has been revised as follows:

The Custodian is not insured by the Federal
Deposit Insurance Corporation (the “FDIC”) but carries insurance provided by private insurance carriers, which is shared
among all of such Custodian’s customers, is not specific to the Trust, and may not be available or sufficient to protect the Trust
from all possible losses or sources of losses. (emphasis added)

Comment 9 – Prospectus
Summary – Overview of the Trust, page 1

The Staff notes your disclosure
that you intend to implement a staking program. Please revise to provide a materially complete description of your planned staking program,
policies and procedures.

Response to Comment 9

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

Comment 10 – Prospectus
Summary – The Trust’s Service Providers – The Staking Provider, page 7

Please revise to include the
material terms of any agreements with Staking Providers, identify the Staking Providers and summarize the responsibilities and duties
of the Staking Providers. In describing your staking program, please disclose how and when rewards from staking will be shared, distributed,
or added to the assets of the Trust and how this will work and clarify the risk management practices you refer to on page 36 that the
Sponsor will undertake to manage liquidity risk, and any other staking related risks. Please also quantify the portion of staking rewards
that all involved parties will receive. Please also refer to Item 601(b)(10) of Regulation S-K and file your material agreement(s) with
Staking Providers as an exhibit to your registration statement.

Response to Comment 10

Pursuant to the Staff’s
comment, the referenced disclosure has been deleted in its entirety and replaced with the following:

The Sponsor will stake, or cause to be staked,
a portion of the Trust’s SOL through one or more trusted staking providers (each, a “Staking Provider”). The initial
Staking Provider for the Trust’s SOL will be Sous Vide Ltd. (“Marinade Finance”). Marinade Finance is expected to be
the exclusive Staking Provider for the Trust for at least two (2) years from the date upon which the Trust first trades. The Staking Program
will be carried out by the Marinade Finance pursuant to an agreement between the Custodian and the Staking Provider. The Trust is not
a party to such agreement.

In consideration for any staking activity in
which the Trust may engage, the Trust will receive a portion of the staking rewards generated by a Staking Provider. The Trust will dedicate
substantially all of the Trust’s SOL to the Trust’s staking program (the “Staking Program”), which will be provided
by one or more Staking Providers through the Custodian. The portion of the Trust’s SOL will be fixed on or before the Trust’s
start date. Marinade Finance is responsible for providing the software protocol that allows the Trust to connect to a pool of verified
validator nodes on the Solana Network for automated SOL staking optimization.

Pursuant to the Staking Program, the Staking
Provider will distribute staking rewards to the Trust’s wallet or wallets at the Custodian [on a periodic basis]. Accrued staking
rewards will be included in the Trust’s daily NAV calculation.

The Staking Provider will carry out the Staking
Program in accordance with the Sponsor’s liquidity risk management policy (the “Liquidity Risk Management Policy”),
which assesses the characteristics of a protocol’s native unbonding period, the particular unbonding characteristics of the Staking
Program, sources of credit, sources of tokens, and other relevant liquidity considerations against the settlement period for any redemption
of the Trust’s shares. The Liquidity Risk Management Policy permits the Trust to maintain credit facilities to help meet redemption
requests. The Sponsor also maintains its own credit facilities to serve as a source of backup liquidity for the Trust.

The Staking Program offered by the Staking Provider
contains a so-called “instant unbond” feature which allows for the Staking Provider to readily access the Trust’s staked
SOL to meet redemption requests without waiting for the native Solana Network epoch to elapse.

Comment 11 – SOL,
SOL Markets, and Regulation of SOL, page 12

Where appropriate, please
expand your disclosure to also address any planned material updates to the Solana Network.

Response to Comment 11

The Registration Statement
has been updated in accordance with the Staff’s comment.

Comment 12 – SOL,
SOL Markets, and Regulation of SOL – Market Participants – Validators, page 14

Please revise to expand your
explanation of how the reward system for SOL validators works, including but not limited to:

 ● How the staking rewards are calculated;

 ● The historical range of rewards due to differing
levels of network congestion; and

 ● The reward frequencies.

Response to Comment 12

Pursuant to the Staff’s
comment, the following disclosure has been inserted in an appropriate location in the section entitled “SOL, SOL Markets and Regulation
of SOL–Market Participants–Validators”:

Staking rewards on the Solana network are determined
by the protocol and are distributed to validators and their associated stakers based on the proportion of stake they have delegated to
a validator relative to the total active stake in the network. The rewards are funded by inflationary issuance of new tokens and transaction
fees collected on the network. The specific amount each validator and staker receives depends on their share of the total stake, the validator’s
uptime and performance, and the overall network conditions.

The historical range of staking rewards on the
Solana network has varied due to differing levels of network congestion and protocol parameters. During periods of low congestion, rewards
have generally been higher, as validators are able to process more transactions efficiently and the network can distribute more rewards.
Conversely, during periods of high congestion, rewards may decrease due to reduced transaction throughput and increased competition among
validators. The actual annualized reward rate has fluctuated over time, reflecting changes in network activity, inflation rates, and protocol
adjustments.

Staking rewards on Solana are distributed at
regular intervals, typically once per epoch. An epoch on Solana lasts approximately two days, after which rewards are calculated and distributed
to validators and their stakers. This regular reward frequency ensures that participants receive their share of rewards in a timely manner,
reflecting their contribution to network security and transaction validation.

Comment 13 – SOL,
SOL Markets, and Regulation of SOL – Solana Protocol Development and Modifications – Forms of Attack Against the Solana Network,
page 15

The Staff notes your disclosure
that “the top three largest staking pools controlled approximately [93.5%] of the SOL staked on the Solana Network.” Please
identify the three largest staking pools and disclose the percentage of SOL each staking pool controls.

Response to Comment 13

Pursuant to the Staff’s
comment, the referenced disclosure has been deleted and replaced with the following:

As of July 2025, the three largest staking platforms,
Lido, Marinade Finance, and Jito, collectively controlled approximately 93.5% of the SOL staked on the Solana Network. These platforms
operate across multiple validator nodes and use delegation strategies that concentrate staking influence. Based on publicly available
data, Lido accounts for approximately 32.5%, Marinade Finance for approximately 31.4%, and Jito for approximately 29.6% of the total staked
SOL. The concentration of stake among these platforms may increase the risk of centralization and validator collusion, particularly if
governance over delegation strategies is limited or coordinated among a small number of decision-makers.

Comment 14 – SOL,
SOL Markets, and Regulation of SOL – SOL Market and SOL Exchanges, page 17

The Staff notes your disclosure
regarding the SOL spot markets. Please expand your disclosure to discuss the futures market for SOL.

Response to Comment 14

Pursuant to the Staff’s
comment, the following disclosure has been inserted in an appropriate location in the section entitled “SOL, SOL Markets and Regulation
of SOL – SOL Market and SOL”:

In addition to spot and OTC markets, SOL futures
contracts are offered by certain digital asset derivatives platforms, allowing investors to speculate on the future price of SOL or hedge
existing exposures. These contracts may be cash-settled or physically settled and are typically traded on regulated or registered trading
venues outside of the Solana Blockchain. SOL futures markets may influence spot market prices and contribute to overall price discovery,
though trading volumes and liquidity vary across platforms.

Comment 15 – Risk
Factors – Risks Associated with SOL and the Solana Network – The Trading Prices Of Many Digital Assets, page 21

Please discuss, if known,
the reasons for the periods of extreme volatility of SOL, and describe any unique features of SOL that may make it more susceptible to
extreme volatility or otherwise not correlate to trends in the broader crypto asset markets.

Response to Comment 15

Pursuant to the Staff’s
comment, the following disclosure has been inserted in an appropriate location in the section entitled “Risk Factors — Risks
Associated with SOL and the Solana Network — The Trading Prices of Many Digital Assets”:

Periods of volatility in SOL’s price have
been driven by a variety of factors, including changes in investor sentiment regarding the long-term viability of the Solana Network,
broader movements in the cryptocurrency markets, highly publicized validator outages and network disruptions, and the launch of competitive
Layer 1 protocols. Macroeconomic conditions, such as rising interest rates, inflation concerns, and tightening monetary policy, have also
contributed to fluctuations in the price of SOL and other digital assets. SOL may also be more susceptible to idiosyncratic volatility
due to its relatively high proportion of programmatic usage by automated trading protocols and its concentration of stake among a limited
number of liquid staking providers, which may amplify market reactions to technical or governance events. As a result, the price performance
of SOL may not always correlate with the broader digital asset market.

Comment 16 – Risk
Factors – Risks Associated with SOL and the Solana Network – In the Event Of a Hard Fork Of The Solana Network, page 29

The Staff notes your disclosure
that in the event of a hard fork of the Solana Network, the Sponsor will, if permitted by the terms of the Trust Agreement, use its discretion
to determine which network should be considered