SecProbe.io

CORRESP
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    Richard
    Coyle

    Partner
    Chapman
    and Cutler LLP

    320 South Canal Street,

    27th Floor Chicago,

    Illinois 60606

    T 312.845.3724

    rcoyle@chapman.com

June 26, 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:
    Bitwise Dogecoin ETF

    File No. 333-284553

Dear Ms. Tillan, Mr. Irving, Ms. Bednarowski and Mr. Lin:

This letter responds to your
comments regarding the registration statement filed on Form S-1 for the Bitwise Dogecoin ETF (the “Trust”) with
the Staff of the Securities and Exchange Commission (the “Staff”) on January 28, 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

Please provide the Staff a
copy of your fact sheet for the Staff’s review

Response to Comment 1

When available, a copy of
the fact sheet will be provided under separate cover.

Comment 2 – Prospectus
Summary – Overview of the Trust, page 1

Please revise to disclose
here that Shareholders have no voting rights under the Trust Agreement and that the Sponsor and Trustee may agree to amend the Trust Agreement
or Sponsor Agreement without Shareholder approval. Also disclose here that any such amendment may increase fees or charges, including
the Sponsor Fee, and disclose examples of why the Sponsor may make such changes. Disclose whether and how Shareholders will be notified
of material amendments to the Trust or Sponsor Agreements, including any increases or changes to the Sponsor Fee.

June 26, 2025

Page 2

Response to Comment 2

Pursuant to the Staff’s
comment, the following disclosure has been added to the referenced portion of the Prospectus Summary:

The Trust Agreement and the Sponsor Agreement
set forth the terms pursuant to which the Trust is operated, including the amount of the Sponsor Fee and any other fees and expenses charged
to the Trust. These agreements may be amended without Shareholder approval. Although not currently intended, such amendments could potentially
increase the amount of fees and expenses paid by the Trust. In the event of a material amendment to the Trust Agreement or Sponsor Agreement,
including an increase in the Sponsor Fee, Shareholders will be provided notice of such amendment on the Trust’s website, in a prospectus
supplement, through a current report on Form 8-K and/or in the Trust’s annual or quarterly reports.

Comment 3 – Prospectus
Summary – Dogecoin, the Dogecoin Blockchain and the Dogecoin Network, page 1

Please clarify your statement
on page 2 that Dogecoin is “one of the larger digital assets when measured by market capitalization” by disclosing the market
capitalization of Dogecoin and how it compares to those of other crypto assets. In addition, please provide quantitative disclosure here
and in the first complete risk factor on page 11 regarding the historic volatility of the price of Dogecoin. Further, please disclose
the transaction fees associated with transferring Dogecoin.

Response to Comment 3

Pursuant to the Staff’s
comment, the following disclosure has been added to the Prospectus Summary and the section of the Registration Statement entitled “Risk
Factors”:

As of April 24, 2025, Dogecoin was believed
to be the 8th largest digital asset by market capitalization of the more than approximately 17,000 digital assets tracked across the over
1,200 exchanges (source: CoinGecko.com). Additionally, Dogecoin has exhibited a historical annualized volatility of 167.71% and maximum
annual price decrease of 88.35%.

June 26, 2025

Page 3

Comment 4 – Prospectus
Summary – The Trust’s Investment Objective and Strategies, page 2

Please reconcile your disclosure
on page 3 and throughout that the Trust will conduct creations and redemptions of Shares in-cash with the following:

 1. Your statement at page 9 that “[d]isruptions at digital asset trading platforms could adversely
affect…the ability of Authorized Participants to purchase or sell Dogecoin and, therefore their ability to create and redeem shares”;

 2. Your statement at page 17 that “the transfer of Dogecoin to and from Authorized Participants is
directed by the Sponsor”; and

 3. Your disclosure on page 19 identifying the Authorized Participants or their agents/partners as a party
that the Sponsor and the Trust engage with for Dogecoin transactions.

Please revise or advise otherwise.

Response to Comment 4

Pursuant to the Staff’s
comment, the referenced disclosures have been deleted.

Comment 5 – Prospectus
Summary – Purchases and Sales of Dogecoin, page 3

The Staff notes your disclosure
on page 4 that purchases and sales of the Trust’s Dogecoin may be facilitated through the Prime Execution Agent, an affiliate of
the Dogecoin Custodian. Please revise in an appropriate section of the prospectus to describe the potential conflicts of interest associated
with such an arrangement and the impact it may have on price.

Response to Comment 5

The section of the Registration
Statement entitled “Material Contracts – Prime Execution Agreement” already contains such disclosure, reproduced below.

The Prime Execution Agreement provides
that the Prime Execution Agent is subject to certain conflicts of interest, including: (i) the Trust’s orders may be routed to the
Prime Execution Agent’s own execution venue where the Trust’s orders may be executed against other customers of the Prime
Execution Agent or with the Coinbase acting as principal, (ii) the beneficial identity of the counterparty purchaser or seller with respect
to the Trust’s orders may be unknown and therefore may inadvertently be another client of the Prime Execution Agent, (iii) the Prime
Execution Agent does not engage in front-running, but is aware of the Trust’s orders or imminent orders and may execute a trade
for its own inventory (or the account of an affiliate) while in possession of that knowledge and (iv) the Prime Execution Agent may act
in a principal capacity with respect to certain orders. As a result of these and other conflicts, when acting as principal, the Prime
Execution Agent may have an incentive to favor its own interests and the interests of its affiliates over the Trust’s interests.

June 26, 2025

Page 4

Comment
6 – Prospectus Summary – The Trust’s Fees and Expenses, page 6

The Staff notes your disclosure
on pages 6 and 72 that “[t]he Sponsor may determine in its sole discretion to assume legal fees and expenses of the Trust in excess
of $500,000 per annum.” Please disclose the criteria the Sponsor will consider or the reasons the Sponsor may choose to pay expenses
beyond the cap amount for legal fees and expenses, and, if so, whether and how Shareholders will be notified in this regard. In addition,
please revise to disclose whether there is a cap for the aggregate expenses that the Sponsor has agreed to assume.

Response to Comment 6

As plainly disclosed in the
referenced disclosure, the Sponsor will determine in its sole discretion whether to choose to assume legal fees and expenses of the Trust
in excess of $500,000 per annum. It has no pre-determined criteria for how it will decide whether to assume legal fees in excess of that
cap. It will make such determination based upon prevailing circumstances at the time. Accordingly, the referenced disclosure has been
revised as set forth below.

The Sponsor may determine in its sole
discretion based upon prevailing circumstances to assume legal fees and expenses of the Trust in excess of $500,000 per annum.

There is no cap on the aggregate
expenses that the Sponsor has agreed to assume and it is not currently intended that Shareholders would be notified in the event the Sponsor
has agreed to assume legal fees and expenses of the Trust in excess of $500,000 per annum.

Comment
7 – Prospectus Summary – The Trust’s Fees and Expenses, page 6

Please revise to clarify whether
the Sponsor will assume the fees of the Dogecoin Trading Counterparties in connection with the purchase and sale of Dogecoin under the
Trust-Directed Trade Model.

June 26, 2025

Page 5

Response to Comment 7

Pursuant to the Staff’s
comment, the following disclosure has been added to the Prospectus Summary:

The Sponsor will not assume the fees of
Aptos Trading Counterparties in connection with their purchase and sale of Aptos.

Comment
8 – Prospectus Summary – The Trust’s Fees and Expenses, page 6

The Staff notes your disclosure
on page 6 that:

 1. The Trust is not responsible for paying any fees or costs associated with the transfer of Dogecoin to
the Sponsor; and;

 2. “[t]he Trust may incur certain extraordinary, non-recurring expenses that are not assumed by the
Sponsor, including, but not limited to, . . . Dogecoin Blockchain Fees.”

Please revise to clarify when
the Trust is responsible for paying Dogecoin Blockchain fees.

Response to Comment 8

Pursuant to the Staff’s
comment, the following disclosure has been added to the section of the Registration Statement entitled “The Trust’s Fees and
Expenses” under the Prospectus Summary:

Transfers of Dogecoin to and from the
Trust Dogecoin Account to the Dogecoin Trading Counterparty are “on-chain” transactions represented on the blockchain. Transfer
fees with respect to this on-chain transfer of Dogecoin will be paid by the Dogecoin Custodian.

Comment 9
– Risk Factors – Risks Associated with Dogecoin and the Dogecoin Blockchain – In the event of a hard fork of the
Dogecoin Blockchain..., page 21

The Staff notes your disclosure
that in the event of a hard fork of the Dogecoin Blockchain, the Sponsor will, pursuant to the terms of the Trust Agreement, use its discretion
to determine which network should be considered the appropriate network for the Trust’s purposes. In an appropriate section of the
prospectus, please disclose the Sponsor’s policies and procedures for making this determination.

June 26, 2025

Page 6

Response to Comment 9

Pursuant to the Staff’s
comment, the following disclosure has been added to the section of the Registration Statement entitled “Additional Information About
the Trust”:

Forks

In the event of a hard fork in the Dogecoin
Blockchain, the Sponsor will, pursuant to the terms of the Trust Agreement, use its discretion to determine which blockchain should properly
be considered the Dogecoin Blockchain for the Trust’s purposes. The Sponsor will base its determination on a range of relevant factors
at the time, including, but not limited to, the Sponsor’s views regarding the expectations of Dogecoin core developers, users, service
providers, businesses, miners, and other stakeholders, as well as the actual ongoing acceptance of, mining support for, and community
engagement with the Dogecoin network. There is no assurance that the Sponsor will select the fork or version of Dogecoin that ultimately
proves to be the most valuable, and this decision could negatively impact the value of the Shares. Additionally, the Sponsor may have
a differing view from Shareholders, the Dogecoin Custodian, security vendors, or the Benchmark Provider as to what is generally accepted
as Dogecoin and should therefore be considered “Dogecoin” for the Trust’s purposes, which could also adversely affect
the value of the Shares.

Comment 10
– Risk Factors – Risks Associated with Dogecoin and the Dogecoin Blockchain – If a malicious actor obtains control
of more than 50%..., page 23

Please expand this risk factor
to provide examples of “51% attacks” that have occurred on crypto asset networks.

Response to Comment 10

Pursuant to the Staff’s
comment, the following disclosure has been added to the risk factor entitled “If a malicious actor obtains control of more than
50% of the validating nodes on the Dogecoin Blockchain, or otherwise obtains control over the Dogecoin Blockchain through its influence
over trusted validators or otherwise, such actor could manipulate the Dogecoin Blockchain, which could adversely affect the value of the
Shares or the ability of the Trust to operate.”:

For example, in August 2020, the Ethereum
Classic Network was the target of two double-spend attacks by an unknown actor or actors that gained more than 50% of the processing power
of the Ethereum Classic Network. The attack resulted in reorganizations of the Ethereum Classic Blockchain that allowed the attacker or
attackers to reverse previously recorded transactions in excess of $5.0 million and $1.0 million. In addition, in May 2019, the Bitcoin
Cash network experienced a 51% attack when two large mining pools reversed a series of transactions in order to stop an unknown miner
from taking advantage of a flaw in a recent Bitcoin Cash protocol upgrade. Although this particular attack was arguably benevolent, the
fact that such coordinated activity was able to occur may negatively impact perceptions of the Bitcoin Cash network.

June 26, 2025

Page 7

Comment 11
– Risk Factors – Risks Associated with Dogecoin and the Dogecoin Blockchain – Congestion or delay in the Dogecoin
Blockchain may delay..., page 29

Please expand this risk factor
to discuss the recent congestion on the Dogecoin Network, which has resulted in delays in recording transactions.

Response to Comment 11

Pursuant to the Staff’s
comment, the following disclosure has been added to the risk factor entitled “Congestion or delay in the Dogecoin Blockchain may
delay purchases or sales of Dogecoin by the Trust”:

In recent years, there have been brief
periods during which the Dogecoin Blockchain has suffered from congestion issues, with users reporting delays in recording transactions.
For example, in May 2021, users reported delays in transaction processing as a burst in network activity surrounding Elon Musk slowed
the network. In other instances, between 2021-2024, users reported periods of congestion and other issues related to software issues or
spikes in activity on the network related to inscriptions, which are images and text embedded into blockchain transactions. While the
Dogecoin network has taken steps to improve its throughput and stability, there is a risk the network will experience congestion or further
issues in the future, which could reduce trust in the network and negatively affect the value of the trust. In extreme circumstances,
network delays could lead to delays in the settlement of Dogecoin into the Trust.

Comment 12 – Risk
Factors – Regulatory Risk – Dogecoin’s status as a “security”..., page 41

The Staff notes your statement
that “[i]f Dogecoin is determined to be a ‘security’ under federal or state securities laws by the SEC or any other
agency....” Please revise this sentence to add after the phrase “determined to be” the phrase “offered and sold
as.” Also, please make corresponding revisions to the first sentence of the first paragraph on page 62.

Response to Comment 12

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

Comment
13 – Risk Factors – Regulatory Risk – Dogecoin’s status as a “security”..., page 41

Please revise to disclose
your internal policies and procedures for analyzing whether Dogecoin is offered and sold as a “security” within the meaning
of Section 2(a)(1) of the Securities Act and disclose the risks of such internal policies and procedures, including that such policies
and procedures are risk-based judgments made by the Sponsor and not a legal standard or determination binding on any regulatory body or
court.

Response to Comment 13

Pursuant to the Staff’s
comment, the disclosure set forth below has been added to the referenced risk in the setion entitled “Risk Factors”:

In determining whether Dogecoin is a security,
the Sponsor does not engage in legal analysis on Dogecoin nor perform any analysis based upon any legal standard. Instead, the Sponsor
reviews the following information to