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

August 15, 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 amendment no. 1 to 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 June 26, 2025 (the “Registration
Statement”). Capitalized terms used herein, but not otherwise defined, have the meanings ascribed to them in the Registration
Statement.

Comment 1 – Table
of Contents, page i

In the Table of Contents,
please correct the typographical errors in the lines “XRP, XRP Market and Regulation of XRP” and “The Trust and XRP
Prices.”

Response to Comment 1

Pursuant to the Staff’s
comment, the Table of Contents has been revised.

Comment 2 – Prospectus
Summary – Dogecoin, the Dogecoin Blockchain and the Dogecoin Network, page 1

The Staff notes your response
and revised disclosure to prior comment 3 and partially reissue. In an appropriate section, please disclose the transaction fees associated
with transferring Dogecoin.

Response to Comment 2

Pursuant to the Staff’s
comment, the following disclosure has been added to the section entitled “Risk Factors.”

August 15, 2025

Page 2

The prevailing level of transaction fees
may adversely affect the usage of the Dogecoin Network.

Dogecoin miners collect fees for each transaction
they confirm. Miners validate unconfirmed transactions by including them in newly mined blocks. While miners are not required to confirm
any particular transaction, they are economically incentivized to include transactions offering fees, which supplement the fixed block
reward. Mining software generally prioritizes transactions based on (i) user-defined thresholds, (ii) transaction fees, (iii) transaction
value, and (iv) time of receipt.

Transaction fees on the Dogecoin Network have
historically been low due to its fast block time and relatively low network congestion but have fluctuated over time. As of July 24, 2025,
the average fee per transaction was approximately $0.0097 per transaction. However, periods of increased demand could result in higher
fees, which may reduce the attractiveness of using the Dogecoin Network.

If miners were to collude in an anticompetitive
manner to exclude low-fee transactions, users might face delays or be required to pay higher fees for prompt processing. Although such
collusion would likely be difficult to enforce across the globally distributed Dogecoin Network, any perception of unfairness or inefficiency
in transaction processing could negatively impact user adoption of Dogecoin and the performance of a Dogecoin-related investment vehicle
such as the Trust.

Comment 3 – Prospectus
Summary – The Trust’s Fees and Expenses, page 6

Refer to your response to
prior comment 8. Please revise your disclosure to explain the circumstances in which the Trust is responsible for paying the Dogecoin
Blockchain fees. In this regard, the Staff notes your continued disclosure on page 6 that “[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.”

Response to Comment 3

Pursuant to the Staff’s
comment, the referenced disclosure has been revised to clarify that the Trust is not responsible for paying Dogecoin Blockchain fees.

August 15, 2025

Page 3

Comment 4 – Risk
Factors – Dogecoin is a relatively new technological innovation with a limited…, page 15

To provide context for this
risk, please specifically state how long Dogecoin has been traded, and how long it has been traded in the United States.

Response to Comment 4

Pursuant to the Staff’s
comment, the following disclosure has been added to the risk factor entitled “Dogecoin is a relatively new technological innovation
with a limited operating history”:

Dogecoin began trading on major global cryptocurrency
exchanges – including US exchanges – in December 2013.

Comment 5 – Risk
Factors – Possible illiquid markets may exacerbate losses or increase..., page 39

To provide context for this
risk, please provide quantitative disclosure discussing the size and liquidity of the Dogecoin market.

Response to Comment 5

Pursuant to the Staff’s
comment, the following disclosure has been added to the risk factor entitled “Possible illiquid markets may exacerbate losses or
increase the variability between the Trust’s NAV and its market price.”:

As of _________, 2025, the market capitalization
of Dogecoin was $___________ and had an average daily trading volume of $________________. Comparatively, bitcoin had a market capitalization
of _____________ and an average daily trading volume of $_____________ and ether had a market capitalization of _____________ and an average
daily trading volume of $_____________. Both bitcoin and ether are held by exchange-traded products with a structure substantially similar
to the Trust.

Comment 6 – Dogecoin,
Dogecoin Market and Regulation of Dogecoin – Dogecoin Markets and Exchanges, page 63

Please revise to add a brief
discussion of the Dogecoin futures markets.

August 15, 2025

Page 4

Response to Comment 6

Pursuant to the Staff’s
comment, the referenced section of the Registration Statement has been revised to include the following disclosure.

The CFTC has regulatory jurisdiction over the
Dogecoin futures markets. In addition, the CFTC has asserted in enforcement actions that digital assets like Dogecoin may constitute “commodities”
under the Commodity Exchange Act. As such, the CFTC has authority to prosecute fraud and manipulation in the cash, or spot, market for
Dogecoin pursuant to Section 6(c)(1) of the Commodity Exchange Act and CFTC Rule 180.1. Beyond instances of fraud or manipulation, the
CFTC generally does not oversee cash or spot market exchanges or transactions involving Dogecoin that do not use collateral, leverage
or financing.

On April 1, 2024, Coinbase Derivatives, LLC
(“Coinbase Derivatives”), a designated contract market (“DCM”) registered with the CFTC, launched new contracts
for Dogecoin futures products. DCMs are boards of trades (or exchanges) that operate under the regulatory oversight of the CFTC, pursuant
to Section 5 of the Commodity Exchange Act. To obtain and maintain designation as a DCM, an exchange must comply on an initial and ongoing
basis with twenty-three Core Principles established in Section 5(d) of the CEA. Among other things, DCMs are required to establish self-regulatory
programs designed to enforce their rules, prevent market manipulation and customer and market abuses, and ensure the recording and safe
storage of trade information. The CFTC did not formally approve the Dogecoin futures contracts but reviewed Coinbase Derivatives’
self-certification filing pursuant to CFTC Regulation 40.2(a). DCMs are required to ensure that listed products are not susceptible to
manipulation and that they comply with the CEA and all applicable regulations. In connection with listing Dogecoin futures, Coinbase Derivatives
was required to maintain information-sharing agreements with digital asset spot platforms to monitor cash market activity and price formation;
to surveil for potential manipulation or anomalous price movements between the spot and futures markets; and to coordinate with CFTC surveillance
staff as needed, including sharing trade and settlement data upon request. As of ____________, 2025, the open interest on such Dogecoin
futures amounted to $______________.

August 15, 2025

Page 5

Comment 7 – Dogecoin,
Dogecoin Market and Regulation of Dogecoin – Government Oversight, Though Increasing, Remains Limited, page 66

Please revise this section
to include a discussion of the regulation of Dogecoin futures and government oversight.

Response to Comment 7

Please see above Response
to Comment 6.

Comment 8 – The
Trust and Dogecoin prices, page 68

The Staff notes that you deleted
the following statement appearing on page 67 of the prior filing: “If there are changes to the Constituent Platforms used to calculate
the Pricing Benchmark, or other material changes to the Pricing Benchmark calculation methodology, the Trust will notify Shareholders
in a prospectus supplement and a current report on Form 8-K or in its annual or quarterly reports.” Please restore this disclosure,
or explain why it was removed.

Response to Comment 8

The Registrant has revised
the disclosure to make clear that while material changes to the calculation methodology may warrant a prospectus supplement and/or Form
8-K filing, mere changes to the Constituent Platforms will not. Changes made by the Benchmark Provider to the Constituents do not constitute
a material change that would necessitate the filing of a Form 8-K or a prospectus supplement.

Comment 9 – The
Trust and Dogecoin prices, page 68

Related to Comment 8, in this
amendment, you have also removed your tabular disclosures providing market share and volume information for each Constituent Platform
used to calculate the Dogecoin price appearing on pages 68 - 69 of the prior filing. Please restore these disclosures.

Response to Comment 9

The disclosure has been restored.

Comment 10 – The
Trust and Dogecoin prices – The CF Dogecoin - Dollar Settlement Price – Pricing Benchmark methodology, page 68

The Staff notes your disclosure
on page 73 that the Benchmark Provider data is used under license as a source of information for the Trust’s products. When available,
please disclose the material terms of any license agreement that the Benchmark Provider and the Sponsor have entered into, including the
obligations of each party and the term and termination provisions. Please also file the agreement as an exhibit to your registration statement
if required by Item 601 of Regulation S-K.

August 15, 2025

Page 6

Response to Comment 10

No such license agreement
exists. The referenced disclosure has been deleted.

Comment 11 – Calculation
of NAV, page 74

The Staff notes your response
and revised disclosure to prior comment 17. Please revise to clarify whether you have a license agreement with a Secondary Source. If
so, please identify the Secondary Source and describe how the value of Dogecoin is calculated by the valuation methods of the Secondary
Source. If not, please so state. In addition, please revise to provide examples of the “available data” the Sponsor will consider
to determine the fair price of Dogecoin if the Pricing Benchmark, the Secondary Source and the principal market price are unavailable
or deemed unreliable.

Response to Comment 11

The Registrant does have agreements
with any third parties for use of their valuation methods and does not have a license to use a secondary index.

Comment 12 – Calculation
of NAV, page 74

The Staff notes your revised
disclosure in response to prior comment 19 that ICE Data Indices, LLC calculates the ITV. To the extent that you have a material agreement
in place with ICE Data Indices, LLC, please revise to disclose the material terms thereof. Also, please file the agreement as an exhibit
to the registration statement, if required by Item 601 of Regulation S-K.

Response to Comment 12

The Registrant anticipates
having an agreement with ICE Data Indices, LLC (“ICE Data”) pursuant to which ICE Data calculates the Trust’s ITV. However,
the Registrant has determined that such agreement will not be material pursuant to Item 601(b)(10)(ii) of Regulation S-K. Such an agreement
is made in the ordinary course of business and the Registrant’s business is not substantially dependent on the services contemplated
under the agreement. The Registrant shares this determination with nearly all other ETF issuers who have declined to file this standard
agreement as an exhibit to their Registration Statement.

August 15, 2025

Page 7

Comment 13 – Custody
of the Trust’s Assets, page 84

Refer to your revised disclosure
in response to prior comment 21 that “[s]imilarly secure technology may include the usage of storage on hardware security modules
(‘HSMs’) that may connect to the internet securely in order to broadcast transactions.” Please revise to address any
risks related to the use of HSMs.

Response to Comment 13

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

While such connectivity is intended to be limited
and secure, it may nonetheless expose the system to cybersecurity risks, including potential vulnerabilities in software, firmware, or
network architecture. Any compromise of the HSM environment, including unauthorized access or exploitation of its internet-connected features,
could result in the loss or theft of digital assets, and may adversely affect the value of the Shares or the Trust’s ability to
transact.

Comment 14 – Creation
and Redemption of Shares, page 95

The Staff notes your disclosure
on page 96 that “[t]he manner by which creations are made is dictated by the terms of the Authorized Participant Agreement.”
Please revise to identify the current Authorized Participants with Authorized Participant Agreements that allow for only cash, only in-kind,
and both cash and in-kind creations and redemptions.

Response to Comment 14

Pursuant to the Staff’s
comment, the following disclosure has been added below to the section entitled Plan of Distribution – Authorized Participants”
and will be populated prior the listing and trading of the Shares.

As of _______________, 2025, ________, ________,
________, ________ and __________ have executed Authorized Participant Agreements with the Trust. Pursuant to the terms of those Authorized
Participant Agreements, each such Authorized Participant, except for _________ and _________, may conduct Cash Creations, Cash Redemptions,
In-Kind Creations and In-Kind Redemptions. As of ___________, 2025, ___________ and _____________ may only conduct Cash Creations and
Cash Redemptions.

August 15, 2025

Page 8

Comment 15 – Creation
and Redemption of Shares, page 95

Refer to the first bullet
of prior comment 23. For creations, please revise your disclosure to clarify whether any excess cash will be returned to the Authorized
Participants to the extent that the cash deposit amount exceeds the execution price of the Dogecoin acquired.

Response to Comment 15

The section of the Registration
Statement entitled “Creation and Redemption of Shares” has been revised to include the following disclosure set forth below.

If the amount of cash required to acquire the
requisite amount of Dogecoin is less than the amount deposited by the Authorized Participant, such excess cash will be returned to the
Authorized Participant.

Comment 16 – Creation
and Redemption of Shares, page 95

The Staff notes your response
to the third bullet of prior comment 23. The Staff is unable to locate your revisions in response to this comment and reissue. Please
revise to clarify whether any costs or transaction fees associated with creations and redemptions are payable by the Trust.

Response to Comment 16

Pursuant to the Staff’s
comment, the following disclosure has been added to the section of the Registration Statement entitled “Creation and Redemption
of Shares – Creation and Redemption Transaction Fee”:

No costs or transaction fees associated with
creations and redemptions are payable by the Trust.

Comment 17 – Conflicts
of Interest, page 102

Refer to your response to
prior comment 25. Please revise this section to address any potential conflicts of interest between the Trust and the Trade Credit Lender
and the Dogecoin Trading Counterp