SecProbe.io

CORRESP
 1
 filename1.htm

 November 21, 2025

 Filed via EDGAR
 Rolf Sundwall, Mark Brunhofer, Irene Paik and Justin Dobbie
 U.S. Securities and Exchange Commission
 Division of Corporation Finance – Office of Crypto Assets
 100 F Street, NE
 Washington, DC 20549

 Subject:

 Franklin Solana Trust (the “Trust”)
 Amendment No. 4 to Registration Statement on Form S-1
 Filed September 26, 2025
 (File No. 333-285121)

 Dear Mr. Sundwall, Mr. Brunhofer, Ms. Paik and Mr. Dobbie:
 On behalf of the Trust, submitted herewith via the EDGAR system are the responses to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the
 “Commission”) provided via written correspondence dated November 18, 2025 with regard to the Trust’s pre-effective Amendment No. 4 to its Registration Statement on Form S-1 (the “Registration Statement”) with respect to the Franklin Solana ETF series
 of the Trust (the “Fund”), which was filed with the Commission on September 26, 2025 under the Securities Act of 1933 (the “1933 Act”).  The Staff’s comments are summarized below, followed by the Trust’s responses thereto.  Terms not defined herein
 have the meaning set forth for that term in the Registration Statement.
 Amendment No. 4 to Registration Statement on Form S-1
 General

 1.

 Comment :  We note your disclosure on the cover page and elsewhere in the prospectus that the Sponsor may seek to use or hold liquid staking tokens in the future. Please confirm your understanding, and revise your disclosure to
 clarify, that the Fund is not currently permitted to hold liquid staking tokens under the Exchange’s generic listing standard.

 Response : The Trust confirms its understanding that the Fund is not currently permitted to hold liquid staking tokens under the Exchange’s generic listing standards. The
 Trust has revised the disclosure throughout the Reigstration Statement to clarify this, as requested.
 Prospectus Summary
 Solana Staking Activities, page 4

 2.

 Comment : You state here that the Fund will receive a portion of the Staking Rewards earned through Staking Activities and the remaining portion of the Staking Rewards will be retained by the Staking Provider. Please revise to
 quantify the percentages of the Staking Rewards that will be retained by each of the Fund and the Staking Provider.

 1

 Response:  As requested, the Trust has revised the disclosure in the Registration Statement to state the percentage of the gross Staking Rewards that will be
 paid to the Staking Provider and the other specified parties (referred to as the Staking Expenses), with the Fund retaining the remainder of the Staking Rewards after payment of such Staking Expenses.
 Attached as Exhibit A hereto please find the proposed fact sheet for the Fund.
 Please do not hesitate to contact J. Stephen Feinour, Jr. at (215) 564-8521 if you have any questions or wish to discuss any of the above responses presented
 above.
 Very truly yours,

 /s/ Julie Patel

 Julie Patel
 Vice President and Secretary of Franklin
 Holdings, LLC, Sponsor of the Trust

 cc:   Navid J. Tofigh, Franklin Templeton
        J. Stephen Feinour, Jr., Stradley Ronon Stevens & Young, LLP
 Miranda Sturgis, Stradley Ronon Stevens & Young, LLP

 2

 Exhibit A