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SEC Comment Letter for 21Shares Dogecoin ETF (TDOG) — Dec 15, 2025

21Shares Dogecoin ETF
Date: Dec. 15, 2025 · CIK: 0002064314 · Accession: 0000000000-25-011555

Financial Reporting Related Party / Governance Regulatory Compliance

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Urgency
Document Type
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SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 333-286456

Date
December 15, 2025
Author
Division of
Form
UPLOAD
Company
21Shares Dogecoin ETF

Letter

Re: 21Shares Dogecoin ETF Amendment No. 5 to Registration Statement on Form S-1 Filed December 2, 2025 File No. 333-286456 Dear Russell Barlow:

December 15, 2025

Russell Barlow Chief Executive Officer 21Shares Dogecoin ETF 477 Madison Avenue, 6th Floor New York, NY 10022

We have reviewed your amended registration statement and have the following comment.

Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe the 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.

Amendment No. 5 to Registration Statement on Form S-1 The Trust's Service Providers The Service Provider, page 75

1. Please revise to provide greater detail regarding the Support Services Agreement, including compensation. In this regard, we note publicly available information that in exchange for providing research, data, sales and marketing and operational support services, House of Doge is entitled to compensation equal to 50% of the net sponsor fee, payable quarterly in arrears. December 15, 2025 Page 2

Please contact David Irving at 202-551-3321 or Jason Niethamer at 202-551-3855 if you have questions regarding comments on the financial statements and related matters. Please contact Lulu Cheng at 202-551-3811 or Sandra Hunter Berkheimer at 202- 551-3758 with any other questions.

Sincerely,
Division of
Corporation Finance
Office of Crypto
Assets
cc: Allison Fumai

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 December 15, 2025

Russell Barlow
Chief Executive Officer
21Shares Dogecoin ETF
477 Madison Avenue, 6th Floor
New York, NY 10022

 Re: 21Shares Dogecoin ETF
 Amendment No. 5 to Registration Statement on Form S-1
 Filed December 2, 2025
 File No. 333-286456
Dear Russell Barlow:

 We have reviewed your amended registration statement and have the
following
comment.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe the 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.

Amendment No. 5 to Registration Statement on Form S-1
The Trust's Service Providers
The Service Provider, page 75

1. Please revise to provide greater detail regarding the Support Services
Agreement,
 including compensation. In this regard, we note publicly available
information that in
 exchange for providing research, data, sales and marketing and
operational support
 services, House of Doge is entitled to compensation equal to 50% of the
net sponsor
 fee, payable quarterly in arrears.
 December 15, 2025
Page 2

 Please contact David Irving at 202-551-3321 or Jason Niethamer at
202-551-3855 if
you have questions regarding comments on the financial statements and related
matters. Please contact Lulu Cheng at 202-551-3811 or Sandra Hunter Berkheimer
at 202-
551-3758 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Crypto
Assets
cc: Allison Fumai
</TEXT>
</DOCUMENT>