SecProbe.io

CORRESP
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 filename1.htm

 Richard Coyle

 Partner
 Chapman and Cutler LLP

 320 South Canal Street, 27th Floor

 Chicago, Illinois 60606

 T 312.845.3724

 rcoyle@chapman.com

 November 18, 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 Chainlink ETF

 File No. 333-289852

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

 This letter responds to your
comments regarding the registration statement filed on Form S-1 for the Bitwise Chainlink ETF (the "Trust" ) with
the Staff of the Securities and Exchange Commission (the "Staff" ) on August 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 – 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 Registrant will provide
the fact sheet in the future under separate cover when such fact sheet is available.

 Comment 2 – Prospectus
Summary – Chainlink and the Chainlink Network, page 1

 We note you include some disclosure
relating to staking on the Chainlink Network. To the extent the Trust plans to stake its LINK when the product launches, please revise
to provide a materially complete description of any planned staking program. Please also confirm your understanding that we may have additional
comments upon reviewing any revised disclosure.

 November 18, 2025

 Page 2

 Response to Comment 2

 The disclosure has been revised
to make clear that the Trust does not intend to stake its Chainlink at the time of launch and that prior to commencing with staking the
Trust will amend its registration statement, which will be subject to SEC comment and review. Such disclosure is set forth below.

 As of the date of this prospectus, the Trust
does not engage in staking. However, at a future date, it is the current intention of the Trust to amend its registration statement to
allow the Trust to conduct staking as a secondary investment objective. The amended registration statement will include a detailed description
of the Trust's staking program under a section entitled "STAKING."

 Comment 3 – Prospectus
Summary – The Trust's Investment Objective and Strategies – Purchases and Sales of Chainlink, page 3

 Please revise to clarify which
party is responsible for fees of Chainlink Trading Counterparties in connection with their purchase and sale of LINK. In this regard,
we note your statement that the Sponsor will not assume such fees.

 Response to Comment 3

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

 The Chainlink Trading Counterparties will pay
their own fees associated with their purchase and sale of Chainlink.

 Comment 4 – Risk
Factors – Risks Related to Digital Assets – The trading prices of many digital assets, page 11

 Please revise to include quantitative
examples of LINK's historic price volatilities.

 Response to Comment 4

 The Registrant directs the Staff
to the disclosure at the end of the first paragraph of the referenced risk factor, which is set forth below:

 Chainlink has exhibited a
historical annualized volatility of 104.63% and maximum annual price decrease of 85.87% over the past five years.

 November 18, 2025

 Page 3

 Comment 5 – Risk
Factors – Risks Associated with Chainlink and the Chainlink Network, page 14

 To the extent material, please
add a separately-captioned section to discuss any risks associated with the Chainlink Reserve.

 Response to Comment 5

 The Registration Statement
has been revised to include the following disclosure regarding the risks associated with the Chainlink Reserve:

 Changes to "Chainlink
Reserve" program, including failure, hacks, or withdrawals, may adversely impact the value of the Shares.

 On August 7, 2025, Chainlink
Labs launched a Chainlink purchasing program called "Chainlink Reserve" that programmatically acquires Chainlink tokens from
the open market on a weekly basis using revenue generated by Chainlink business operations. As of November 14, 2025, the Chainlink Reserve
held 803,388 Chainlink worth approximately $11.4 million. Chainlink Labs has described the Reserve as a "strategic" program
that will grow with increased adoption of the Chainlink Network. It has said that it does not expect to make any "withdrawals"
from the Chainlink Reserve for several years.

 If a malicious actor were
to compromise the Chainlink Reserve and steal the funds contained therein, that incident could negatively impact value of Chainlink, and
thus the value of the shares.

 Chainlink Labs has not disclosed
all the revenue sources that supply the Chainlink Reserve program. While some of the revenues are derived from traceable, onchain business
activities, other revenues come from offchain businesses. It is unknown what percentage of total Chainlink revenue Chainlink Labs has
earmarked for the Chainlink Reserve Program. A change in the purchasing size of the Chainlink Reserve program could negatively impact
the value of the shares.

 Chainlink Labs has not
disclosed the conditions under which Chainlink tokens acquired in the Chainlink Reserve program would be withdrawn from the program. Any
shift in the strategy of the program, including sudden withdrawals, could negatively impact the value of the shares.

 November 18, 2025

 Page 4

 Comment 6 – Chainlink,
Chainlink Market and Regulation of Chainlink – Chainlink Supply, page 61

 Please revise to include the
locking and unlocking schedule for LINK. In this regard, we note your statement on page 9 that the ongoing unlocking of Chainlink may
cause the price of Chainlink to decline over time.

 Response to Comment 6

 Pursuant to the Staff's
comment, the disclosure has been revised, as set forth below:

 The total supply of Chainlink
is capped at 1 billion tokens, many of which were subject to time locks following the initial creation. As of November 14, 2025, approximately
696,840,970 Chainlink tokens were believed to be in the circulating supply. Chainlink Labs unlocks batches of tokens roughly once every
quarter. The token release schedule is currently 7% of the total supply per year

 Comment 7 – The
Trust and Chainlink Prices – The CME CF Chainlink-Dollar Reference Rate - New York Variant, page 66

 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. Alternatively, if there will not be an agreement with the Benchmark Provider prior to effectiveness, please
explain whether you are authorized to value the net assets of the Trust and its Shares on a daily basis with the Pricing Benchmark calculated
by the Benchmark Provider.

 November 18, 2025

 Page 5

 Response to Comment 7

 The Registrant confirms that
it will file the Pricing Benchmark License Agreement as an exhibit to the Registration Statement. Additionally, the Registration Statement
has been revised to include the following disclosure regarding the terms of the Pricing Benchmark License Agreement:

 Pricing Benchmark License Agreement

 The Sponsor has entered into an agreement with
the Benchmark Provider (the "Pricing Benchmark License agreement") providing the Trust with a non-exclusive, non-transferable,
non-sub-licensable, perpetual, worldwide, license to access, view and use the Pricing Benchmark to develop, create, calculate, settle,
maintain or support and market the Trust for the term of the Pricing Benchmark License Agreement. The Pricing Benchmark License Agreement
is subject to a three-year initial term period and will automatically be renewed for successive one-year periods, unless terminated pursuant
to the terms of the Pricing Benchmark License Agreement.

 Comment 8 – Calculation
of NAV, page 70

 Please address the following
points in your next amendment and/or response letter, as applicable:

 ● With a view towards revised disclosure, please
tell us whether you have agreements with any third parties for use of their valuation methods. We may have further comments based upon
your response and any revisions.

 ● Please revise your disclosure to state whether
you have an agreement with a Secondary Source. To the extent that you have identified a Secondary Source that you intend to use, please
identify the Secondary Source and describe how the value of LINK is calculated by the valuation methods of the Secondary Source. To the
extent that you do not yet have plans related to which Secondary Source you will use, please so state. Also, please revise to provide
examples of the "available data" the Sponsor will consider to determine the fair price of LINK if the Pricing Benchmark, the
Secondary Source or the principal market price are unavailable or deemed unreliable.

 November 18, 2025

 Page 6

 Response to Comment 8

 Besides the Pricing Benchmark
License Agreement referenced in Response to Comment 7, as of the date of this correspondence, the Trust does not have executed agreements
with any third parties for use of their valuation methods. However, the Sponsor has a high degree of confidence that by the time of effectiveness
of the Registration Statement it will have entered into an agreement allowing it to use the Lukka Digital Asset Reference Rate –
Chainlink as a Secondary Source. Accordingly, the following disclosure has been added to the section entitled "Calculation of NAV":

 In such cases, the Sponsor expects to utilize
a volume-weighted average price or volume-weighted median price of Chainlink provided by a secondary pricing source (a Secondary Source).
It is currently expected that the Lukka Digital Asset Reference Rate – Chainlink, the Lukka Reference Rate, would be used a Secondary
Source. The Lukka Reference Rate provides a reference rate for the U.S. dollar price of Chainlink (LINK/USD), calculated as of 4:00 p.m.
ET. The Lukka Reference Rate aggregates executed transactions from several trading venues, during a calculation window between 3:00 p.m.
and 4:00 p.m. ET and produces a U.S. Dollar price of Chainlink at 4:00 p.m. ET. Specifically, the Lukka Reference Rate is calculated based
on eligible transactions from all of the eligible exchanges, which are currently Bitfinex, Bitstamp, Coinbase, Crypto.com, Gemini, Kraken,
LMAX Digital, and OKX, and which may change from time to time as approved by Lukka's Price Integrity Oversight Board. In determining
the value of Chainlink, Lukka applies a multi-step process for aggregating executed transactions for Chainlink from several trading venues
during a calculation window between 3:00 p.m. and 4:00 p.m. ET to produce a Chainlink price as of 4:00 p.m. ET. Step 1: Executed transactions
from eligible exchanges are collected by Lukka. Step 2: The calculation window is sectioned into equal time intervals, called partitions.
Step 3: For each combination of partition, exchange and currency-pair, a Volume Weighted Average Price ("VWAP") is calculated.
Step 4: For each partition and currency pair, the median of these VWAP's by exchange is calculated. Step 5: The Lukka Reference
Rate for Chainlink is then calculated as the simple average of the partition medians calculated in the previous step.

 Lastly, as it relates to the
data that the Sponsor will utilize in a fair value situation, the referenced disclosure has been revised as set forth below.

 If a Secondary Source is not available, or if
the Sponsor determines in its sole discretion that the Secondary Source is unreliable, the Sponsor may consider the price reported by
the Trust's principal market as of 4:00 p.m. ET on the valuation date. If the principal market price is also unavailable or deemed
unreliable by the Sponsor, the Sponsor will use its best judgment to determine a good faith estimate of fair value based on all available
data (such as pricing data available from the digital asset trading platforms it deems most reliable) . (emphasis added)

 November 18, 2025

 Page 7

 Comment 9 – Custody
of the Trust's Assets, page 80

 You disclose that a "substantial
portion" of the private keys will be held in the Cold Chainlink Account with the remaining portion held in the Hot Chainlink Account,
but you also disclose that "[t]he Sponsor expects that all of the Trust's assets and private keys will be held in cold
storage." Please reconcile the inconsistency.

 Response to Comment 9

 Pursuant to the Staff's
comment, the disclosure has been revised, as set forth below:

 The Sponsor expects that all
of the Trust's assets and private keys, other than those maintained in the Trading Balance with the Prime Execution Agent or held
in a Hot Chainlink Account, will be held in cold storage of the Chainlink Custodian on an ongoing basis.

 Comment 10 – Governing
Law; Consent to Delaware Jurisdiction, page 103

 We note the statement on page
103 that each Shareholder consents "to the exclusive jurisdiction of the courts of the State of Delaware and any federal courts
located in Delaware" and that, pursuant to the Trust Agreement, such clause "shall not apply to causes of action for violations
of U.S. federal or state securities laws." Please direct us to the portion of the Trust Agreement that contains these provisions.

 Response to Comment 10

 Please see section 10.3 of
the Trust Agreement filed as Exhibit 3, reproduced below.

 Each party hereto, each Authorized
Participant by its delivery of an Authorized Participant Agreement and each Registered Owner and Beneficial Owner by the acceptance of
a Share irrevocably consents to the jurisdiction of the courts of the State of Delaware, and of any federal court located in New Castle
County, Delaware, in connection with any action, suit or other proceeding arising out of or relating to the Shares, the Trust Property
or this Agreement or any action taken or omitted under this Agreement and waives any claim of forum non conveniens and any objections
as to laying of venue; provided however, that actions for violations of the Securities Act, or the rules and regulations promulgated thereunder,
or the Securities Exchange Act of 1934 or the rules and regulations promulgated can be brought in any forum pursuant to applicable federal
securities laws. Each party further waives personal service of any summons, complaint or other process and agrees that service thereof
may be made by certified or registered mail directed to such Person at such Person's address last specified for purposes of notices
hereunder.

 ********

 November 18, 2025

 Page 8

 Please call me at (312) 845-3724
if you have any questions or issues you would like to discuss regarding these matters.

 Sincerely yours,

 Chapman and Cutler LLP

 By:
 /s/ Richard Coyle

 Richard Coyle