SecProbe.io

CORRESP
 1
 filename1.htm

 Bitwise 10 Crypto Index ETF
250 Montgomery Street, Suite 200

 San Francisco, California 94104

 December 4, 2025

 VIA EDGAR CORRESPONDENCE

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, DC 20549

 Re: Bitwise 10 Crypto Index ETF
(the "Registrant" )

 Ladies and Gentlemen:

 The undersigned, Bitwise 10 Crypto Index ETF
(formerly Bitwise 10 Crypto Index Fund) (the " Registrant "), pursuant to the provisions of Rule 461 of the General
Rules and Conditions of the Securities and Exchange Commission (the " Commission ") under the Securities Act of
1933, as amended, hereby respectfully requests that the Commission grant acceleration of the effectiveness of Amendment No. 4 to the
Registrant's Registration Statement on Form S-3 (Registration No. 333-287889), filed on December 4, 2025, so that the same may
become effective at 4:30 p.m. Eastern Time on December 8, 2025 or as soon thereafter as practicable.

 Very truly yours,

 Bitwise Investment Advisers, LLC,

 Sponsor of the Bitwise 10 Crypto Index ETF

 By:
 /s/ Paul Fusaro

 Name:
 Paul Fusaro

 Title:
 Chief Operating Officer and Secretary

 (Principal Executive Officer)*

 * As the Registrant is a Trust, this correspondence is being filed on behalf of the Registrant by Bitwise Investment Advisers, LLC in
its capacity as the Sponsor of the Registrant. The identified person signing this correspondence is signing in that person's capacity
as an authorized officer of Bitwise Investment Advisers, LLC.

CORRESP
1
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

September
10, 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 10 Crypto Index Fund

File
No. 333-287889

Dear
Ms. Cheng and Ms. Paik:

This
letter responds to your comment provided telephonically on September 3, 2025 regarding amendment no. 2 to the registration statement
filed on Form S-3 for the Bitwise 10 Crypto Index Fund (the “Trust”) with the Staff of the Securities and Exchange
Commission (the “Staff”) on August 25, 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

The
Staff notes the response to prior comment 1 and reissues in part. Please revise to reconcile the inconsistencies between the publicly
available information about the Index and the information incorporated by reference to the 10-K. For example, some of the crypto asset
eligibility criteria for the Index appear to be inconsistent, such as the requirement that the crypto asset must have traded more than
1% of its free float adjusted market cap on eligible trading venues over the past 30 days, the requirement that it has maintained a unit
price greater than one cent for the past consecutive 30 days, and the circumstances in which the Sponsor will retain discretion to exclude
one or more crypto assets and or rebalance the weighting of the portfolio assets.

Response
to Comment 1

The
prospectus has been updated to reconcile the inconsistencies between the publicly available information about the Index and the information
incorporated by reference to the 10-K in accordance with the Staff’s comment.

*
* * * * * * *

September 10, 2025

Page 2

Please
call me at (312) 845-3724 or my colleague James Audette at (312) 845-3421 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

    cc:
    James
    Audette, Esq., Chapman and Cutler LLP

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

August 22, 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 10 Crypto Index Fund

    File No. 333-287889

Dear Ms. Cheng and Ms. Paik:

This letter responds to your
comments regarding amendment no. 1 to the registration statement filed on Form S-3 for the Bitwise 10 Crypto Index Fund (the “Trust”)
with the Staff of the Securities and Exchange Commission (the “Staff”) on July 18, 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

The Staff notes that the Exchange
filed an amended Rule 19b-4 application on July 17, 2025. Please revise your disclosure throughout the prospectus, including with respect
to information incorporated by reference from your Annual Report on Form 10-K for the fiscal year ended December 31, 2024, for consistency
with the amended Rule 19b-4 application.

Response to Comment 1

The disclosure throughout
the prospecuts has been updated to align with the representations made in the Rule 19b-4 application, including information incorporated
by reference therein.

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

The Staff notes your response
to prior comment 3. Please reconcile your disclosures here and on page 28 to be consistent with your response relating to the Sponsor’s
pursuit of incidental opportunities.

Response to Comment 2

The prospectus has been updated
in applicable sections to make clear that the Trust will not pursue incidental opportunities..

August 22, 2025

Page 2

Comment 3 – Prospectus
Summary – The Index, page 1

Please revise to include a
brief description of each of the constituent platforms comprising the Index, including the eligibility criteria, any oversight of the
selection process, and where the platforms are located and how they are licensed or regulated. In addition, please include a table with
market share and volume information for each constituent platform used to calculate the Index.

Response to Comment 3

The prospectus has been updated
in accordance with the Staff’s comment.

Comment 4 – Material
Contracts – Custodian Agreement, page 53

The Staff notes your response
to prior comment 4. Please reconcile your statement here that “[n]either the Sponsor nor the Trust has given any instructions to
the Custodian as it relates to Incidental Rights and/or IR Assets,” with your disclosure elsewhere that the Trust will not seek
to acquire, and has disclaimed ownership in any, IR Assets or Incidental Rights.

Response to Comment 4

The prospectus has been updated
in applicable locations to make clear that the Trust will disclaim such assets but it has not given an anticipatory instruction
to the Custodian..

Comment 5 – Exhibits

The Staff notes your response
to prior comment 20 and re-issues the comment in part. Please file your Prime Execution Agreement and Trade Financing Agreement as exhibits
to the registration statement, or tell us why they are not required to be filed. Refer to Item 601(b)(10) of Regulation S-K.

Response to Comment 5

In accordance with the Staff’s
comments, the Prime Execution Agreement and Trade Financing Agreement have been filed as exhibits to the Registration Statement.

********

August 22, 2025

Page 3

Please call me at (312) 845-3724
or my colleague James Audette at (312) 845-3421 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

    cc:
    Katherine Dowling, Esq., General Counsel of Bitwise Asset Management

    James Audette, Esq., Chapman and Cutler LLP

August 1, 2025
Hunter Horsley
President and Treasurer
Bitwise 10 Crypto Index Fund
250 Montgomery Street, Suite 200
San Francisco, CA 94104
Re:Bitwise 10 Crypto Index Fund
Amendment No. 1 to Registration Statement on Form S-3
Filed June 18, 2025
File No. 333-287889
Dear Hunter Horsley:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a 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. Unless we note
otherwise, any references to prior comments are to comments in our July 2, 2025 letter.
Amendment No. 1 to Registration Statement on Form S-3
General
1.We note that the Exchange filed an amended Rule 19b-4 application on July 17, 2025.
Please revise your disclosure throughout the prospectus, including with respect to
information incorporated by reference from your Annual Report on Form 10-K for the
fiscal year ended December 31, 2024, for consistency with the amended Rule 19b-4
application.

August 1, 2025
Page 2
Prospectus Summary
Overview of the Trust, page 1
2.We note your response to prior comment 3. Please reconcile your disclosures here and
on page 28 to be consistent with your response relating to the Sponsor’s pursuit of
incidental opportunities.
The Index, page 3
3.Please revise to include a brief description of each of the constituent platforms
comprising the Index, including the eligibility criteria, any oversight of the selection
process, and where the platforms are located and how they are licensed or regulated.
In addition, please include a table with market share and volume information for each
constituent platform used to calculate the Index.
Material Contracts
Custodian Agreement, page 53
4.We note your response to prior comment 4. Please reconcile your statement here that
“[n]either the Sponsor nor the Trust has given any instructions to the Custodian as it
relates to Incidental Rights and/or IR Assets,” with your disclosure elsewhere that the
Trust will not seek to acquire, and has disclaimed ownership in any, IR Assets or
Incidental Rights.
Exhibits
5.We note your response to prior comment 20 and re-issue the comment in part. Please
file your Prime Execution Agreement and Trade Financing Agreement as exhibits to
the registration statement, or tell us why they are not required to be filed. Refer to
Item 601(b)(10) of Regulation S-K.
            Please contact Lulu Cheng at 202-551-3811 or Irene Paik at 202-551-6553 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets
cc:James Audette, Esq.

CORRESP
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    Richard Coyle
    Chapman and Cutler LLP

    Partner
    320 South Canal Street, 27th Floor

    Chicago, Illinois  60606

    T 312.845.3724

    rcoyle@chapman.com

July 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 10 Crypto Index Fund

              File No. 333-287889

Dear Ms. Cheng and Ms. Paik:

This letter responds to your
comments regarding the registration statement filed on Form S-3 for the Bitwise 10 Crypto Index Fund (the “Trust”)
with the Staff of the Securities and Exchange Commission (the “Staff”) on June 10, 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

The Staff notes your statement
on page 16 of the Trust’s Form 10-K (“Trust Annual Report”) for the fiscal year ended December 31, 2024, that the Committee’s
risk-based assessment that considers whether a Crypto Asset may be deemed a security under U.S. federal securities laws “does not
preclude legal or regulatory action based on the presence of a security.” In future filings, please further revise to state that
any such assessment is not a legal standard or determination binding on any regulatory body or court.

Response to Comment 1

The Registrant confirms that
it will further revise the referenced disclosure in future filings to state that any such assessment is not a legal standard or determination
binding on any regulatory body or court.

Comment 2 – General

Please revise to disclose
whether and how you expect that the initial and continuing listing requirements applicable to the Trust may impact the weighting of the
Trust’s Portfolio Crypto Assets.

July 18, 2025

Page 2

Response to Comment 2

In accordance with the Staff’s
comment, the following has been added under the caption “Prospectus Summary – The Index”:

Notwithstanding the foregoing, pursuant to the
rules of the Exchange, on [ ], 2025, the Index methodology was modified to include the condition that at least 85% of the index components
will consist of commodities that are the primary investment underlying exchange traded-products that have been approved by the SEC to
list and trade on a national securities exchange. This condition may result in a different weighting of Portfolio Crypto Assets than if
such condition had not been adopted.

Comment 3 – Cover
Page

To the extent the Trust intends
to “take advantage of incidental opportunities to generate additional returns in excess of the Index” as discussed on page
1, please provide such disclosure on the cover page.

Response to Comment 3

The Registration Statement
has been updated in accordance with the Staff’s comment.

Comment 4 – Prospectus
Summary – The Trust’s Investment Objective and Strategies, page 1

The Staff notes that the “Sponsor
has the discretion, when possible and prudent, to take advantage of incidental opportunities to generate additional returns in excess
of the Index...through, for example, Airdrops, Staking, Emissions, Hard Forks, lending or similar network events and activities.”
Please revise to describe:

 ● Whether any approvals are necessary for the Trust
to engage in such activities;

 ● In greater detail the lending and “similar
network events and activities” that the Sponsor may take advantage of;

 ● The criteria, if any, the Sponsor will use to
exercise such discretion; and

 ● How and when investors will be informed as to
when the Sponsor exercises such discretion and the identity of the related Portfolio Crypto Asset.

July 18, 2025

Page 3

Response to Comment 4

In accordance with the representations
made in the Exchange’s 19b-4 application related to the listing and trading of the Shares of the Trust, references to such incidental
opportunities have been removed from the Registration Statement. Accordingly, the Staff’s comment is no longer applicable. In addition,
the following disclosure has been added to the prospectus:

Incidental Rights

Notwithstanding anything to the contrary in
the Annual Report, the Trust may, from time to time, passively receive, by virtue of holding Portfolio Crypto Assets, certain additional
digital assets (“IR Assets”) or rights to receive IR Assets (“Incidental Rights”) through a fork of a digital
asset network or an airdrop of assets. The Trust will not seek to acquire such IR Assets or Incidental Rights. Pursuant to the terms of
the Trust Agreement, the Trust has disclaimed ownership in any such IR Assets and/or Incidental Rights to make clear that such assets
are not and shall never be considered assets of the Trust and will not be taken into account for purposes of determining the Trust’s
NAV or NAV per Share. Neither the Trust, nor the Sponsor, nor the Custodian, nor any other person associated with the Trust will, directly
or indirectly, engage in action where any portion of the Trust’s Portfolio Crypto Assets becomes subject to any proof-of-stake validation
or is used to earn additional assets or generate income or other earnings.

Comment 5 – Prospectus
Summary – The Index, page 3

The Staff notes that you incorporate
by reference the description of the Index Methodology provided in the Trust Annual Report. In future Exchange Act reports, to the extent
incorporated by reference, please address the following in your disclosure regarding the Index Methodology:

 ● Include a table with market share and volume
information for each Crypto Asset exchange selected by the Sponsor and its affiliates to calculate the value of Crypto Assets in the Index;

 ● Explain how the Crypto Asset exchanges are selected;

 ● Include a brief description of each of the Crypto
Asset exchanges, including where they are located and how they are licensed or regulated; and

 ● Revise to describe the adjustments that may be
made to the Index and the impact that such adjustments could have on the NAV of the Trust.

July 18, 2025

Page 4

Response to Comment 5

The Sponsor undertakes to
update its future Exchange Act reports in accordance with the Staff’s comments.

Comment 6 – Prospectus
Summary – Calculation of NAV, page 4

The Staff notes your cross-reference
to “Part I—Item 1. Business—Calculation of NAV” in the Trust Annual Report. Please revise this cross-reference
to refer to the correct section of the Trust Annual Report.

Response to Comment 6

The cross-references referenced
in the Staff’s comments have been corrected.

Comment 7 – Prospectus
Summary – The Trust’s Legal Structure, page 4

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. In this regard, the Staff notes your disclosure on page 59 that “except
as required under applicable federal law or under the rules or regulations of an Exchange, Shareholders do not have any voting rights,
take no part in the management or control, and have no voice in, the Trust’s operations or business.”

Response to Comment 7

The Registration Statement
has been updated in accordance with the Staff’s comment.

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

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

Response to Comment 8

The Registration Statement
has been updated in accordance with the Staff’s comment.

July 18, 2025

Page 5

Comment 9 – Prospectus
Summary – The Trust’s Fees and Expenses, page 6

Please reconcile your usage
of the term “Sponsor Fee” with the term “Management Fee.”

Response to Comment 9

The Registration Statement
has been updated in accordance with the Staff’s comment.

Comment 10 – Prospectus
Summary – The Trust’s Fees and Expenses, page 6

The Staff notes your disclosure
that the “Trust is not responsible for paying any fees or costs associated with the transfer of Crypto Assets or cash to the Sponsor,”
and it is unclear whether these fees and costs are paid by the Sponsor. Please revise to clarify when the Trust is responsible for paying
blockchain fees.

Response to Comment 10

The Registration Statement
has been updated in accordance with the Staff’s comment.

Comment 11 – The
Trust’s Investment Program – Purchase and Sale of Crypto Assets – Trust-Directed Trade Model, page 29

The Staff notes your disclosure
that transfer fees with respect to on-chain transfers to and from the Custodial Account to the Trading Counterparty will be paid by the
Custodian. The Staff also notes your statement on page 32 that the Sponsor will direct the Custodian to transfer Portfolio Crypto Assets
from the Custodial Account to pay Trust expenses not assumed by the Sponsor. Please revise to clarify whether the Custodian will pay such
transfer fees using the Trust’s assets.

Response to Comment 11

Pursuant
to the Staff’s comment, the following has been added to the referenced section: “The costs of such transfers will be
the responsibility of the Custodian.”

Comment 12 – The
Trust’s Investment Program – Purchase and Sale of Crypto Assets – Trust-Directed Trade Model, page 29

The Staff notes your disclosure
that “[t]here is no contractual relationship between the Trust, the Sponsor or the Trading Counterparties and all transactions will
be done on an arms-length basis.” However, the Staff also notes your disclosure on page 3 that “[t]he Sponsor has entered
into contractual agreements with the Trading Counterparties, and these agreements set forth the general parameters under which transactions
in Portfolio Crypto Assets will be effectuated, should any transaction with a Trading Counterparty occur.” Please revise your disclosure
as appropriate to reconcile this discrepancy. In addition, to the extent that the Sponsor has entered into contractual arrangements with
Trading Counterparties, please disclose the material terms of the agreements, including the term, termination and indemnification provisions,
as applicable.

July 18, 2025

Page 6

Response to Comment 12

The Registration Statement
has been updated to correct this discrepancy. In addition, the following description of the contractual arrangement with the Trading Counterparties
has been added:

Such agreements have an indefinite term and
may be terminated at will by either party. Such agreements also provide that the Trust and the Sponsor will indemnify the Trust Trading
Counterparty and its affiliates against all losses, liabilities, judgments, proceedings, claims, damages and costs (including attorneys’
fees) resulting from any third-party action related to: (i) the Trust’s breach of the terms of the applicable agreement, (ii) the
Trust’s violation of any applicable law, rule or regulation, (iii) the Trading Counterparty’s reliance on any instruction
(in whatever form delivered) which it reasonably believed to have been given by the Trust, or (iv) other acts or omissions in connection
with the execution of Crypto Asset transactions.

Comment 13 – Custody
of the Trust’s Assets, page 33

You disclose that the Custodian
will keep a “substantial portion” of the private keys associated with the Trust’s Portfolio Crypto Assets in cold storage
or “similarly secure technology.” Please revise to disclose the percentage of the Portfolio Crypto Assets that is held in
cold storage and describe the “similarly secure technology” used to hold the private keys.

Response to Comment 13

The Registration Statement
has been updated in accordance with the Staff’s comment.

Comment 14 – Custody
of the Trust’s Assets, page 33

Please define the term “Hot
Storage Account.”

July 18, 2025

Page 7

Response to Comment 14

The Registration Statement
has been updated in accordance with the Staff’s comment.

Comment 15 – The
Prime Execution Agent and the Trade Credit Lender – The Trade Credit Lender, page 40

Please disclose the interest
rate of Trade Credits. Please also disclose the maximum “Authorized Amount” of Trade Credits available to the Trust.

Response to Comment 15

The Registration Statement
has been updated in accordance with the Staff’s comment.

Comment 16 – Creations
and Redemptions of Shares, page 43

Please revise to include the
following disclosures:

 ● For creations, please 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 Portfolio
Crypto Assets acquired.

 ● For creation and redemption transactions, disclose
whether the interest payable on Trade Credits utilized under the Trade Financing Agreement are included in the execution price and therefore
the responsibility of the Authorized Participants

 ● Please discuss the mechanics of the redemption
procedures, including how and when cash and the Shares are transferred under the Trust-Directed Trade Model and the Agent Execution Model.

 ● Clarify whether any costs or transaction fees
associated with creations and redemptions are payable by the Trust.

Response to Comment 16

The Registration Statement
has been updated in accordance with the Staff’s comment.

July 18, 2025

Page 8

Comment 17 – Creations
and Redemptions of Shares – Suspension or Rejection of Redemption Orders, page 45

Please revise to disclose
whether and how you will notify Shareholders if the Trust has suspended creations and redemptions, and describe the potential impact of
suspending creations and redemptions.

Response to Comment 17

The
following has been added to the referenced section: “If the Trust suspends creation or redemption orders, the Sponsor will
notify Shareholders by posting such notice 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.” In addition, the Registration Statement has been updated to include
a cross-reference to the risks related to the suspension of the creation and redemption of Shares.

Comment 18 – Use
of Proceeds, page 46

To the extent applicable,
please revise your disclosure to address how you will use the proceeds received by the Trust from incidental opportunities to generate
additional returns through, “for example, Airdrops, Staking, Emissions, Hard Forks, lending or similar network events and activities.”

Response to Comment 18

As discussed above in connection
with Comment 4, in accordance with the representations made in the Exchange’s 19b-4 application related to the listing and trading
of the Shares of the Trust, references to such incidental opportunities have been removed from the Registration Statement.

Comment 19 – Conflicts
of Interest, page 47

Please revise this section
to address any potential conflicts of interest between the Trust and Authorized Participants on the one hand, and the Prime Execution
Agent, the Trade Credit Lender and the Trading Counterparties, on the other hand, as applicable.

July 18, 2025

Page 9

Response to Comment 19

The “Conflicts of Interest”
section of the Registration Statement has been updated to include the following:

Conflicts of Interest for the Prime Execution
Agent, the Custodian and the Trade Credit Lender

The Prime Execution Agent, the Custodian and
the Trade Credit Lender are affiliates of Coinbase Global. As affiliates, the Coinbase Entities may have actual or potential conflicts
of interest when executing the Trust’s orders. As a result of these and other conflicts, when acting as principal, the Coinbase
Entities may have an incentive to favor their own interests and the interests of their affiliates over the Trust’s interests and
have in place certain policies and procedures that are designed to mitigate such conflicts. For additional information on the conflicts
of interest of the Coi

July 2, 2025
Hunter Horsley
President and Treasurer
Bitwise 10 Crypto Index Fund
250 Montgomery Street, Suite 200
San Francisco, CA 94104
Re:Bitwise 10 Crypto Index Fund
Registration Statement on Form S-3
Filed June 10, 2025
File No. 333-287889
Dear Hunter Horsley:
            We have conducted a limited review of your registration statement and have the
following comments.
            Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a 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.
Registration Statement on Form S-3
General
1.We note your statement on page 16 of the Trust’s Form 10-K (“Trust Annual Report”)
for the fiscal year ended December 31, 2024, that the Committee’s risk-based
assessment that considers whether a Crypto Asset may be deemed a security under
U.S. federal securities laws “does not preclude legal or regulatory action based on the
presence of a security.” In future filings, please further revise to state that any such
assessment is not a legal standard or determination binding on any regulatory body or
court.
2.Please revise to disclose whether and how you expect that the initial and continuing
listing requirements applicable to the Trust may impact the weighting of the Trust’s
Portfolio Crypto Assets.

July 2, 2025
Page 2
Cover Page
3.To the extent you intend to "take advantage of incidental opportunities to generate
additional returns in excess of the Index" as discussed on page 1, please provide such
disclosure on the cover page.
Prospectus Summary
The Trust's Investment Objective and Strategies, page 1
4.We note that the "Sponsor has the discretion, when possible and prudent, to take
advantage of incidental opportunities to generate additional returns in excess of the
Index...through, for example, Airdrops, Staking, Emissions, Hard Forks, lending or
similar network events and activities." Please revise to describe:
•Whether any approvals are necessary for the Trust to engage in such activities;
•In greater detail the lending and "similar network events and activities" that the
Sponsor may take advantage of;
•The criteria, if any, the Sponsor will use to exercise such discretion; and
•How and when investors will be informed as to when the Sponsor exercises such
discretion and the identity of the related Portfolio Crypto Asset.
The Index, page 3
5.We note that you incorporate by reference the description of the Index Methodology
provided in the Trust Annual Report. In future Exchange Act reports, to the extent
incorporated by reference, please address the following in your disclosure regarding
the Index Methodology:
•Include a table with market share and volume information for each Crypto Asset
exchange selected by the Sponsor and its affiliates to calculate the value of Crypto
Assets in the Index;
•Explain how the Crypto Asset exchanges are selected;
•Include a brief description of each of the Crypto Asset exchanges, including
where they are located and how they are licensed or regulated; and
•Revise to describe the adjustments that may be made to the Index and the impact
that such adjustments could have on the NAV of the Trust.
Calculation of NAV, page 4
6.We note your cross-reference to “Part I—Item 1. Business—Calculation of NAV” in
the Trust Annual Report. Please revise this cross-reference to refer to the correct
section of the Trust Annual Report.
The Trust's Legal Structure, page 4
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. In this regard, we
note your disclosure on page 59 that "except as required under applicable federal law
or under the rules or regulations of an Exchange, Shareholders do not have any voting 7.

July 2, 2025
Page 3
rights, take no part in the management or control, and have no voice in, the Trust's
operations or business."
The Trust's Fees and Expenses, page 6
8.Please revise to clarify whether the Sponsor will assume the fees of the Trading
Counterparties in connection with the purchase and sale of Portfolio Crypto Assets
under the Trust-Directed Trading Model.
9.Please reconcile your usage of the term “Sponsor Fee” with the term “Management
Fee.”
10.We note your disclosure that the “Trust is not responsible for paying any fees or costs
associated with the transfer of Crypto Assets or cash to the Sponsor,” and it is unclear
whether these fees and costs are paid by the Sponsor. Please revise to clarify when the
Trust is responsible for paying blockchain fees.
The Trust's Investment Program
Purchase and Sale of Crypto Assets
Trust-Directed Trade Model, page 29
11.We note your disclosure that transfer fees with respect to on-chain transfers to and
from the Custodial Account to the Trading Counterparty will be paid by the
Custodian. We also note your statement on page 32 that the Sponsor will direct the
Custodian to transfer Portfolio Crypto Assets from the Custodial Account to pay Trust
expenses not assumed by the Sponsor. Please revise to clarify whether the Custodian
will pay such transfer fees using the Trust's assets.
12.We note your disclosure that "[t]here is no contractual relationship between the Trust,
the Sponsor or the Trading Counterparties and all transactions will be done on an
arms-length basis." However, we also note your disclosure on page 3 that
"[t]he Sponsor has entered into contractual agreements with the Trading
Counterparties, and these agreements set forth the general parameters under which
transactions in Portfolio Crypto Assets will be effectuated, should any transaction
with a Trading Counterparty occur." Please revise your disclosure as appropriate to
reconcile this discrepancy. In addition, to the extent that the Sponsor has entered into
contractual arrangements with Trading Counterparties, please disclose the material
terms of the agreements, including the term, termination and indemnification
provisions, as applicable.
Custody of the Trust's Assets, page 33
13.You disclose that the Custodian will keep a "substantial portion" of the private keys
associated with the Trust's Portfolio Crypto Assets in cold storage or "similarly secure
technology.” Please revise to disclose the percentage of the Portfolio Crypto Assets
that is held in cold storage and describe the "similarly secure technology" used to hold
the private keys.
14.Please define the term “Hot Storage Account.”

July 2, 2025
Page 4
The Prime Execution Agent and the Trade Credit Lender
The Trade Credit Lender, page 40
15.Please disclose the interest rate of Trade Credits. Please also disclose the maximum
“Authorized Amount” of Trade Credits available to the Trust.
Creations and Redemptions of Shares, page 43
16.Please revise to include the following disclosures:
•For creations, please 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 Portfolio Crypto Assets acquired.
•For creation and redemption transactions, disclose whether the interest payable on
Trade Credits utilized under the Trade Financing Agreement are included in the
execution price and therefore the responsibility of the Authorized Participants.
•Please discuss the mechanics of the redemption procedures, including how and
when cash and the Shares are transferred under the Trust-Directed Trade Model
and the Agent Execution Model.
•Clarify whether any costs or transaction fees associated with creations and
redemptions are payable by the Trust.
Suspension or Rejection of Redemption Orders, page 45
17.Please revise to disclose whether and how you will notify Shareholders if the Trust
has suspended creations and redemptions, and describe the potential impact of
suspending creations and redemptions.
Use of Proceeds, page 46
18.To the extent applicable, please revise your disclosure to address how you will use the
proceeds received by the Trust from incidental opportunities to generate additional
returns through, "for example, Airdrops, Staking, Emissions, Hard Forks, lending or
similar network events and activities."
Conflicts of Interest, page 47
19.Please revise this section to address any potential conflicts of interest between the
Trust and Authorized Participants on the one hand, and the Prime Execution Agent,
the Trade Credit Lender and the Trading Counterparties, on the other hand, as
applicable.
Material Contracts, page 51
20.Please revise to disclose the material terms of any agreement you have with the
Sponsor, Prime Execution Agent and Trade Credit Lender, including the term,
termination and indemnification provisions thereof, as applicable. Please also file the
agreements as exhibits to the registration statement.

July 2, 2025
Page 5
Taxation of the Trust, page 53
21.Please reconcile the disclosure that “[a]ssuming that the Trust is currently a grantor
trust for U.S. federal income tax purposes” with the remainder of the discussion in this
section.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Lulu Cheng at 202-551-3811 or Irene Paik at 202-551-6553 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets
cc:James Audette, Esq.

United States securities and exchange commission logo
October 2, 2023
Paul Fusaro
Chief Operating Officer
Bitwise 10 Crypto Index Fund
400 Montgomery Street
Suite 600
San Francisco, CA 94104
Re:Bitwise 10 Crypto Index Fund
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed February 24, 2023
File No. 000-56270
Dear Paul Fusaro:
            We have completed our review of your filing. We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets

CORRESP
1
filename1.htm

CORRESP

 Bitwise 10 Crypto Index Fund

400 Montgomery Street

Suite 600

 San Francisco,
CA 94104

 September 18, 2023

 Via EDGAR

 U.S. Securities and Exchange Commission

Division of Corporation Finance

 Office of Crypto Assets

100 F. Street, N.E.

 Washington, D.C. 20549

Attention:

Rolf Sundwall

David Irving

          Re:

Bitwise 10 Crypto Index Fund

Form 10-K for the Fiscal Year Ended December 31, 2022

Filed February 24, 2023

File No. 000-56270

 Dear Mr. Sundwall and Mr. Irving:

Bitwise 10 Crypto Index Fund (the “Company”) hereby acknowledges receipt of the comment letter dated September 6, 2023
(the “Comment Letter”) from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) concerning the above-captioned Annual Report on Form
10-K for the fiscal year ended December 31, 2022 filed February 24, 2023 (the “Annual Report”). The Company hereby submits this letter in response to the Comment Letter.

For the convenience of the Staff, each comment from the Comment Letter corresponds to the numbered paragraph in the Comment Letter and is
restated in italics prior to the response to such comment.

 Form 10-K for the Fiscal Year Ended
December 31, 2022

 Item 9A. Controls and Procedures

Managements Report on Internal Control Over Financial Reporting, page 106

1.
 You state that you have not included the Management’s Report on Internal Control over Financial
Reporting due to a transition period established by the rules of the SEC for newly public companies. The instructions to Regulation S-K, Item 308, permit the omission until you have filed an annual report in
the prior fiscal year. You filed an annual report for your fiscal year ended December 31, 2021. Please amend your Form 10-K for the fiscal year ended December 31, 2022 to include your
Management’s Report on Internal Control over Financial Reporting, or advise us otherwise.

 The Company acknowledges the Staff’s comment and respectfully advises the Staff that
management of Bitwise Investment Advisers, LLC, the Company’s sponsor (the “Sponsor”), performed the assessment of internal control over financial reporting at December 31, 2022 and inadvertently excluded disclosures
related to that assessment from its Annual Report.

 The Company is filing an amendment to the Annual Report (the
“Form 10-K/A”) to include an amendment and restatement of the disclosure in Item 9A of the Annual Report relating to management’s assessment of internal control over
financial reporting at December 31, 2022.

 Exhibits

2.
 You have omitted the language in paragraph 4 and 4(b) referring to internal control over financial
reporting in your certifications of principal officers pursuant to Rule 13a-14(a) and 15d-14(a) under the Securities Exchange Act of 1934 in Exhibits 31.1 and 31.2 of
your Form 10-K for the Fiscal Year Ended December 31, 2022 and Forms 10-Q for the quarterly periods ended March 31, 2023 and June 30, 2023. Please amend
your filings to include the certifications exactly as set forth in Regulation S-K, Item 601(b)(31)(i), or advise us otherwise. Refer to question 246.13 of the Compliance and Disclosure Interpretations for
Regulation S-K, updated August 25, 2023.

 The Company acknowledges
the Staff’s comment and respectfully advises the Staff that the Principal Executive Officer and Principal Financial and Accounting Officer of the Sponsor inadvertently omitted the language in paragraph 4 and 4(b) referring to internal control
over financial reporting in their certifications pursuant to Rule 13a-14(a) and 15d-14(a) under the Securities Exchange Act of 1934 in Exhibits 31.1 and 31.2 of the
Annual Report, the Form 10-Q for the quarterly period ended March 31, 2023, filed with the Commission on May 15, 2023, and the Form 10-Q for the quarterly
period ended June 30, 2023, filed with the Commission on August 4, 2023 (the “Form 10-Qs”).

The Company is filing the Form 10-K/A and amendments to its Form
10-Qs to refile Exhibits 31.1 and 31.2 to the Annual Report and the Form 10-Qs to include the inadvertently omitted language in paragraph 4 and 4(b) referring to
internal control over financial reporting.

 2

 We appreciate the Staff’s comments and request the Staff contact the undersigned at
(415) 789-6952 or teddy@bitwiseinvestments.com with any questions or comments regarding this letter.

Very truly yours,

/s/ Paul Fusaro

Paul Fusaro

 Chief Operating Officer of Bitwise

 Investment
Advisers, LLC, the Sponsor of

 Bitwise 10 Crypto Index Fund

 3

United States securities and exchange commission logo
September 6, 2023
Paul Fusaro
Chief Operating Officer
Bitwise 10 Crypto Index Fund
400 Montgomery Street
Suite 600
San Francisco, CA 94104
Re:Bitwise 10 Crypto Index Fund
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed February 24, 2023
File No. 000-56270
Dear Paul Fusaro:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2022
Item 9A. Controls and Procedures
Managements Report on Internal Control Over Financial Reporting, page 106
1.You state that you have not included the Management's Report on Internal Control over
Financial Reporting due to a transition period established by the rules of the SEC for
newly public companies.  The instructions to Regulation S-K, Item 308, permit the
omission until you have filed an annual report in the prior fiscal year.  You filed an annual
report for your fiscal year ended December 31,2021.  Please amend your Form 10-K for
the fiscal year ended December 31, 2022 to include your Management's Report on Internal
Control over Financial Reporting, or advise us otherwise.

 FirstName LastNamePaul Fusaro
 Comapany NameBitwise 10 Crypto Index Fund
 September 6, 2023 Page 2
 FirstName LastName
Paul Fusaro
Bitwise 10 Crypto Index Fund
September 6, 2023
Page 2
Exhibits
2.You have omitted the language in paragraph 4 and 4(b) referring to internal control over
financial reporting in your certifications of principal officers pursuant to Rule 13a-14(a)
and 15d-14(a) under the Securities Exchange Act of 1934 in Exhibits 31.1 and 31.2 of
your Form 10-K for the Fiscal Year Ended December 31, 2022 and Forms 10-Q for the
quarterly periods ended March 31, 2023 and June 30, 2023.  Please amend your filings to
include the certifications exactly as set forth in Regulation S-K, Item 601(b)(31)(i), or
advise us otherwise.  Refer to question 246.13 of the Compliance and Disclosure
Interpretations for Regulation S-K, updated August 25, 2023.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Rolf Sundwall at 202-551-3105 or David Irving at 202-551-3321 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets

United States securities and exchange commission logo
June 17, 2022
Hunter Horsley
President
Bitwise 10 Crypto Index Fund
400 Montgomery Street, Suite 600
San Francisco, CA 94111
Re:Bitwise 10 Crypto Index Fund
Registration Statement on Form 10
Filed April 23, 2021
File No. 000-56270
Dear Mr. Horsley:
            We have completed our review of your filing.  We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Finance

CORRESP
1
filename1.htm

CORRESP

 Wilson Sonsini Goodrich & Rosati

Professional Corporation

1700 K Street NW

Fifth Floor

Washington, D.C. 20006-3817

O: 202.973.8800

F: 202.973.8899

 May 23, 2022

Via EDGAR

 U.S. Securities and Exchange
Commission

 Division of Corporation Finance

 Office of
Finance

 100 F. Street, N.E.

 Washington, D.C. 20549

Attention:
 Justin Dobbie

Sonia Bednarowski

 William
Schroeder

 John Spitz

Re:
 Bitwise 10 Crypto Index Fund

Amendment No. 6

Registration Statement on Form 10

Filed April 21, 2022

File No. 000-56270

Ladies and Gentlemen:

 On behalf of our client,
Bitwise 10 Crypto Index Fund (“Bitwise” or the “Company”), we submit this letter in response to a comment from the staff (the “Staff”) of the Securities and Exchange Commission contained in its
letter dated May 17, 2022, relating to the above-referenced Registration Statement on Form 10 (the “Form 10”).

 In
this letter, we have recited the comment from the Staff in italicized, bold type and have followed the comment with the Company’s response.

Amendment No. 6 to Registration Statement on Form 10

General

1.
 Refer to your responses to comments 22 and 24 of our letter dated May 24, 2021 and subsequent
related comments. While we do not have any further comments at this time regarding your responses, please confirm your understanding that our decision not to issue additional comments should not be interpreted to mean that we either agree or
disagree with your responses, including any conclusions you have made, positions you have taken and practices you have engaged in with respect to these matters.

AUSTIN    BEIJING    BOSTON    BOULDER    BRUSSELS
  HONG KONG    LONDON    LOS ANGELES    NEW YORK    PALO ALTO

SALT LAKE CITY    SAN DIEGO    SAN
FRANCISCO    SEATTLE    SHANGHAI    WASHINGTON, DC    WILMINGTON, DE

 Securities and Exchange Commission

May 23, 2022

 Page 2

 In response to the Staff’s comment, the Company acknowledges that the Staff’s
decision not to issue additional comments should not be interpreted to mean that the Staff either agrees or disagrees with the Company’s responses, including any of the Company’s conclusions made, positions taken, or practices engaged in
with respect to these matters.

 Securities and Exchange Commission

May 23, 2022

 Page 3

 Please direct any questions regarding the Company’s response to me at (202) 973-8808 or rrosenblum@wsgr.com.

Very truly yours,

WILSON SONSINI GOODRICH & ROSATI

Professional Corporation

/s/ Robert H. Rosenblum

Robert H. Rosenblum

United States securities and exchange commission logo
May 17, 2022
Hunter Horsley
President
Bitwise 10 Crypto Index Fund
400 Montgomery Street, Suite 600
San Francisco, CA 94111
Re:Bitwise 10 Crypto Index Fund
Amendment No. 6 to
Registration Statement on Form 10
Filed April 21, 2022
File No. 000-56270
Dear Mr. Horsley:
            We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response and any amendment you may file in response to these
comments, we may have additional comments.
Amendment No. 6 to Registration Statement on Form 10
General
1.Refer to your responses to comments 22 and 24 of our letter dated May 24, 2021 and
subsequent related comments. While we do not have any further comments at this time
regarding your responses, please confirm your understanding that our decision not to issue
additional comments should not be interpreted to mean that we either agree or disagree
with your responses, including any conclusions you have made, positions you have taken
and practices you have engaged in with respect to these matters.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

 FirstName LastNameHunter  Horsley
 Comapany NameBitwise 10 Crypto Index Fund
 May 17, 2022 Page 2
 FirstName LastName
Hunter  Horsley
Bitwise 10 Crypto Index Fund
May 17, 2022
Page 2
            You may contact William Schroeder at 202-551-3294 or John Spitz at 202-551-3484 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Sonia Bednarowski at 202-551-3666 or Justin Dobbie at 202-551-3469 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Finance

CORRESP
1
filename1.htm

CORRESP

 Wilson Sonsini Goodrich & Rosati

Professional Corporation

1700 K Street NW

Fifth Floor

Washington, D.C. 20006-3817

O: 202.973.8800

F: 202.973.8899

 April 21, 2022

Via EDGAR

 U.S. Securities and Exchange
Commission

 Division of Corporation Finance

 Office of
Finance

 100 F. Street, N.E.

 Washington, D.C. 20549

Attention:
 Justin Dobbie

Sonia Bednarowski

 William
Schroeder

 John Spitz

Re:
 Bitwise 10 Crypto Index Fund

Amendment No. 5

Registration Statement on Form 10

Filed February 23, 2022

File No. 000-56270

Ladies and Gentlemen:

 On behalf of our client,
Bitwise 10 Crypto Index Fund (“Bitwise” or the “Company”), we submit this letter in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) contained in its letter dated April 7, 2022, relating to the above-referenced Registration Statement on Form 10 (the “Form 10”). We are concurrently publicly filing via EDGAR a revised draft of
the registration statement (the “Revised Registration Statement”).

 In this letter, we have recited the comments
from the staff in italicized, bold type and have followed each comment with the Company’s response. Except for page references appearing in the headings and Staff comments below (which are references to the Amended and Restated Registration
Statement submitted on February 23, 2022), all page references herein correspond to the Revised Registration Statement.

 Amendment No. 5 to
Registration Statement on Form 10

 Business

Activities of the Trust, page 5

AUSTIN    BEIJING    BOSTON    BRUSSELS    HONG
KONG    LONDON    LOS ANGELES    NEW YORK    PALO ALTO

 SAN
DIEGO    SAN FRANCISCO    SEATTLE    SHANGHAI    WASHINGTON, DC    WILMINGTON, DE

 Securities and Exchange Commission

April 21, 2022

 Page 2

1.
 Refer to your response to comment 2. Please describe the circumstances in which the Trust may determine
that staking activities are in the best interests of shareholders, and describe your current policies regarding staking activities. In this regard, we note your disclosure on page 16 that you consider whether or not the activity is supported by the
Trust’s custodian.

 In response to the Staff’s comment, the Company has updated the disclosure on
pages 6, 16 and 17 of the Revised Registration Statement to note that the Trust will determine whether staking activities are in the best interests of shareholders on a
case-by-case basis, and in making such a determination, consider whether the staking activities present possible and prudent opportunities to generate additional returns
for shareholders in excess of the Index, the risks associated with the staking activities, the potential for the loss of all or part of the staked amounts and whether or not the activity is supported by the Trust’s custodian.

Index, page 9

2.
 Refer to your response to comment 3. Please revise your disclosure in the Index section on page 9 to
clarify that you may have Exchange Act current or periodic reporting obligations due to other changes to the Index Methodology, such as to how the Index and Trust are calculated. In addition, we note your revised disclosure on page 9 that “[i]f
not required by applicable law, the Trust may or may not file a Form 8-K with the SEC to disclose changes to the Index Methodology that do not result in a material change.” Please disclose the factors the
Trust will consider in deciding whether or not to file a Form 8-K to disclose changes to the Index Methodology that do not result in a material change.

In response to the Staff’s comment, the Company has updated the disclosure on page 9 of the Revised Registration Statement to note that
the Trust may have current or periodic reporting obligations under the Exchange Act due to other changes to the Index Methodology, such as to how the Index is calculated. The Company has also disclosed the factors the Trust will consider when
deciding whether or not to file a Form 8-K to disclose changes to the Index Methodology that do not result in a material change.

 Securities and Exchange Commission

April 21, 2022

 Page 3

Please direct any questions regarding the Company’s responses or the Revised Registration Statement to me at (202)
973-8808 or rrosenblum@wsgr.com.

Very truly yours,

WILSON SONSINI GOODRICH & ROSATI

Professional Corporation

 /s/ Robert H. Rosenblum

Robert H. Rosenblum

United States securities and exchange commission logo
April 7, 2022
Hunter Horsley
President
Bitwise 10 Crypto Index Fund
400 Montgomery Street, Suite 600
San Francisco, CA 94111
Re:Bitwise 10 Crypto Index Fund
Amendment No. 5 to
Registration Statement on Form 10
Filed February 23, 2022
File No. 000-56270
Dear Mr. Horsley:
            We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response and any amendment you may file in response to these
comments, we may have additional comments.
Amendment No. 5 to Registration Statement on Form 10
Business
Activities of the Trust, page 5
1.Refer to your response to comment 2.  Please describe the circumstances in which the
Trust may determine that staking activities are in the best interests of shareholders, and
describe your current policies regarding staking activities.  In this regard, we note your
disclosure on page 16 that you consider whether or not the activity is supported by the
Trust's custodian.
Index, page 9
2.Refer to your response to comment 3.  Please revise your disclosure in the Index section
on page 9 to clarify that you may have Exchange Act current or periodic reporting

 FirstName LastNameHunter  Horsley
 Comapany NameBitwise 10 Crypto Index Fund
 April 7, 2022 Page 2
 FirstName LastName
Hunter  Horsley
Bitwise 10 Crypto Index Fund
April 7, 2022
Page 2
obligations due to other changes to the Index Methodology, such as to how the Index and
Trust are calculated.  In addition, we note your revised disclosure on page 9 that "[i]f not
required by applicable law, the Trust may or may not file a Form 8-K with the SEC to
disclose changes to the Index Methodology that do not result in a material change."
Please disclose the factors the Trust will consider in deciding whether or not to file a Form
8-K to disclose changes to the Index Methodology that do not result in a material change.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact William Schroeder at 202-551-3294 or John Spitz at 202-551-3484 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Sonia Bednarowski at 202-551-3666 or Justin Dobbie at 202-551-3469 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Finance

CORRESP
1
filename1.htm

CORRESP

 Wilson Sonsini Goodrich & Rosati

Professional Corporation

1700 K Street NW

 Fifth Floor

Washington, D.C. 20006-3817

O: 202.973.8800

 F:
202.973.8899

 February 23, 2022

Via EDGAR

 U.S. Securities and Exchange
Commission

 Division of Corporation Finance

 Office of
Finance

 100 F. Street, N.E.

 Washington, D.C. 20549

Attention:

William Schroeder

John Spitz

CC:

Justin Dobbie

Sonia Bednarowski

Stephanie Sullivan

 Re:

Bitwise 10 Crypto Index Fund

Letter dated February 17, 2022

 Dear Messrs. Schroeder and Spitz:

We are submitting this letter on behalf of our client, Bitwise 10 Crypto Index Fund (“Bitwise” or the
“Company”), to attach Exhibit A to the above-referenced letter, which was inadvertently omitted at the time of the filing of the letter via EDGAR.

Please direct any questions regarding the attachment to me at (202) 973-8808 or rrosenblum@wsgr.com.

Very truly yours,

WILSON SONSINI GOODRICH & ROSATI

Professional Corporation

 /s/ Robert H. Rosenblum

Robert H. Rosenblum

AUSTIN    BEIJING    BOSTON    BRUSSELS    HONG
KONG    LONDON    LOS ANGELES    NEW YORK    PALO ALTO

 SAN
DIEGO    SAN FRANCISCO    SEATTLE    SHANGHAI    WASHINGTON, DC    WILMINGTON, DE

 EXHIBIT A

SUMMARY OF BITWISE MATERIALITY ANALYSIS UNDER SEC STAFF

ACCOUNTING BULLETIN: NO. 99

A. Materiality Determination

As set forth in SEC Staff Accounting Bulletin: No. 99 (“SAB 99”), assessments of materiality by financial management
require both quantitative and qualitative analysis. Based on the guidance provided in SAB 99, management of Bitwise Investment Advisers, LLC (the “Sponsor”) determined that the error was neither quantitatively nor qualitatively
material.

 a. Quantitative Materiality

In the course of the Company’s review of FASB ASC Topic 820, management evaluated whether there was a material difference by conducting a
quantitative assessment. The results of this assessment established that the average difference in fair valuation prices for all measurement periods was less than one quarter of one percent for each asset. This assessment was disclosed in the
amended and restated registration statement on Form 10, filed August 13, 2021. Based on the results of the assessment, management concluded that the error was quantitatively immaterial.

b. Qualitative Materiality

Management has also concluded that the error was qualitatively immaterial. As described in SAB 99, the Staff of the Securities and Exchange
Commission clarified that materiality assessments require a full analysis of all relevant considerations in addition to a quantitative analysis. Based on the guidance in SAB 99, the management of the Sponsor considered the following qualitative
factors, both individually and in the aggregate, and in the light of the totality of the circumstances and full context of the facts:

•

 Whether the misstatement arose from an item capable of precise measurement or from an estimate, and, if so, the
degree of imprecision inherent in such estimate;

•

 Whether the misstatement masks a change in earnings or other trends;

•

 Whether the misstatement hides a failure to meet analysts’ consensus expectations for the enterprise;

•

 Whether the misstatement changes a loss into income or vice versa;

•

 Whether the misstatement concerns a segment or other portion of the registrant’s business that has been
identified as playing a significant role in the registrant’s operations or profitability;

•

 Whether the misstatement affects the registrant’s compliance with regulatory requirements;

•

 Whether the misstatement affects the registrant’s compliance with loan covenants or other contractual
requirements;

•

 Whether the misstatement has the effect of increasing the management’s compensation—for example, by
satisfying the requirements for the award of bonuses or other forms of incentive compensation;

•

 Whether the misstatement involves concealment of an unlawful transaction; and

•

 Other relevant factors, such as possible market reaction.

In light of these factors, the management of the Sponsor determined that the degree of imprecision in the estimate of fair value did not:

•

 Mask a change in earnings or other trends;

•

 Hide any failures to meet analyst consensus expectations;

•

 Change a loss into income or vice versa;

•

 Significantly affect a segment or portion of the Company’s business;

•

 Affect compliance with regulatory requirements;

•

 Affect compliance with loan covenants or other contractual requirements;

•

 Significantly affect the compensation of management of the Sponsor, including triggering the payment of bonuses
or other compensation; nor

•

 Involve concealment of unlawful transactions.

Considering all of the foregoing, management concluded that the error to be corrected would not be deemed important or significant by a
reasonable person. As such, the management determined that the error was also qualitatively immaterial.

 -2-

CORRESP
1
filename1.htm

CORRESP

 Wilson Sonsini Goodrich & Rosati
Professional Corporation

 1700 K Street NW
Fifth Floor
Washington, D.C. 20006-3817

 O: 202.973.8800
F: 202.973.8899

 February 17, 2022

Via EDGAR

 U.S. Securities and Exchange
Commission

 Division of Corporation Finance

 Office of
Finance

 100 F. Street, N.E.

 Washington, D.C. 20549

Attention:

William Schroeder

John Spitz

CC:

Justin Dobbie

Sonia Bednarowski

Stephanie Sullivan

Re:

Bitwise 10 Crypto Index Fund

Current Report on Form 8-K

Filed December 2, 2021

Amendment No. 1

Current Report on Form 8-K/A

Filed December 21, 2021

Amendment No. 3

Registration Statement on Form 10

Filed December 23, 2021

File No. 000-56270

 Dear Messrs. Schroeder and Spitz:

We are submitting this letter on behalf of our client, Bitwise 10 Crypto Index Fund (“Bitwise” or the
“Company”), (i) to describe changes the Company intends to make to Amendment No. 3 to Form 10 filed by the Company with the Securities and Exchange Commission (the “Commission”) on December 23, 2021
(“Amendment No. 3”), and (ii) to respond to comments from the staff (the “Staff”) of the Commission contained in its letter dated January 31, 2021, relating to Amendment No. 3.
The Company is concurrently publicly filing via EDGAR Amendment No. 4 to Form 10 (the “Amendment No. 4”) to reflect the changes discussed herein.

AUSTIN    BEIJING    BOSTON    BRUSSELS    HONG
KONG    LONDON    LOS ANGELES    NEW YORK    PALO ALTO

 SAN
DIEGO    SAN FRANCISCO    SEATTLE    SHANGHAI    WASHINGTON, DC    WILMINGTON, DE

 U.S. Securities and Exchange Commission

February 17, 2022

  Page
 2

 PART I

A.    Discussion of FASB ASC Topic 820

In a letter from the staff of the Commission (the “Staff”), dated August 2, 2021, the Staff raised a question as to
whether the appropriate valuation methodology for the Company’s investments should have been that specified in FASB ASC Topic 820 (“ASC 820”). In response to the Staff’s comment, the Company filed an amended registration
statement on Form 10, dated August 13, 2021 (“Amendment No. 2”), which included, among other things, an amendment to the text of Note 3 of the Company’s financial statements (“Note 3”).
This amended text was intended to address the Staff’s comment relating to ASC 820, and discussed why the Company’s valuation methodology, while not technically in line with ASC 820, yielded only immaterial deviations from the valuations
that would have been included in the financial statements under strict compliance with ASC 820.

 Subsequently, the management of Bitwise
Investment Advisers, LLC (the “Sponsor”) determined, after consultation with WithumSmith+Brown PC (“WSB”), the Company’s independent registered public accounting firm for the relevant time period, that the
changes to Note 3, while accurate, should not be relied upon because they had not been included in financial statements on which WSB had issued an audit opinion. On December 1, 2021, the Company and its counsel spoke with the Staff and advised
them of this issue, and advised the Staff of the proposed resolution of this issue and certain related considerations. In summary, the Company advised the Staff that it intended to:

(1) advise the public, through the issuance of a Form 8-K, that, even though the Company believed the
amended version of Note 3 was accurate, the public should not rely on the revised version of Note 3 included in Amendment No. 2, because it was not part of the original financial statements upon which WSB had issued an audit opinion;

(2) the Company would promptly file a new amended Form 10 that included financial statements on which WSB had issued an audit report, and that
those financial statements would include the revised version of Note 3 as it had appeared in the financial statements included in Amendment No. 2; this audit opinion would be “dual dated,” to include both the date of the audit report
of the financial statements included in the original Form 10 and the date that WSB issued the audit opinion with respect to the financial statements including the revised version of Note 3; and

 U.S. Securities and Exchange Commission

February 17, 2022

  Page
 3

 (3) the Company anticipated subsequently filing an additional amendment to the Form 10 that
included reissued financial statements in full compliance with ASC 820.

 On December 2, 2021, the Company filed a Current Report on
Form 8-K (the “Original 8-K”), in which it disclosed all three points the Company had identified to the Staff in the conversation held on
December 1, 2021.

 In a call involving the Staff, the Company, Company’s outside counsel, and WSB held on December 1, 2021
and in a letter dated December 9, 2021, the Staff raised several questions under Item 4.02 of Form 8-K relating to WSB’s role in the decision made by management of the Sponsor to determine that the
changes to Note 3 could not be relied upon. On December 21, 2021, the Company filed Amendment No. 1 to the Original 8-K (the “8-K/A
No. 1”). The 8-K/A No. 1 clarified that management of the Sponsor made the determination that the text of Note 3 as amended in Amendment No. 2 could not be relied upon and
that WSB was consulted during the deliberations by management of the Sponsor.

 On December 23, 2021, the Company filed Amendment
No. 3 to the Form 10, which included financial statements including the amended version of Note 3, and WSB’s dual-dated audit opinion covering those financial statements.

B.    Subsequent Discussion of FASB ASC Topics 250 and 275 and Other Matters

Following the filing of Amendment No. 3, the Staff requested a discussion with the Company and WSB to discuss the financial statements and
related matters in the audit opinion. On January 18, 2022, the Staff, the Company, Company’s outside counsel, and WSB held a call to discuss additional Staff concerns regarding the Company’s financial statements, the dual-dated audit
opinion, and the Company’s plans to file another amended Form 10 with re-issued financial statements. On the call, the Staff raised the following matters (among others) for the Company and WSB to
consider:

•

 Whether the changes to the financial statements based on ASC 820 constituted a correction of an error under FASB
ASC Topic 250 (“ASC 250”) and the impact of whatever determination the Company made under ASC 250;

•

 The appropriateness of the heading of Note 4 to the Company’s financial statements in Amendment No. 3
(“Note 4”) and certain disclosures in Note 4 (which includes a discussion of certain issues related to digital assets that the Company believes readers of the financial statements should consider), in light
of FASB ASC Topic 275 (“ASC 275”);

•

 Whether financial statements filed in the Company’s Forms 10-Q filed
on August 13, 2021 and November 10, 2021 (the “10-Qs”) would need to be restated to conform with the change of methodology in valuing digital assets, consistent with ASC 820; and

 U.S. Securities and Exchange Commission

February 17, 2022

  Page
 4

•

 The appropriateness of certain statements in the Emphasis of Matter section of WSB’s audit report related to
the financial statements in Amendment No. 3.

 On January 25, 2022, the Company, Company’s counsel and WSB
reconvened with the Staff to advise the Staff of the Company’s proposed plan to address the matters raised by the Staff on the call on January 18, 2022. In summary, the Company advised the Staff that:

(1) upon further examination of ASC 250, the Company had determined that: (i) the failure to technically comply with ASC 820 constituted
an error within the meaning of ASC 250, (ii) because the Company determined that the error was immaterial, as described in the Summary of Bitwise Materiality Analysis Under SEC Staff Accounting Bulletin: No. 99 attached hereto as Exhibit
A, ASC 250 required the Company to not file restated financial statements, but to instead issue an “out of period adjustment” explaining the error and the immaterial nature of the error; and (iii) the Company already has made that
out of period adjustment in the unaudited financial statements included in its Form 10-Q filed November 10, 2021;

(2) the Company would adjust the heading of Note 4 to conform to the language in ASC 275;

(3) the Company would revise Note 4 (with related changes to Notes 2 and 3) to reflect all of the Staff’s comments, including the
deletion of the paragraph titled “Control of Private Keys,” the deletion of the paragraph titled “Transactions in Cryptocurrencies May be Irreversible,” and the deletion of the statement that there is “currently no specific
authoritative accounting literature under accounting principles generally accepted in the United States of America (U.S. GAAP) which addresses the accounting for digital assets” under the heading “Financial Reporting” and comparable
statements in other sections of the Form 10, as applicable;

 (4) the Company would not restate the unaudited financial statements included
in the 10-Qs, but would include in future filings appropriate disclosure relating to any comparative financial information that includes valuation figures or information that did not comply with ASC 820;

(5) WSB would revise the emphasis of matter section of its audit opinion to reflect the Staff’s comments; and

(6) the Company and WSB would appropriately address all of these matters in Amendment No. 4.

 U.S. Securities and Exchange Commission

February 17, 2022

  Page
 5

 On January 26, 2022, the Staff requested this supplementary letter to provide
appropriate context for the changes the Company and WSB are making in Amendment No. 4.

 On February 10, 2022, the Company and
Company’s counsel reconvened with the Staff to discuss with the Staff the Company’s proposed plan to address matters raised by the Staff on the call on January 25, 2022. As a result of such conversation, the Company plans to make
additional clarifying changes, including updates to the tables showing investments in digital assets, at fair value, held by the Company as of the dates indicated, which are included in Note 3 of the financial statements. In addition to
Amendment No. 4, the Company is also concurrently publicly filing via EDGAR Amendment No. 2 to the Original 8-K (the “8-K/A
No. 2”) to reflect changes discussed with the Staff.

 PART II

In this Part II of this letter, we have recited in italicized, bold type the comments from the Staff’s letter to the Company dated
January 31, 2022, and have followed each comment with the Company’s response. Except for page references appearing in the headings and Staff comments below (which are references to Amendment No. 3), all page references herein
correspond to Amendment No. 4.

 Amendment No. 3 to Registration Statement on Form 10

General

1.
 Please note that we continue to evaluate your responses to comments 3 and 14 and may have additional
comments.

 The Company respectfully acknowledges that the Staff continues to evaluate responses to comments 3
and 14.

 Business

 Activities of the Trust, page 5

2.
 Your response to comment 4 suggests that the Trust will no longer engage in staking activities but your
disclosure on page 6 and throughout indicates that the Trust may engage in staking activities. Please revise to clarify whether the Trust will engage in staking activities. To the extent that the Trust will continue to do so, please tell us why you
believe that such activities are consistent with your disclosure that decisions related to engaging in staking the Trust’s digital assets are consistent with your disclosure that the Trust is managed as a passive investment vehicle.

 U.S. Securities and Exchange Commission

February 17, 2022

  Page
 6

 In response to the Staff’s comment, the Company has updated the disclosure on pages iii,
6, 8, 16, 20, 61 and 67 through 68 of Amendment No. 4 to clarify that while the Company currently does not engage in staking activities, it may engage in such activities in the future if the Company deems such activity to be in the best
interests of shareholders. The Sponsor believes that staking activities are consistent with the passive management of the Trust. Staking activities do not result in any new portfolio securities being purchased for the Trust, and do not result in any
existing portfolio securities being sold for the Trust.

 In addition, the Sponsor believes that the Company’s staking activities are
conceptually similar to securities lending activities. The Sponsor would not view an index fund that engages in securities lending activities to cease being a passively-managed index fund simply because it engages in such activities. The Sponsor
therefore believes that staking activities are consistent with the Company’s investment objective to passively invest in a portfolio that tracks an index (just as securities lending activities are consistent with the activities of an index
fund), and that the Sponsor’s ability to engage in staking activities on behalf of the Company – which is fully disclosed to investors, including in the Form 10 – is consistent with the Company’s disclosure that the Company is
managed as a passive investment vehicle.

 Index, page 9

3.
 Refer to your response to comment 5. Please revise to disclose why you believe that you will have
satisfied your Exchange Act reporting obligations in connection with notifying investors only of changes to the Index Methodology that result in 10% or more changes to the composition of the Index that also result in corresponding changes to the
Trust and not to other changes such as changes that impact how the Index is calculated.

 The Company
acknowledges the Staff’s comment, but respectfully notes that 10% is a generally accepted threshold for materiality. The Company believes that other changes that would not result in a 10% or more change to the composition of the Index, would be
immaterial to the Company’s investors and would not provide them with meaningful or relevant insights.

 In response to the
Staff’s comment, the Company has updated the disclosure on page 9 of Amendment No. 4 to clarify that if not required by applicable law, the Company may or may not file a Form 8-K with the SEC to
disclose changes to the Index Methodology that do not result in a material change.

 U.S. Securities and Exchange Commission

February 17, 2022

  Page
 7

 Eligibility of Cryptocurrencies, page 13

4.
 Refer to your response to comment 7. Please clarify what you mean by the Committee’s determination
that a digital asset does “not face undue risk of being in violation of U.S. federal securities laws” and whether the only matter the Committee considers in such determination is whether the digital asset may be deemed a security under
U.S. federal securities laws. Similarly, please disclose what you mean by the Sponsor’s determination regarding whether a Portfolio Crypto Asset “may be at increased risk of being in violation of U.S. federal securities laws” and
describe the Sponsor’s analyses to make such a determination.

 In response to the Staff’s comment, the
Company has updated the disclosure on pages 13, 15 and 76 of Amendment No. 4 to clarify that when the Bitwise Crypto Index Committee (the “Committee”) and the Sponsor make a determination as to whether a digital asset faces
undue risk of being in violation of U.S. federal securities laws, each of the Committee and Sponsor considers whether the digital asset may be deemed a security under U.S. federal securities laws and whether it is subject to regulatory action that
may imperil the value of the digital asset.

 Further, the Company notes that the analysis conducted in this regard by the Committee and
Sponsor often depends heavily on whether the Commission or a court has held or suggested that a specific digital asset may be a security as the Committee and Sponsor are limited in the amount of information that they can obtain about the various
factors identified by the Staff in the “F

United States securities and exchange commission logo
January 31, 2022
Hunter Horsley
President
Bitwise 10 Crypto Index Fund
300 Brannan Street, Suite 201
San Francisco, CA 94107
Re:Bitwise 10 Crypto Index Fund
Amendment No. 3 to
Registration Statement on Form 10
Filed December 23, 2021
File No. 000-56270
Dear Mr. Horsley:
            We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response and any amendment you may file in response to these
comments, we may have additional comments.
Amendment No. 3 to Registration Statement on Form 10
General
1.Please note that we continue to evaluate your responses to comments 3 and 14 and may
have additional comments.
Business
Activities of the Trust, page 5
2.Your response to comment 4 suggests that the Trust will no longer engage in staking
activities but your disclosure on page 6 and throughout indicates that the Trust may
engage in staking activities.  Please revise to clarify whether the Trust will engage in
staking activities. To the extent that the Trust will continue to do so, please tell us why
you believe that such activities are consistent with your disclosure that decisions related to

 FirstName LastNameHunter  Horsley
 Comapany NameBitwise 10 Crypto Index Fund
 January 31, 2022 Page 2
 FirstName LastName
Hunter  Horsley
Bitwise 10 Crypto Index Fund
January 31, 2022
Page 2
engaging in staking the Trust's digital assets are consistent with your disclosure that the
Trust is managed as a passive investment vehicle.
Index, page 9
3.Refer to your response to comment 5.  Please revise to disclose why you believe that you
will have satisfied your Exchange Act reporting obligations in connection with notifying
investors only of changes to the Index Methodology that result in 10% or more changes to
the composition of the Index that also result in corresponding changes to the Trust and not
to other changes such as changes that impact how the Index is calculated.
Eligibility of Cryptocurrencies, page 13
4.Refer to your response to comment 7.  Please clarify what you mean by the Committee's
determination that a digital asset does "not face undue risk of being in violation of U.S.
federal securities laws" and whether the only matter the Committee considers in such
determination is whether the digital asset may be deemed a security under U.S. federal
securities laws.   Similarly, please disclose what you mean by the Sponsor's determination
regarding whether a Portfolio Crypto Asset "may be at increased risk of being in violation
of U.S. federal securities laws" and describe the Sponsor's analyses to make such a
determination.
5.We note your response to comment 8 and we reissue.  You state on your website that the
Fund seeks to track an Index comprised of the 10 most highly valued cryptocurrencies,
screened and monitored for certain risks, weighted by market capitalization, and
rebalanced monthly. Given that the Index is made up of the top coins by market
capitalization, other than those that do not meet the screening criteria, please include a
table listing the digital assets included in the Index and the digital assets with larger
market capitalizations than Bitcoin Cash that are not included in the Index along with a
brief explanation for the reason they are not included in the Index.
Staking Activities, page 18
6.Refer to your response to comment 9.  Please revise to clarify, if true, that in addition to
posting information on your website regarding the Trust's inability to rebalance its
holdings in accordance with monthly rebalancing of the Index, there may be
circumstances in which you would also have Exchange Act current or periodic reporting
obligations.

 FirstName LastNameHunter  Horsley
 Comapany NameBitwise 10 Crypto Index Fund
 January 31, 2022 Page 3
 FirstName LastName
Hunter  Horsley
Bitwise 10 Crypto Index Fund
January 31, 2022
Page 3
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact William Schroeder at 202-551-3294 or John Spitz at 202-551-3484 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Sonia Bednarowski at 202-551-3666 or Justin Dobbie, Office Chief, at 202-551-3469
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance

CORRESP
1
filename1.htm

CORRESP

                 Wilson Sonsini Goodrich
& Rosati

                 Professional
Corporation

                1700 K Street NW

                Fifth Floor

                Washington, D.C. 20006-3817

                O: 202.973.8800

                F: 202.973.8899

December 23, 2021

 Via EDGAR

 U.S. Securities and Exchange Commission

Division of Corporation Finance

 Office of Finance

100 F. Street, N.E.

 Washington, D.C. 20549

Attention:      Justin Dobbie

Sonia Bednarowski

 William
Schroeder

 John Spitz

Re:    Bitwise 10 Crypto Index Fund

Amendment No. 2

Registration Statement on Form 10

Filed August 13, 2021

File No. 000-56270

Ladies and Gentlemen:

 On behalf of our client,
Bitwise 10 Crypto Index Fund (“Bitwise” or the “Company”), we submit this letter in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) contained in its letter dated November 12, 2021, relating to the above referenced Registration Statement on Form 10 (the “Form 10”). We are concurrently publicly filing via EDGAR a revised draft
of the registration statement (the “Revised Registration Statement”).

 In this letter, we have recited the
comments from the staff in italicized, bold type and have followed each comment with the Company’s response. Except for page references appearing in the headings and Staff comments below (which are references to the Amended and Restated
Registration Statement submitted on August 13, 2021), all page references herein correspond to the Revised Registration Statement.

AUSTIN        BEIJING        BOSTON
   BRUSSELS        HONG KONG        LONDON        LOS
ANGELES        NEW YORK            PALO ALTO

SAN DIEGO        SAN
FRANCISCO        SEATTLE        SHANGHAI        WASHINGTON, DC        WILMINGTON, DE

 Securities and Exchange Commission

December 23, 2021

 Page 2

 Amendment No. 2 to Registration Statement on Form 10

Glossary, page iv

1.
 We note your response and revisions made to your filing as a result of comment 7. Specifically, you have
revised your filing to define Portfolio Crypto Assets per share to mean NAV per share. However, based upon disclosure on page 84, NAV is calculated by summing the assets and liabilities whereas Portfolio Crypto Assets represent a portfolio of
cryptocurrencies as disclosed on page 1. Since it appears that NAV and Portfolio Crypto Assets and each of the corresponding per share measures are calculated differently, please revise your filing accordingly. To the extent you continue to present
Portfolio Crypto Assets per share, please revise your filing to clearly label this measure as non-GAAP and include all of the disclosures required by Regulation G and Item 10(e) of Regulation S-X.

 In response to the Staff’s comment, the Company has updated the
disclosure on pages v, 1-2, 64, 71-72 and 125 of the Revised Registration Statement to clarify the definitions of NAV and Portfolio Crypto Assets and to remove the term “Portfolio Crypto Assets per share.”

Business

 Activities of the Trust, page 5

2.
 Refer to your response to comment 5. Please clarify what you mean by “liquidity provisions” on
page 6, and clarify whether your reference to participation in decentralized finance protocols including governance, voting, staking assets, lending assets and liquidity provisions applies to a direct or indirect investment.

 In response to the Staff’s comment, the Company has updated the disclosure on pages 6 and 60 of the
Revised Registration Statement to remove the reference to liquidity provisions, as it is unnecessary and redundant and to clarify that to the extent that the Company engaged with decentralized finance protocols, it would only be with protocols where
the Company had made a direct investment into the protocol’s digital asset.

 Calculation of Valuation, page 6

3.
 We note your revised disclosures and response to comment 7 regarding your calculation of the NAV per
share, the NAV of the Trust, and the fair valuations for each Portfolio Crypto Asset, which were based on the use of the Bitwise Crypto Asset

 Securities and Exchange Commission

December 23, 2021

 Page 3

Price. We also note disclosure on pages 10-12 of how you determine the Bitwise Crypto Asset Price, which does not result in the identification of a principal market to
determine fair value pursuant to ASC 820-10-35-5 through 35-6C but rather a “blended
average” used to determine fair value. Therefore, despite your conclusion that use of the principal market determination of fair value in accordance with ASC 820 compared to your use of a Bitwise Crypto Asset Price was not materially different
for any period presented, we believe all measures based upon the Bitwise Crypto Asset Price should be labeled as a non-GAAP measure. Please revise all references in your filing accordingly.

 In response to the Staff’s comment, the Company has updated the disclosure on pages 6, 7, 10-12, and 101-103
of the Revised Registration Statement. The Company respectfully advises the Staff that there the Revised Registration Statement contains descriptions of three different methods used to calculate crypto asset prices, and has adjusted the defined
terms accordingly.

 The Blended Bitwise Crypto Asset Price refers to the crypto asset price that was calculated by the Trust using the
“blended average” method. This method is no longer in use by the Trust and any references to the Blended Bitwise Crypto Asset Price are solely for historical context. The Trust now uses the Principal Market Bitwise Crypto Asset Price,
which is calculated in accordance with ASC 820-10 and utilizes a principal market.

 The Index also
calculates a crypto asset price, which is defined in the Revised Registration Statement as the Index Crypto Asset Price or Index CAP. This price is calculated using a “blended average” method, however, only the Index utilizes this price
and it is not utilized by the Trust or the Sponsor.

 Investment Strategy, page 8

4.
 Refer to your response to comment 8. We note your disclosure on page 8 that you do not consider taking
advantage of incidental opportunities to generate additional returns in excess of the Index that arise from the Portfolio Crypt Assets held by the Trust to be inconsistent with your disclosure that the Trust is managed as a passive investment
vehicle. Please tell us why you believe that such activities, specifically decisions related to engaging in staking the Trust’s digital assets, are consistent with your disclosure that the Trust is managed as a passive investment vehicle.

 In response to the Staff’s comment, the Company has updated the disclosure on pages 1, 5, 8 and 84 of the
Revised Registration Statement to remove the reference to staking, as the Company does not consider staking to be in the same category of activity as airdrops, emissions or forks. The Sponsor respectfully notes that it believes that its decision to
generate additional returns for its investors by taking advantage of incidental opportunities, such as airdrops, emissions, forks, or similar network events, are consistent with the Trust’s management as a passive investment vehicle. The
receipt of additional digital assets through such opportunities arise naturally as a consequence of the Trust holding the Portfolio Crypto Assets and do not require any actions or decisions by the Trust. The Trust believes its decision to utilize
the received digital assets in such a way as to generate additional returns to investors is consistent with being managed as a passive investment vehicle.

 Securities and Exchange Commission

December 23, 2021

 Page 4

 Index, page 9

5.
 Refer to your responses to comments 9 and 26. Please tell us why you believe that you will have satisfied
your Exchange Act reporting obligations in connection with notifying investors of material changes in the Index Methodology by disclosing only those changes that result in 10% or more changes to the composition of the Index that also result in a
corresponding change to the Trust. For example, we note your disclosure on page 62 that “[t]he Index could be calculated now or in the future in a way that adversely affects an investment in the Trust.” In addition, we note your disclosure
on page 1 that halting Share subscriptions could cause the Shares to trade at a substantial premium over or a substantial discount to the value of the Trust’s Portfolio Crypto Assets per Share. Please tell us why you believe that you will have
satisfied your Exchange Act reporting obligations by announcing a decision to halt subscriptions on your website.

In response to the Staff’s comment, the Company has updated the disclosure on page 90 of the Revised Registration Statement to note that
a decision by the Trust to halt subscriptions will be disclosed on a Form 8-K. The Company acknowledges the Staff’s comment with respect to the materiality threshold for changes to the composition of the
Index, but respectfully notes that 10% is a generally-accepted threshold for materiality. In addition, the Company respectfully notes that the SEC has provided guidance indicating that public communication of information by use of a company’s
corporate website is a valid method of disclosing information to the public. The Company respectfully notes that the current composition of the Trust’s portfolio is always available on its website, and as a result, Investors would expect that
any information related to the rebalancing of the portfolio would be available in the same location.

 Composite Price Determination, page 10

 Securities and Exchange Commission

December 23, 2021

 Page 5

6.
 Refer to your response to comment 11. Please revise your disclosure in Section 3.a.iv on page 11 to
clarify how you convert the crypto-to-crypto price into a U.S. dollar equivalent for a trading pair that is not denominated in Quote Crypto Assets.

 In response to the Staff’s comment, the Company has updated the disclosure on pages 11-12 of the Revised
Registration Statement to clarify how crypto-to-crypto prices are converted for trading pairs that are not denominated in Quote Crypto Assets.

Eligibility of Cryptocurrencies, page 12

7.
 Refer to your response to comment 12. We note your risk factor that “[a] determination that any of
the Portfolio Crypto Assets are a ‘security’ may adversely affect the value of the Portfolio Crypto Assets and the value of the Shares, and result in potentially extraordinary, nonrecurring expenses to, or termination of, the Trust.”
Please disclose whether or not the Sponsor or Committee screens digital assets for undue risk of being deemed a security and, if so, disclose your policies regarding a digital asset holding that is determined to be at risk of being deemed a
security. In this regard, please also explain your revised disclosure that the Committee screens digital assets to determine whether or not a digital asset faces undue risk of “being in violation of U.S. federal securities laws.”

 In response to the Staff’s comment, the Company has updated the disclosure on pages 13-14 and 75 of the
Revised Registration Statement to clarify that the Committee does not engage in legal analysis of any digital assets or perform any analysis of digital assets based upon any legal standards. The Company has also clarified that while the Committee
does perform a risk-based assessment of limited, publicly available materials to determine whether there is any public evidence that would indicate that a digital asset may face undue risk of being deemed to be in violation of U.S. federal
securities laws, such analysis is not a legal analysis and does not preclude legal or regulatory action based on the presence of a security.

8.
 We note that Polygon, currently the 21st largest digital asset by market capitalization according to
CoinMarketCap.com, appears to be the digital asset with the smallest market capitalization held by the Trust. We also note that you currently identify the coins in the top 10 by market capitalization that are not held by the Trust. Please include a
table identifying all of the digital assets with larger market capitalizations than Polygon along with a brief explanation for the reason they are not included in the Index.

In response to the Staff’s comment, the Company has updated the disclosure on page 14 of the Revised Registration Statement. The Company
respectfully acknowledges the Staff’s comment, but is of the opinion that it is not necessary to provide investors with the specific

 Securities and Exchange Commission

December 23, 2021

 Page 6

 details of why the Committee chose to include or exclude from the Index every single
digital asset that is included in a specific market capitalization list provided by CoinMarketCap.com. The Committee performs an independent evaluation of all digital assets it believes should be evaluated for inclusion in the Index, based upon
criteria as described in the Revised Registration Statement, and such evaluation is not tied to or influenced by CoinMarketCap.com. The list of the seven coins that the Committee chose to exclude from the Index was presented as an example of the
types of reasons that might result in a digital asset’s exclusion, not to provide specific guidance regarding the Committee’s views on an exhaustive list of digital assets.

Departures from the Index, page 16

9.
 Refer to your response to comment 15. Please disclose when and how you will communicate to investors if
your staking activities prevent you from being able to rebalance the Trust in accordance with the rebalancing of the Index.

In response to the Staff’s comment, the Company has updated the disclosure on page 17, 18 and 62 of the Revised Registration Statement to
clarify that if the Trust was unable to rebalance its holdings in accordance with the monthly rebalancing of the Index, the Trust would include this information on its website, as the current Portfolio and any relevant information regarding the
Portfolio is always provided on the Trust’s website.

 Risks Related to Potential Conflicts of Interest, page 69

10.
 Refer to your response to comment 21. Please add a separate risk factor that specifically addresses the
relationships between the Sponsor and the Index Provider and the associated risk of conflicts of interests related to using an Index Provider that is affiliated with the Sponsor as well as the potential conflicts related to the composition of the
Bitwise Crypto Index Committee.

 In response to the Staff’s comment, the Company has updated the disclosure
on page 71 of the Revised Registration Statement.

 Financial Information

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Net Realized Loss from Digital Assets, page 85

11.
 We note the revisions made to your filing as a result of your response to comment 23 related to the
reason(s) for the realized losses related to fluctuations in the value of the Trust’s Portfolio of Crypto Assets for the three months ended March 31, 2021 and 2020. Please also revise your MD&A on page 87 to provide similar disclosures
for your fiscal years ended December 31, 2020 and 2019.

 Securities and Exchange Commission

December 23, 2021

 Page 7

 In response to the Staff’s comment, the Company has updated the
disclosure on pages 87 and 88 of the Revised Registration Statement.

 Management Fee, page 87

12.
 Refer to your response to comment 25. Please clarify what you mean by workout expenses on page 88.

 In response to the Staff’s comment, the Company has updated the disclosure on pages iv and 89 of the
Revised Registration Statement to replace the term “workout” with “financial distress,” as the Company believes the new term is more accurate.

The Custodian and the Custodial Services Agreement

Description of the Trust Company Custodial Services Agreement, page 114

13.
 Refer to your response to comment 31. Please revise to

United States securities and exchange commission logo
December 22, 2021
Hunter Horsely
Chief Executive Officer
Bitwise 10 Crypto Index Fund
400 Montgomery Street, Suite 600
San Francisco, CA 94111
Re:Bitwise 10 Crypto Index Fund
Form 8-K filed December 2, 2021
File No. 000-56270
Dear Mr. Horsely:
            We have completed our review of your filings.  We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Finance

CORRESP
1
filename1.htm

CORRESP

 Wilson Sonsini Goodrich & Rosati
Professional Corporation

 1700 K Street NW
Fifth Floor
Washington, D.C. 20006-3817

 O: 202.973.8800
F: 202.973.8899

 December 21, 2021

Via EDGAR

 U.S. Securities and Exchange
Commission

 Division of Corporation Finance

 Office of
Finance

 100 F. Street, N.E.

 Washington, D.C. 20549

Attention:

Justin Dobbie

Sonia Bednarowski

William Schroeder

John Spitz

Re:
 Bitwise 10 Crypto Index Fund

Form 8-K filed December 2, 2021

File No. 000-56270

Ladies and Gentlemen:

 On behalf of our client,
Bitwise 10 Crypto Index Fund (“Bitwise” or the “Company”), we submit this letter in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) contained in its letter dated December 7, 2021, relating to the above referenced Form 8-K (the “8-K”). The Company
is concurrently publicly filing via EDGAR Amendment No. 1 to the Form 8-K (the “Revised 8-K”).

In this letter, we have recited the comments from the staff in italicized, bold type and have followed each comment with the Company’s
response. Except for page references appearing in the headings and Staff comments below (which are references to the 8-K), all page references herein correspond to the Revised
8-K.

 Form 8-K filed December 2, 2021 Item 4.02, page 1

1.
 We note your disclosure that WithumSmith+Brown PC (“WSB”), advised the Sponsor that since the
amended text of Note 3 was added subsequently to the issuance of the opinion related to the Trust’s financial statements issued on April 22, 2021, the text of Note 3 as amended could not be relied upon as part of the existing opinion over
the audited financial statements. Please revise your filing to address the following:

AUSTIN    BEIJING    BOSTON    BRUSSELS    HONG
KONG    LONDON    LOS ANGELES    NEW YORK    PALO ALTO

 SAN
DIEGO     SAN FRANCISCO     SEATTLE     SHANGHAI     WASHINGTON, DC     WILMINGTON, DE

 Securities and Exchange Commission

December 21, 2021

  Page
 2

•

 Refer to Item 4.02(b) of Form 8-K and revise to provide all
required disclosures if you are advised by, or received notice from, your independent accountant that disclosure should be made or action should be taken to prevent future reliance on a previously issued audit report to previously issued financial
statements; and

•

 Revise to include an independent accountant’s letter as required by the Form 8-K instructions under Item 4.02(c)(3). Please also tell us whether you have completed all of the other steps specified by Item 4.02(c).

We acknowledge the Staff’s comment, and respectfully note that the Company filed the 8-K pursuant
to Item 4.02(a) of Form 8-K. The Company is filing the Revised 8-K to clarify that management of Bitwise Investment Advisers, LLC (the “Sponsor”) made
the determination that the text of Note 3 as amended in Form 10-12G on August 13, 2021 could not be relied upon. Management of the Sponsor discussed its decision with WSB during its deliberations, and no
notice or advisement under Item 4.02(b) of Form 8-K was received from WSB. The Company has confirmed with WSB that the determination was made pursuant to Item 4.02(a) of Form
8-K.

 Securities and Exchange Commission

December 21, 2021

  Page
 3

 Please direct any questions regarding the Company’s responses or the Revised 8-K to me at (202) 973-8808 or rrosenblum@wsgr.com.

Very truly yours,

WILSON SONSINI GOODRICH & ROSATI

Professional Corporation

 /s/ Robert H. Rosenblum

Robert H. Rosenblum

cc:
 Hunter Horsley, Bitwise 10 Crypto Index Fund

Amy B. Caiazza, Wilson Sonsini Goodrich & Rosati, P.C.

United States securities and exchange commission logo
December 7, 2021
Hunter Horsely
Chief Executive Officer
Bitwise 10 Crypto Index Fund
400 Montgomery Street, Suite 600
San Francisco, CA 94111
Re:Bitwise 10 Crypto Index Fund
Form 8-K filed December 2, 2021
File No. 000-56270
Dear Mr. Horsely:
            We have reviewed your filing and have the following comment. Please respond to
this comment within ten business days by providing the requested information or advise us as
soon as possible when you will respond.  If you do not believe our comment applies to your facts
and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 8-K filed December 2, 2021
Item 4.02, page 1
1.We note your disclosure that WithumSmith+Brown PC (“WSB”), advised the Sponsor
that since the amended text of Note 3 was added subsequently to the issuance of the
opinion related to the Trust’s financial statements issued on April 22, 2021, the text of
Note 3 as amended could not be relied upon as part of the existing opinion over the
audited financial statements. Please revise your filing to address the following:

•Refer to Item 4.02(b) of Form 8-K and revise to provide all of the required
disclosures if you are advised by, or received notice from, your independent
accountant that disclosure should be made or action should be taken to prevent future
reliance on a previously issued audit report to previously issued financial statements;
and
•Revise to include an independent accountant’s letter as required by the Form 8-K
instructions under Item 4.02(c)(3). Please also tell us whether you have completed all
of the other steps specified by Item 4.02 (c).
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of

 FirstName LastNameHunter  Horsely
 Comapany NameBitwise 10 Crypto Index Fund
 December 7, 2021 Page 2
 FirstName LastName
Hunter  Horsely
Bitwise 10 Crypto Index Fund
December 7, 2021
Page 2
action by the staff.
            You may contact William Schroeder at 202-551-3294 or John Spitz at 202-551-3484 if
you have questions regarding  these comments.
Sincerely,
Division of Corporation Finance
Office of Finance

United States securities and exchange commission logo
November 12, 2021
Hunter Horsley
President
Bitwise 10 Crypto Index Fund
300 Brannan Street, Suite 201
San Francisco, CA 94107
Re:Bitwise 10 Crypto Index Fund
Amendment No. 2 to
Registration Statement on Form 10
August 13, 2021
File No. 000-56270
Dear Mr. Horsley:
            We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response and any amendment you may file in response to these
comments, we may have additional comments.
Amendment No. 2 to Registration Statement on Form 10
Glossary, page iv
1.We note your response and revisions made to your filing as a result of comment 7.
Specifically, you have revised your filing to define Portfolio Crypto Assets per share to
mean NAV per share.  However, based upon disclosure on page 84, NAV is calculated by
summing the assets and liabilities whereas Portfolio Crypto Assets represent a portfolio of
cryptocurrencies as disclosed on page 1. Since it appears that NAV and Portfolio Crypto
Assets and each of the corresponding per share measures are calculated differently, please
revise your filing accordingly. To the extent you continue to present Portfolio Crypto
Assets per share, please revise your filing to clearly label this measure as non-GAAP and
include all of the disclosures required by Regulation G and Item 10(e) of Regulation S-X.

 FirstName LastNameHunter  Horsley
 Comapany NameBitwise 10 Crypto Index Fund
 November 12, 2021 Page 2
 FirstName LastNameHunter  Horsley
Bitwise 10 Crypto Index Fund
November 12, 2021
Page 2
Business
Activities of the Trust, page 5
2.Refer to your response to comment 5.  Please clarify what you mean by "liquidity
provisions" on page 6, and clarify whether your reference to participation in decentralized
finance protocols including governance, voting, staking assets, lending assets and liquidity
provisions applies to a direct or indirect investment.
Calculation of Valuation, page 6
3.We note your revised disclosures and response to comment 7 regarding your calculation
of the NAV per share, the NAV of the Trust, and the fair valuations for each Portfolio
Crypto Asset, which were based on the use of the Bitwise Crypto Asset Price. We also
note disclosure on pages 10-12 of how you determine the Bitwise Crypto Asset Price,
which does not result in the identification of a principal market to determine fair value
pursuant to ASC 820-10-35-5 through 35-6C but rather a “blended average” used to
determine fair value. Therefore, despite your conclusion that use of the principal market
determination of fair value in accordance with ASC 820 compared to your use of a
Bitwise Crypto Asset Price was not materially different for any period presented, we
believe all measures based upon the Bitwise Crypto Asset Price should be labeled as a
non-GAAP measure. Please revise all references in your filing accordingly.
Investment Strategy, page 8
4.Refer to your response to comment 8.  We note your disclosure on page 8 that you do not
consider taking advantage of incidental opportunities to generate additional returns in
excess of the Index that arise from the Portfolio Crypt Assets held by the Trust to be
inconsistent with your disclosure that the Trust is managed as a passive investment
vehicle.  Please tell us why you believe that such activities, specifically decisions related
to engaging in staking the Trust's digital assets, are consistent with your disclosure that the
Trust is managed as a passive investment vehicle.
Index, page 9
5.Refer to your responses to comments 9 and 26.  Please tell us why you believe that you
will have satisfied your Exchange Act reporting obligations in connection with notifying
investors of material changes in the Index Methodology by disclosing only those changes
that result in 10% or more changes to the composition of the Index that also result in a
corresponding change to the Trust.  For example, we note your disclosure on page 62 that
"[t]he Index could be calculated now or in the future in a way that adversely affects an
investment in the Trust."  In addition, we note your disclosure on page 1 that halting Share
subscriptions could cause the Shares to trade at a substantial premium over or a substantial
discount to the value of the Trust's Portfolio Crypto Assets per Share. Please tell us why
you believe that you will have satisfied your Exchange Act reporting obligations by
announcing a decision to halt subscriptions on your website.

 FirstName LastNameHunter  Horsley
 Comapany NameBitwise 10 Crypto Index Fund
 November 12, 2021 Page 3
 FirstName LastNameHunter  Horsley
Bitwise 10 Crypto Index Fund
November 12, 2021
Page 3
Composite Price Determination, page 10
6.Refer to your response to comment 11.  Please revise your disclosure in Section 3.a.iv on
page 11 to clarify how you convert the crypto-to-crypto price into a U.S. dollar equivalent
for a trading pair that is not denominated in Quote Crypto Assets.
Eligibility of Cryptocurrencies, page 12
7.Refer to your response to comment 12.  We note your risk factor that "[a] determination
that any of the Portfolio Crypto Assets are a 'security' may adversely affect the value of
the Portfolio Crypto Assets and the value of the Shares, and result in potentially
extraordinary, nonrecurring expenses to, or termination of, the Trust."  Please disclose
whether or not the Sponsor or Committee screens digital assets for undue risk of being
deemed a security and, if so, disclose your policies regarding a digital asset holding that is
determined to be at risk of being deemed a security.  In this regard, please also explain
your revised disclosure that the Committee screens digital assets to determine whether or
not a digital asset faces undue risk of "being in violation of U.S. federal securities laws."
8.We note that Polygon, currently the 21st largest digital asset by market capitalization
according to CoinMarketCap.com, appears to be the digital asset with the smallest market
capitalization held by the Trust.  We also note that you currently identify the coins in the
top 10 by market capitalization that are not held by the Trust.  Please include a table
identifying all of the digital assets with larger market capitalizations than Polygon along
with a brief explanation for the reason they are not included in the Index.
Departures from the Index, page 16
9.Refer to your response to comment 15.  Please disclose when and how you will
communicate to investors if your staking activities prevent you from being able to
rebalance the Trust in accordance with the rebalancing of the Index.
Risks Related to Potential Conflicts of Interest, page 69
10.Refer to your response to comment 21.  Please add a separate risk factor that specifically
addresses the relationships between the Sponsor and the Index Provider and the associated
risk of conflicts of interests related to using an Index Provider that is affiliated with the
Sponsor as well as the potential conflicts related to the composition of the Bitwise Crypto
Index Committee.
Financial Information
Management's Discussion and Analysis of Financial Condition and Results of Operations
Net Realized Loss from Digital Assets, page 85
11.We note the revisions made to your filing as a result of your response to comment 23
related to the reason(s) for the realized losses related to fluctuations in the value of the
Trust’s Portfolio of Crypto Assets for the three months ended March 31, 2021 and 2020.

 FirstName LastNameHunter  Horsley
 Comapany NameBitwise 10 Crypto Index Fund
 November 12, 2021 Page 4
 FirstName LastName
Hunter  Horsley
Bitwise 10 Crypto Index Fund
November 12, 2021
Page 4
Please also revise your MD&A on page 87 to provide similar disclosures for your fiscal
years ended December 31, 2020 and 2019.
Management Fee, page 87
12.Refer to your response to comment 25.  Please clarify what you mean by workout
expenses on page 88.
The Custodian and the Custodial Services Agreement
Description of the Trust Company Custodial Services Agreement, page 114
13.Refer to your response to comment 31. Please revise to describe the types of losses that
are covered by the commercial crimes insurance program held by Coinbase Global, Inc.
Report of the Independent Registered Accounting Firm, page F-19
14.We note the revisions to Note 3 Fair Value Measurements, beginning on page F-30 of
your audited financial statements as a result of comment 34.  Please tell us how your
Independent Registered Accounting Firm considered AS 3110 in determining whether to
dual date their audit report, or revise your filing accordingly.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact William Schroeder at 202-551-3294 or John Spitz at 202-551-3484 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Sonia Bednarowski at 202-551-3666 or Justin Dobbie at 202-551-3469 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Finance

CORRESP
1
filename1.htm

CORRESP

 Wilson Sonsini Goodrich & Rosati
Professional Corporation

 1700 K Street NW
Fifth Floor
Washington, D.C. 20006-3817

 O: 202.973.8800
F: 202.973.8899

 August 13, 2021

Via EDGAR

 U.S. Securities and Exchange
Commission

 Division of Corporation Finance

 Office of
Finance

 100 F. Street, N.E.

 Washington, D.C. 20549

Attention:
 Sonia Bednarowski

Justin Dobbie

 William Shcroeder

 John Spitz

Re:
 Bitwise 10 Crypto Index Fund

Amendment No. 1 to Registration Statement on Form 10

Filed July 1, 2021

File No. 000-56270

Ladies and Gentlemen:

 On behalf of our client,
Bitwise 10 Crypto Index Fund (“Bitwise” or the “Company”), we submit this letter in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) contained in its letter dated August 2, 2021, relating to the above referenced Registration Statement on Form 10 (the “Form 10”). We are concurrently publicly filing via EDGAR a revised draft of
the registration statement (the “Revised Registration Statement”).

 In this letter, we have recited the comments
from the staff in italicized, bold type and have followed each comment with the Company’s response. Except for page references appearing in the headings and Staff comments below (which are references to the Amendment No. 1 to Registration
Statement submitted on July 1, 2021), all page references herein correspond to the Revised Registration Statement.

 Amendment No. 1 to
Registration Statement on Form 10

 AUSTIN     BEIJING     BOSTON
    BRUSSELS     HONG KONG     LONDON     LOS ANGELES     NEW YORK     PALO ALTO

SAN DIEGO     SAN FRANCISCO     SEATTLE     SHANGHAI
    WASHINGTON, DC     WILMINGTON, DE

 Securities and Exchange Commission

August 13, 2021

  Page
 2

 Amendment No. 1 to Registration Statement on Form 10

Business, page 1

1. Refer to your response to comment 30. Your disclosure on page 1 that Bitwise Asset Management, LLC is the parent of the Sponsor
appears to be inconsistent with your disclosure on page 92 that Bitwise Management, Inc. is the parent of the Sponsor. Please revise for clarity and consistency. In addition, there are still references to “Bitwise” in which it is unclear
as to whether you are referring to the parent company of the Sponsor, the Sponsor or the Trust. For example, on page 23, you state that “Bitwise may be required to register as an investment adviser.” Please revise throughout for clarity.

 In response to the Staff’s comment, the Company has updated the disclosure on pages 1 and 108 of the Revised Registration
Statement, and the Company has clarified its references to “Bitwise” throughout the Revised Registration Statement.

 2. We
note your response to comment 3. Please revise the first sentence of the last paragraph on page 1 to clarify the distinction between tracking the holdings of the Index and an investor’s ability to achieve a return on investment that tracks the
performance of the Index.

 In response to the Staff’s comment, the Company has updated the disclosure on pages 1 and 2 of the
Revised Registration Statement.

 3. We note your disclosure on page 4 that “[t]he Trust seeks to make it easier for an investor
to invest in the cryptocurrency market as a whole, without having to pick specific tokens, manage a portfolio, or constantly monitor ongoing news and developments” and that “[a]lthough the Shares will not be the exact equivalent of a
direct investment in cryptocurrencies, they provide investors with an alternative that constitutes a relatively cost-effective, professionally managed way to participate in cryptocurrency markets.” Please discuss in your registration statement
the extent to which the Trust has been able to achieve the goal expressed on page 4 in light of the difference between the trading price of the Shares on the OTCQX as compared to the Trust’s net asset value per share.

In response to the Staff’s comment, the Company has updated the disclosure on pages 1 and 2 of the Revised Registration Statement.

 Securities and Exchange Commission

August 13, 2021

  Page
 3

 4. Refer to your response to comment 6. We note your disclosure on page 5 that you
purchase digital assets from approved counterparties, including exchanges, electronic trading systems that seek liquidity from multiple trading venues and OTC trading desks. Please include a discussion of counterparty risks in your risk factors
section, including risks related to counterparty exposure. In this regard, we note your disclosure on page 88.

 In response to the
Staff’s comment, the Company has updated the disclosure on page 51 of the Revised Registration Statement.

 5. Refer to your
response to comment 7. Please expand your summary of the material differences between an investment in your Shares and a direct investment of digital assets on page 4 to include (i) the holding period under Rule 144 for the resale of the Shares
purchased from the Trust, (ii) the risk that the Shares may trade at a substantial premium over or a substantial discount to the Trust’s Portfolio Crypto Assets per Share and (iii) the risk that over time the number of Portfolio
Crypto Assets represented by a Share will gradually decrease as the Portfolio Crypto Assets are used to pay the Trust’s expenses.

In response to the Staff’s comment, the Company has updated the disclosure on page 5 of the Revised Registration Statement.

6. Refer to your response to comment 29. Please revise to disclose here a detailed description of how the Sponsor calculates the NAV of
the Trust, the NAV per Share and the price per Share.

 In response to the Staff’s comment, the Company has updated the
disclosure on pages 6 and 7 of the Revised Registration Statement.

 7. We note multiple references to the “Trust’s
Portfolio Crypto Assets per share” on page 2 and elsewhere in your filing and your discussion of the “Bitwise Crypto Asset Price” on page 7. Please revise your filing to clearly define these measures and explain how management uses
them, and tell us whether you intend to present these measures in future filings. Additionally, please tell us how you considered whether these measures were Non-GAAP measures, and if so determined, revise to
include all of the disclosures required by Regulation G and Item 10(e) of Regulation S-X.

 Securities and Exchange Commission

August 13, 2021

  Page
 4

 In response to the Staff’s comment, the Company has updated the glossary and the
disclosure on pages 6 and 7 of the Revised Registration Statement. The Company notes that its response to the comment regarding how management has used the “Bitwise Crypto Asset Price” is contained in the discussion in response to Question
6. The Sponsor notes has revised the definition of “Portfolio Crypto Assets Per Share” to mean “Net Asset Value per Share.” The Sponsor respectfully notes that it believes that there was no material departure from U.S. GAAP
due to the immaterial nature of the differences in the Trust’s use of a blended average to determine fair value and the Trust’s proposed change in valuation policy to identify a principal market to determine fair value, described in
response to question 6, and that the results as presented were not materially different or significantly different from an approach that would have identified a principal market in each instance. The Company respectfully concludes that its
measures were consistent with U.S. GAAP and therefore neither the Company nor its auditors believe that these measures were Non-GAAP measures.

Investment Strategy , page 5

8. Refer to your response to comment 12. Your disclosure on pages 5 and 91 that “upon the occurrence of Network Distributions like
hard forks, airdrops, emissions, . . . staking, or other one-off events, the Trust will follow the policies of the Index” appears to be inconsistent with your disclosure on page 12 that “there may be
opportunities for the Trust to generate returns in excess of the Index through airdrops and proof of stake which the Sponsor will endeavor to do where possible and prudent.” Please revise for clarity and consistency, and please disclose how
generating returns in excess of the Index is consistent with your investment strategy, including your disclosure that you are a passive investment vehicle. In addition, we note your disclosure on page 11 that the Index does not calculate the value
of emissions, airdrops, or staking rewards but that the Sponsor may choose to periodically liquidate the emissions, airdrops and staking rewards to deliver excess returns to Shareholders. Please clarify if the Sponsor’s policies differ from the
Trust’s policies related to airdrops, emissions and staking only in the calculation of the value from such activities but not in regards to accepting and liquidating emissions, airdrops and staking rewards.

In response to the Staff’s comment, the Company has updated the disclosure on pages 7 and 8 of the Revised Registration Statement.

 Index, page 6

9. Refer to your response to comment 8. Your disclosure on page 6 that the components of the Index Methodology are subject to change in
the sole discretion of the Sponsor and your disclosure on page 7 that eligibility criteria developed by the Sponsor and its affiliates are applied to screen for investment feasibility in selecting the top ten largest

 Securities and Exchange Commission

August 13, 2021

  Page
 5

cryptocurrencies for the Index and that the “[p]ublic exchanges used for calculating the Index are selected using criteria chosen by the Sponsor in its sole discretion” appear to be
inconsistent with your disclosure on page 11 that the Bitwise Crypto Index Committee has total responsibility for developing, maintaining and adjusting the Bitwise Crypto Index Methodologies. Please revise for clarity and consistency regarding the
roles of the Bitwise Crypto Index Committee and the Sponsor. In addition, please disclose how you will satisfy your Exchange Act reporting obligations in connection with notifying investors of material changes in Index Methodology. In this regard,
we note your disclosure on page 9 that “[m]ethodological changes to the Index have historically been posted to a specific section on the Sponsor’s website.” Also, please revise the second and third complete risk factors on page 54
accordingly.

 In response to the Staff’s comment, the Company has updated the disclosure on pages 9, 13, 14, 15, 16, and
61 of the Revised Registration Statement.

 Price and Cost Slippage, page 6

10. Refer to your response to comment 11. We note your disclosure on page 6 that “there are a number of other factors aside from
price slippage that inform best practices in trade execution.” Please revise your disclosure to summarize the “other factors” that you consider in connection with purchases and sales of digital assets and the resulting “best
practices” used in trade execution.

 In response to the Staff’s comment, the Company has updated the disclosure on
page 8 of the Revised Registration Statement.

 Composite Price Determination, page 7

11. Refer to your response to comment 15. Please revise your disclosure in Section 3.a.iv on page 8 to clarify how you “[u]se
the synchronous CAP for the relevant Quote Crypto Assets to translate crypto-to-crypto pairs into a
crypto-to-U.S.-dollar equivalent.”

 In
response to the Staff’s comment, the Company has updated the disclosure on page 11 of the Revised Registration Statement.

 Securities and Exchange Commission

August 13, 2021

  Page
 6

 Eligibility of Cryptocurrencies, page 9

12. Refer to your responses to comments 22 and 24. Please disclose (i) whether the Index’s methodology differs from the
Trust’s methodology for determining whether a digital asset may be a security, (ii) how the Trust and Index determine whether or not a digital asset may be a security, and (iii) the policies of both the Trust and the Index if a
digital asset holding is deemed to be at risk of being a security. Please also emphasize here and in your risk factor disclosure, if accurate, that the legal test to determine whether an asset is a security is different from the analysis performed
by the Trust and the Index, which is not a legal standard and only a risk-based assessment that does not preclude legal or regulatory action based on the presence of a security.

In response to the Staff’s comment, the Company has updated the disclosure on pages 12 and 73 of the Revised Registration Statement.

 One-Off Events, page 10

13. We note your response to comment 20. Please revise the relevant sections of your filing to include your abandonment policies and
procedures related to each of these one-off events, as applicable.

 In response to the
Staff’s comment, the Company has updated the disclosure on page 15 of the Revised Registration Statement.

 14. Refer to
your response to comment 19. Please clarify here the factors that the Index and the Trust consider in connection with (i) accepting and selling airdrops of digital assets and (ii) engaging in staking activities. In addition, to the extent
that the Index and Trust have historically accepted and sold airdrops of digital assets or utilized emissions, please provide a brief summary of such activities. In addition, we note your disclosure regarding the staking activities of the Trust on
page 13. Please revise to clarify whether the Index participated in the Tezos staking activities in 2020.

 In response to the
Staff’s comment, the Company has updated the disclosure on pages 14 and 15 of the Revised Registration Statement. The Company notes that the section “One Off Events” discloses that the Index does not include staking
rewards.

 Securities and Exchange Commission

August 13, 2021

  Page
 7

 Departures from the Index, page 12

15. Refer to your response to comment 21. Please disclose the factors that the Sponsor considers in connection with a decision to hold
different digital assets from the Index. In addition, we note your disclosure on page 12 that such exceptions may not always be communicated in advance to Shareholders. Please disclose when and how such exceptions will be communicated to
Shareholders. Also, please disclose the “other assets” the Trust is permitted to hold.

 In response to the Staff’s
comment, the Company has updated the disclosure on page 16 of the Revised Registration Statement.

 Staking Activities, page 13

 16. Refer to your response to comment 13. Please disclose whether the Trust’s staking activities could affect its ability
to rebalance its holdings due to the monthly rebalancing of the Index, and address the risks associated with staking in your risk factor section. In this regard, we note your disclosure regarding risks associated with staking on page 13 of your
registration statement and your revised disclosure on page 53. Please also address the regulatory uncertainty regarding the status of staking activities under the U.S. federal securities laws in your risk factor disclosure.

In response to the Staff’s comment, the Company has updated the disclosure on pages 16, 59 and 60 of the Revised Registration Statement.

 Overview of Index Constituents, page 16

17. We note that you have updated your overview of Index Constituents and their corresponding weights as of March 31, 2021. Please
revise your filing to also include a detailed listing of the constituents in the index and their weights as of December 31, 2020 and 2019.

In response to the Staff’s comment, the Company has updated the disclosure on page 21 of the Revised Registration Statement.

 Securities and Exchange Commission

August 13, 2021

  Page
 8

 Risk Factors

Risks Related to Cryptocurrencies

Transactions in cryptocurrencies may be irreversible even if they are fraudulent, page 41

18. Your response to comment 28 that “[t]here are no circumstances in the normal course of business under which the Trust would
deliver digital assets to its shareholders” appears to be

United States securities and exchange commission logo
August 2, 2021
Hunter Horsley
President
Bitwise 10 Crypto Index Fund
300 Brannan Street, Suite 201
San Francisco, CA 94107
Re:Bitwise 10 Crypto Index Fund
Amendment No. 1 to Registration Statement on Form 10
July 1, 2021
File No. 000-56270
Dear Mr. Horsley:
            We have reviewed your amended filing and have the following comments.  In some of
our comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Amendment No. 1 to Registration Statement on Form 10
Business, page 1
1.Refer to your response to comment 30.  Your disclosure on page 1 that Bitwise Asset
Management, LLC is the parent of the Sponsor appears to be inconsistent with your
disclosure on page 92 that Bitwise Management, Inc. is the parent of the Sponsor.  Please
revise for clarity and consistency.  In addition, there are still references to "Bitwise" in
which it is unclear as to whether you are referring to the parent company of the the
Sponsor, the Sponsor or the Trust.  For example, on page 23, you state that "Bitwise may
be required to register as an investment adviser."  Please revise throughout for clarity.
2.We note your response to comment 3.  Please revise the first sentence of the last
paragraph on page 1 to clarify the distinction between tracking the holdings of the Index
and an investor's ability to achieve a return on investment that tracks the performance of
the Index.

 FirstName LastNameHunter  Horsley
 Comapany NameBitwise 10 Crypto Index Fund
 August 2, 2021 Page 2
 FirstName LastNameHunter  Horsley
Bitwise 10 Crypto Index Fund
August 2, 2021
Page 2
3.We note your disclosure on page 4 that "[t]he Trust seeks to make it easier for an investor
to invest in the cryptocurrency market as a whole, without having to pick specific tokens,
manage a portfolio, or constantly monitor ongoing news and developments" and that
"[a]lthough the Shares will not be the exact equivalent of a direct investment in
cryptocurrencies, they provide investors with an alternative that constitutes a relatively
cost-effective, professionally managed way to participate in cryptocurrency markets."
Please discuss in your registration statement the extent to which the Trust has been able to
achieve the goal expressed on page 4 in light of the difference between the trading price of
the Shares on the OTCQX as compared to the Trust's net asset value per share.
4.Refer to your response to comment 6.  We note your disclosure on page 5 that you
purchase digital assets from approved counterparties, including exchanges, electronic
trading systems that seek liquidity from multiple trading venues and OTC trading desks.
Please include a discussion of counterparty risks in your risk factors section, including
risks related to counterparty exposure.  In this regard, we note your disclosure on page 88.
5.Refer to your response to comment 7.  Please expand your summary of the material
differences between an investment in your Shares and a direct investment of digital assets
on page 4 to include (i) the holding period under Rule 144 for the resale of the Shares
purchased from the Trust, (ii) the risk that the Shares may trade at a substantial premium
over or a substantial discount to the Trust's Portfolio Crypto Assets per Share and (iii) the
risk that over time the number of Portfolio Crypto Assets represented by a Share will
gradually decrease as the Portfolio Crypto Assets are used to pay the Trust's expenses.
6.Refer to your response to comment 29.  Please revise to disclose here a detailed
description of how the Sponsor calculates the NAV of the Trust, the NAV per Share and
the price per Share.
7.We note multiple references to the “Trust’s Portfolio Crypto Assets per share” on page 2
and elsewhere in your filing and your discussion of the “Bitwise Crypto Asset Price” on
page 7. Please revise your filing to clearly define these measures and explain how
management uses them, and tell us whether you intend to present these measures in future
filings. Additionally, please tell us how you considered whether these measures were
Non-GAAP measures, and if so determined, revise to include all of the disclosures
required by Regulation G and Item 10(e) of Regulation S-X.
Investment Strategy , page 5
8.Refer to your response to comment 12.  Your disclosure on pages 5 and 91 that "upon the
occurrence of Network Distributions like hard forks, airdrops, emissions, . . . staking, or
other one-off events, the Trust will follow the policies of the Index" appears to be
inconsistent with your disclosure on page 12 that "there may be opportunities for the Trust
to generate returns in excess of the Index through airdrops and proof of stake which the
Sponsor will endeavor to do where possible and prudent."  Please revise for clarity and
consistency, and please disclose how generating returns in excess of the Index is

 FirstName LastNameHunter  Horsley
 Comapany NameBitwise 10 Crypto Index Fund
 August 2, 2021 Page 3
 FirstName LastNameHunter  Horsley
Bitwise 10 Crypto Index Fund
August 2, 2021
Page 3
consistent with your investment strategy, including your disclosure that you are a passive
investment vehicle.  In addition, we note your disclosure on page 11 that the Index does
not calculate the value of emissions, airdrops, or staking rewards but that the Sponsor may
choose to periodically liquidate the emissions, airdrops and staking rewards to deliver
excess returns to Shareholders.  Please clarify if the Sponsor's policies differ from the
Trust's policies related to airdrops, emissions and staking only in the calculation of the
value from such activities but not in regards to accepting and liquidating emissions,
airdrops and staking rewards.
Index, page 6
9.Refer to your response to comment 8.  Your disclosure on page 6 that the components of
the Index Methodology are subject to change in the sole discretion of the Sponsor and
your disclosure on page 7 that eligibility criteria developed by the Sponsor and its
affiliates are applied to screen for investment feasibility in selecting the top ten largest
cryptocurrencies for the Index and that the "[p]ublic exchanges used for calculating the
Index are selected using criteria chosen by the Sponsor in its sole discretion" appear to be
inconsistent with your disclosure on page 11 that the Bitwise Crypto Index Committee has
total responsibility for developing, maintaining and adjusting the Bitwise Crypto Index
Methodologies.  Please revise for clarity and consistency regarding the roles of the
Bitwise Crypto Index Committee and the Sponsor.  In addition, please disclose how you
will satisfy your Exchange Act reporting obligations in connection with notifying
investors of material changes in Index Methodology.  In this regard, we note your
disclosure on page 9 that "[m]ethodological changes to the Index have historically been
posted to a specific section on the Sponsor’s website."  Also, please revise the second and
third complete risk factors on page 54 accordingly.
Price and Cost Slippage, page 6
10.Refer to your response to comment 11. We note your disclosure on page 6 that "there are a
number of other factors aside from price slippage that inform best practices in trade
execution."  Please revise your disclosure to summarize the "other factors" that you
consider in connection with purchases and sales of digital assets and the resulting "best
practices" used in trade execution.
Composite Price Determination, page 7
11.Refer to your response to comment 15.  Please revise your disclosure in Section 3.a.iv on
page 8 to clarify how you "[u]se the synchronous CAP for the relevant Quote Crypto
Assets to translate crypto-to-crypto pairs into a crypto-to-U.S.-dollar equivalent."
Eligibility of Cryptocurrencies, page 9
12.Refer to your responses to comments 22 and 24.  Please disclose (i) whether the Index's
methodology differs from the Trust's methodology for determining whether a digital asset

 FirstName LastNameHunter  Horsley
 Comapany NameBitwise 10 Crypto Index Fund
 August 2, 2021 Page 4
 FirstName LastNameHunter  Horsley
Bitwise 10 Crypto Index Fund
August 2, 2021
Page 4
may be a security, (ii) how the Trust and Index determine whether or not a digital asset
may be a security, and (iii) the policies of both the Trust and the Index if a digital asset
holding is deemed to be at risk of being a security.  Please also emphasize here and in
your risk factor disclosure, if accurate, that the legal test to determine whether an asset is a
security is different from the analysis performed by the Trust and the Index, which is not a
legal standard and only a risk-based assessment that does not preclude legal or regulatory
action based on the presence of a security.
One-Off Events, page 10
13.We note your response to comment 20. Please revise the relevant sections of your filing to
include your abandonment policies and procedures related to each of these one-off events,
as applicable.
14.Refer to your response to comment 19. Please clarify here the factors that the Index and
the Trust consider in connection with (i) accepting and selling airdrops of digital assets
and (ii) engaging in staking activities.  In addition, to the extent that the Index and Trust
have historically accepted and sold airdrops of digital assets or utilized emissions, please
provide a brief summary of such activities.  In addition, we note your disclosure regarding
the staking activities of the Trust on page 13.  Please revise to clarify whether the Index
participated in the Tezos staking activities in 2020.
Departures from the Index, page 12
15.Refer to your response to comment 21.  Please disclose the factors that the Sponsor
considers in connection with a decision to hold different digital assets from the Index.  In
addition, we note your disclosure on page 12 that such exceptions may not always be
communicated in advance to Shareholders.  Please disclose when and how such
exceptions will be communicated to Shareholders.  Also, please disclose the "other assets"
the Trust is permitted to hold.
Staking Activities, page 13
16.Refer to your response to comment 13.  Please disclose whether the Trust's staking
activities could affect its ability to rebalance its holdings due to the monthly rebalancing
of the Index, and address the risks associated with staking in your risk factor section.  In
this regard, we note your disclosure regarding risks associated with staking on page 13 of
your registration statement and your revised disclosure on page 53.  Please also address
the regulatory uncertainty regarding the status of staking activities under the U.S. federal
securities laws in your risk factor disclosure.
Overview of Index Constituents, page 16
17.We note that you have updated your overview of Index Constituents and their
corresponding weights as of March 31, 2021.  Please revise your filing to also include a
detailed listing of the constituents in the index and their weights as of December 31, 2020

 FirstName LastNameHunter  Horsley
 Comapany NameBitwise 10 Crypto Index Fund
 August 2, 2021 Page 5
 FirstName LastName
Hunter  Horsley
Bitwise 10 Crypto Index Fund
August 2, 2021
Page 5
and 2019.
Risk Factors
Risks Related to Cryptocurrencies
Transactions in cryptocurrencies may be irreversible even if they are fraudulent, page 41
18.Your response to comment 28 that "[t]here are no circumstances in the normal course of
business under which the Trust would deliver digital assets to its shareholders" appears to
be inconsistent with your disclosure on page 41 that "[i]f information provided by a
Shareholder proves incorrect, and, as a result, cryptocurrencies are not delivered to the
Shareholder, the Trust will have no liability to the Shareholder for the Trust’s good faith
reliance on such misinformation."  Please revise for clarity.
Risks Related to Bitcoin and Ethereum, page 47
19.We note your response to our prior comment 25.  Please revise to ensure that you disclose
any material risks associated with the use of Bitcoin for illegal purposes, the potential for
new or different regulation of Bitcoin and Ether, and Bitcoin mining and its potential
environmental impact.
Risks Related to Decentralized Finance Portfolio Crypto Assets
Certain Portfolio Crypto Assets utilize decentralized finance protocols, page 53
20.Please identify the Portfolio Crypto Assets that contain decentralized finance protocols
here, including governance, voting, staking assets, lending assets, or liquidity provisions,
and, in your business section, discuss the Trust's and the Index's participation in such
activities to date.
Risks Related to Potential Conflicts of Interests, page 61
21.Refer to your response to comment 37.  Please add risk factors that specifically address
the relationships between the Sponsor and the Index Provider and the associated risk of
conflicts of interests related to using an Index Provider that is affiliated with the Sponsor
as well as the potential conflicts related to the composition of the Bitwise Crypto Index
Committee.
Risks Related to Trading on the OTCQX
Due to the fact that the Shares may trade on the OTCQX, page 63
22.Refer to your responses to comments 4 and 36.  Please provide quantitative disclosure
here to demonstrate the historical difference between the prices quoted on the OTCQX
and the NAV of the Trust's Portfolio Crypto Assets per Share, and discuss the risks to
shareholders of deviations between the NAV per Share and the price per Share on the
OTCQX.

 FirstName LastNameHunter  Horsley
 Comapany NameBitwise 10 Crypto Index Fund
 August 2, 2021 Page 6
 FirstName LastName
Hunter  Horsley
Bitwise 10 Crypto Index Fund
August 2, 2021
Page 6
Risks Related to Regulatory and Compliance, page 66
23.We note your response to comment 38 and the revisions to your filing on page 67.  Please
revise your MD&A on page 78 to include disclosure of the $1.46 million realized loss on
XRP that was recorded in net realized loss from digital assets. Additionally, please expand
your MD&A to discuss in detail the reason(s) for realized losses related to fluctuations in
the value of the Trust’s Portfolio of Crypto Assets.
Financial Information
Management's Discussion and Analysis of Financial Condition and Results of Operations
Comparison of the three-month periods ended March 31, 2021 and 2020, page 77
24.We note disclosure that the $128 thousand of net realized loss from digital assets for the
three months ended March 31, 2021 was due to fluctuations in the value of the Portfolio
Crypto Assets. Please revise your filing to explain the reason(s) for these realized losses
and clarify in your discussion the overall impact of the continued increase in the historical
Portfolio Crypto Asset prices during this period as disclosed on page 83.
Management Fee, page 79
25.Refer to your response to comment 39.  Please clarify what you consider to be
extraordinary expenses that are not covered by the Management Fee.
Shareholder Subscriptions, page 79
26.Refer to your response to comment 42.  Please disclose the reasons the Trust may choose
to halt the acceptance of subscriptions for an extended period.  In this regard, we note that
your revised disclosure on page 80 states that a decision to halt the acceptance of
subscriptions "would [be made] based on business considerations."  In addition, please
disclose how a decision to halt subscriptions will be disclosed to Shareholders.
27.Your disclosure on pages 80 and 106 that you accept cash and in-kind subscriptions on
Tuesdays and Thursdays appears to conflict with your discl

CORRESP
1
filename1.htm

CORRESP

 Wilson Sonsini Goodrich & Rosati
Professional Corporation

 1700 K Street NW
Fifth Floor
Washington, D.C. 20006-3817

 O: 202.973.8800
F: 202.973.8899

 June 30, 2021

Via EDGAR

 U.S. Securities and Exchange
Commission

 Division of Corporation Finance

 Office of
Finance

 100 F. Street, N.E.

 Washington, D.C. 20549

Attention:
 Justin Dobbie

 Sonia Bednarowski

 William Schroeder

 John Spitz

Re:
 Bitwise 10 Crypto Index Fund

 Registration Statement on Form 10

 Filed April 23, 2021

 File No. 000-56270

Ladies and Gentlemen:

 On behalf of our client,
Bitwise 10 Crypto Index Fund (“Bitwise” or the “Company”), we submit this letter in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) contained in its letter dated May 24, 2021, relating to the above referenced Registration Statement on Form 10 (the “Form 10”). We are concurrently publicly filing via EDGAR a revised draft of the
registration statement (the “Revised Registration Statement”).

 In this letter, we have recited the comments from
the staff in italicized, bold type and have followed each comment with the Company’s response. Except for page references appearing in the headings and Staff comments below (which are references to the Registration Statement submitted on
April 23, 2021), all page references herein correspond to the Revised Registration Statement.

 Registration Statement on Form 10

General

1.
 Please revise your filing to include a glossary of defined terms. Additionally, we note references to the
Trust’s Portfolio Crypto Assets per Share and also references to Net Asset Value per Share. Please clearly define these measures and, if the same, please revise your filing for consistency.

In response to the Staff’s comment, the Company has provided a glossary, which begins on page iv of the Revised Registration Statement.

AUSTIN            BEIJING
  BOSTON            BRUSSELS            HONG KONG
 LONDON            LOS ANGELES            NEW YORK
 PALO ALTO

SAN DIEGO            SAN FRANCISCO
     SEATTLE            SHANGHAI            WASHINGTON, DC
     WILMINGTON, DE

 Securities and Exchange Commission

June 30, 2021

  Page
 2

2.
 Please revise to include and clearly label a Management’s Discussion and Analysis of Financial
Condition and Results of Operations section in your filing for each period presented. Refer to Item 303(a) of Regulation S-K.

In response to the Staff’s comment, the Company has updated the disclosure beginning on page 75 of the Revised Registration Statement.

3.
 You state that the Trust’s principal investment objective is to invest in a portfolio of
cryptocurrencies that tracks the Bitwise 10 Large Cap Crypto Index as closely as possible. Please discuss in your registration statement the extent to which the Trust has met its principal investment objective in light of the difference between the
trading price of the shares on the OTCQX as compared to the Trust’s net asset value per share.

 In response
to the Staff’s comment, the Company has updated the disclosure on pages 1 and 76 of the Revised Registration Statement.

 Business

History of the Trust and the Shares, page 1

4.
 We note your disclosure on page 1 that the price of the shares as quoted on the OTCQX has varied
significantly from the value of the Trust’s Portfolio Crypto Assets per Share since the shares were approved for quotation. Please provide quantitative disclosure to demonstrate the historical difference between the prices quoted on the OTCQX
and the NAV of the Trust’s Portfolio Crypto Assets per Share. Please also revise the first risk factor on page 44 accordingly.

In response to the Staff’s comment, the Company has updated the disclosure on page 2 and added the risk factor on page 63 of the
Revised Registration Statement.

 Emerging Growth Company Status, page 2

5.
 We note disclosure that you are choosing to opt-out of the
extended transition period for applying new or revised accounting standards. Please revise the facing page of your filing to check the box indicating your election to not use the extended transition period for complying with new or revised financial
accounting standards.

 The Company respectfully acknowledges the Staff’s comment. The Company notes that it
does intend to take advantage of the extended transition period, and accordingly has updated the disclosure on page 2 of the Revised Registration Statement.

 Securities and Exchange Commission

June 30, 2021

  Page
 3

 Activities of the Trust, page 3

6.
 We note your disclosure on page 4 that the activities of the Trust include selling or buying Portfolio
Crypto Assets in connection with monthly rebalancing and selling Portfolio Crypto Assets to cover the Sponsor’s Management Fee. Please disclose the principal market the Trust uses to convert digital assets to U.S. dollars and to purchase
digital assets in connection with a sale of shares or in connection with the monthly rebalancing of the Portfolio Crypto Assets.

In response to the Staff’s comment, the Company has updated the disclosure on page 5 of the Revised Registration Statement.

Business of the Trust, page 3

7.
 We note your disclosure on page 3 that the Trust provides investors with a cost-effective and
professionally managed way to invest in digital assets. Please revise to clarify that an indirect investment in digital assets through your shares may operate and perform differently from a direct investment in digital assets, and summarize the
material differences. In addition, please disclose here the expenses of the Trust, including the Sponsor’s fee of 2.5% per annum.

In response to the Staff’s comment, the Company has updated the disclosure on page 4 of the Revised Registration Statement.

Index, page 4

8.
 Please clarify the roles of the Bitwise Crypto Committee and the Bitwise Crypto Index Advisory Board in
the governance of the Index. In this regard, we note your disclosure on page 4 that the components of the Index’s methodology are subject to change in the sole discretion of the Sponsor, that the Sponsor and its affiliates select the exchanges
used by the Index and that additional eligibility criteria may be developed by the Sponsor and its affiliates to screen for investment feasibility in selecting the top ten largest cryptocurrencies for the Index. Also disclose the factors that may
cause the Sponsor to modify the Index’s methodology, and describe any changes that have been made to the Index’s methodology since the inception of the Index. Finally, please provide an analysis as to why you believe that, as a reporting
company under the Exchange Act, you are not required to notify shareholders of changes in Index methodology or composition. Please revise here and the second risk factor on page 42 accordingly.

In response to the Staff’s comment, the Company has updated the disclosure on pages 11-12 and
the risk factor on pages 54 and 66 of the Revised Registration Statement.

 Securities and Exchange Commission

June 30, 2021

  Page
 4

9.
 Please add a separate subsection to describe how and when the Index is rebalanced on a monthly basis and
how the Trust adjusts its holdings to track the Index.

 In response to the Staff’s comment, the Company has
updated the disclosure on page 13 of the Revised Registration Statement.

10.
 You state that you have described “certain aspects” of the Index methodology. Please revise
this statement and your disclosure regarding the Index to confirm that you have provided a materially complete description of the Index and its methodology.

In response to the Staff’s comment, the Company has updated the disclosure on page 6 of the Revised Registration Statement.

Investment strategy, page 4

11.
 Please describe how the Sponsor manages costs and price slippage during trade execution.

 In response to the Staff’s comment, the Company has updated the disclosure on page 6 of the Revised
Registration Statement.

12.
 Your disclosure on page 4 that “[u]pon the occurrence of Network Distributions like hard forks,
airdrops, emissions, staking, or other one-off events, the Trust will follow the policies of the Index” appears to be inconsistent with your disclosure on page 7 “[t]hat there may be opportunities
for the Trust to generate returns in excess of the Index through airdrops and proof of stake which the Sponsor will endeavor to do where possible and prudent.” Please revise for consistency, and disclose how generating returns in excess of the
Index is consistent with your investment strategy, including your disclosure that you are a passive investment vehicle. In addition, please disclose how the Trust will inform investors of how these activities will impact the value of the Trust.
Also, please clearly describe the Sponsor’s policies regarding airdrops, including the criteria for accepting an airdrop and how the Sponsor capitalizes on such airdrops.

In response to the Staff’s comment, the Company has updated the disclosure on pages 10-11 of
the Revised Registration Statement.

 Securities and Exchange Commission

June 30, 2021

  Page
 5

13.
 We note your disclosure that the Sponsor uses the assets of the Trust for staking. Please identify the
digital assets it uses for staking and whether it uses a third party for its staking activities. Please clarify whether the Sponsor maintains custody of the staked assets and whether the staked assets could impact the monthly rebalancing of the
Trust’s assets. In addition, please add a risk factor that addresses the risks associated with using the Trust’s assets for staking activities.

In response to the Staff’s comment, the Company has updated the disclosure on page 13 and added the risk factor on page 53 of
the Revised Registration Statement.

14.
 Please also revise your filing to disclose the following:

•

 Disclose your accounting policy for staking;

•

 Disclose whether you have performed any staking services during any period presented; and

•

 Quantify the associated revenues earned and any expenses incurred for each period presented.

 In response to the Staff’s comment, the Company has updated the disclosure on page 13 of the Revised
Registration Statement.

 Index Methodology, page 5

15.
 Please discuss in detail how the composite prices of the digital assets in the Index are determined by
applying the trade-volume weighting technique and the price deviation analysis. To the extent useful to understanding how the prices of the Index’s digital assets are determined, please consider including an illustrative example.

 In response to the Staff’s comment, the Company has updated the disclosure on pages 7-8 of the Revised
Registration Statement.

16.
 We note your disclosure on page 5 regarding the public exchanges the Sponsor selects to calculate the
value of the digital assets included in the Index. Please clarify what you mean by “regulatory compliance,” and describe how the Sponsor determines the “regulatory compliance, security and reliability of real-time price and trade
volume information and absence of abnormal withdrawal restrictions of crypto and fiat currencies” of public exchanges. In addition, please identify the exchanges that the Sponsor currently uses in order to calculate the value of the digital
assets included in the Index, and clarify what you mean by “legitimate public exchanges” on page 6.

 In
response to the Staff’s comment, the Company has updated the disclosure on page 7 of the Revised Registration Statement.

 Securities and Exchange Commission

June 30, 2021

  Page
 6

17.
 We note your disclosure that the ten coins in the Index may not always match the top 10 coins on popular
websites like CoinMarketCap.com that do not use the Index’s screening methodology. For each of the screening criterion, please identify those coins that would be part of the Index based on their total market capitalization but for the
particular criterion.

 In response to the Staff’s comment, the Company has updated the disclosure on page 10
of the Revised Registration Statement.

 Bitwise Crypto Index Committee, page 6

18.
 You state that the Index is evaluated and studied on an “ongoing basis” by the Bitwise Crypto
Index Committee. Please revise to clarify whether the Committee has any recurring or standing meetings to consider the Index and its constituent assets and the frequency of those meetings.

In response to the Staff’s comment, the Company has updated the disclosure on page 11 of the Revised Registration Statement.

One-Off Events, page 6

19.
 Please provide detailed disclosure here regarding the Index’s provisions for Network Distributions
events. In addition, please define the term “emissions.”

 In response to the Staff’s comment, the
Company has updated the disclosure on pages iv and 11 of the Revised Registration Statement.

20.
 We note your disclosure of one-off events, which includes
references to trade suspensions, hard forks and other “network distribution events” such as emissions, airdrops, and staking. We also note disclosure on page 4, which states that for one-off events
the Trust will follow the policies of the Index. Please revise the Index Methodology section and other relevant sections of your filing to include your accounting policies related to each of these one-off
events, including how and when these assets are initially recognized, distributed, transferred or abandoned, as applicable, and disclose the impact of these decisions on your investors. Please also disclose the fair value of any of these assets held
along with any other financial statement impact as a result of these one-off events for all periods presented.

In response to the Staff’s comment, the Company has updated the disclosure on pages 10-11 of the Revised Registration Statement.

 Securities and Exchange Commission

June 30, 2021

  Page
 7

 Departures from the Index, page 7

21.
 Please disclose the criteria that the Sponsor will use to determine whether or not a coin is fraudulent
or otherwise at high risk to shareholders and how the Sponsor will notify investors of a change in the types of assets held by the Trust. In addition, please disclose the “other assets” the Trust may hold and the factors the Sponsor will
consider in deciding to hold such assets. Please also disclose whether, and under what circumstances, the Trust has differed from the Index in the assets it holds.

In response to the Staff’s comment, the Company has updated the disclosure on page 12 of the Revised Registration Statement.

22.
 We note your disclosure that the Trust may differ from the Index in the coins it holds, including if the
Trust deems a digital asset in the Index to be a security. However, you also disclose that the Index will not select a digital asset that is at risk of being deemed a security under U.S. federal securities laws. Please clarify whether the
Sponsor’s methodology differs from the Trust’s methodology for determining whether a digital asset may be a security, and disclose the policies of both the Trust and the Index if a digital asset holding is deemed to be at risk of being a
security. Please also reconcile with your disclosure on page 43 that the Trust intends to avoid investing in cryptocurrencies that constitute securities under U.S. securities laws, while the Index has no such restriction in its methodology.

 In response to the Staff’s comment, the Company has updated the disclosure on page 12 and the risk factor
on page 55 of the Revised Registration Statement. The Company notes that this description was incorrect, as the Index also intends to avoid investing in cryptocurrencies that constitute securities under U.S. securities laws.

Overview of Index Constituents

 Overview of Changes to
the Index Constituents since December 31, 2020, page 15

23.
 We note your disclosure that on January 29, 2021 the Bitwise Crypto Index Committee added two new
constituents to the Index. Ple

United States securities and exchange commission logo
May 24, 2021
Hunter Horsley
President
Bitwise 10 Crypto Index Fund
300 Brannan Street, Suite 201
San Francisco, CA 94107
Re:Bitwise 10 Crypto Index Fund
Registration Statement on Form 10
Filed April 23, 2021
File No. 000-56270
Dear Mr. Horsley:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Registration Statement on Form 10
General
1.Please revise your filing to include a glossary of defined terms. Additionally, we note
references to the Trust’s Portfolio Crypto Assets per Share and also references to Net
Asset Value per Share. Please clearly define these measures and, if the same, please revise
your filing for consistency.
2.Please revise to include and clearly label a Management’s Discussion and Analysis of
Financial Condition and Results of Operations section in your filing for each period
presented. Refer to Item 303(a) of Regulation S-K.
3.You state that the Trust’s principal investment objective is to invest in a portfolio of
cryptocurrencies that tracks the Bitwise 10 Large Cap Crypto Index as closely as

 FirstName LastNameHunter  Horsley
 Comapany NameBitwise 10 Crypto Index Fund
 May 24, 2021 Page 2
 FirstName LastNameHunter  Horsley
Bitwise 10 Crypto Index Fund
May 24, 2021
Page 2
possible.  Please discuss in your registration statement the extent to which the Trust has
met its principal investment objective in light of the difference between the trading price
of the shares on the OTCQX as compared to the Trust's net asset value per share.
Business
History of the Trust and the Shares, page 1
4.We note your disclosure on page 1 that the price of the shares as quoted on the OTCQX
has varied significantly from the value of the Trust's Portfolio Crypto Assets per Share
since the shares were approved for quotation.  Please provide quantitative disclosure to
demonstrate the historical difference between the prices quoted on the OTCQX and the
NAV of the Trust's Portfolio Crypto Assets per Share. Please also revise the first risk
factor on page 44 accordingly.
Emerging Growth Company Status, page 2
5.We note disclosure that you are choosing to opt-out of the extended transition period for
applying new or revised accounting standards.  Please revise the facing page of your filing
to check the box indicating your election to not use the extended transition period for
complying with new or revised financial accounting standards.
Activities of the Trust, page 3
6.We note your disclosure on page 4 that the activities of the Trust include selling or buying
Portfolio Crypto Assets in connection with monthly rebalancing and selling Portfolio
Crypto Assets to cover the Sponsor's Management Fee.  Please disclose the principal
market the Trust uses to convert digital assets to U.S. dollars and to purchase digital assets
in connection with a sale of shares or in connection with the monthly rebalancing of the
Portfolio Crypto Assets.
Business of the Trust, page 3
7.We note your disclosure on page 3 that the Trust provides investors with a cost-effective
and professionally managed way to invest in digital assets.  Please revise to clarify that an
indirect investment in digital assets through your shares may operate and perform
differently from a direct investment in digital assets, and summarize the material
differences.  In addition, please disclose here the expenses of the Trust, including the
Sponsor's fee of 2.5% per annum.
Index, page 4
8.Please clarify the roles of the Bitwise Crypto Committee and the Bitwise Crypto Index
Advisory Board in the governance of the Index.  In this regard, we note your disclosure on
page 4 that the components of the Index's methodology are subject to change in the sole
discretion of the Sponsor, that the Sponsor and its affiliates select the exchanges used by
the Index and that additional eligibility criteria may be developed by the Sponsor and its

 FirstName LastNameHunter  Horsley
 Comapany NameBitwise 10 Crypto Index Fund
 May 24, 2021 Page 3
 FirstName LastNameHunter  Horsley
Bitwise 10 Crypto Index Fund
May 24, 2021
Page 3
affiliates to screen for investment feasibility in selecting the top ten largest
cryptocurrencies for the Index.  Also disclose the factors that may cause the Sponsor to
modify the Index's methodology, and describe any changes that have been made to
the Index's methodology since the inception of the Index.  Finally, please
provide an analysis as to why you believe that, as a reporting company under the
Exchange Act, you are not required to notify shareholders of changes in Index
methodology or composition. Please revise here and the second risk factor on page 42
accordingly.
9.Please add a separate subsection to describe how and when the Index is rebalanced on a
monthly basis and how the Trust adjusts its holdings to track the Index.
10.You state that you have described "certain aspects" of the Index methodology.  Please
revise this statement and your disclosure regarding the Index to confirm that you have
provided a materially complete description of the Index and its methodology.
Investment strategy, page 4
11.Please describe how the Sponsor manages costs and price slippage during trade
execution.
12.Your disclosure on page 4 that "[u]pon the occurrence of Network Distributions like hard
forks, airdrops, emissions, staking, or other one-off events, the Trust will follow the
policies of the Index" appears to be inconsistent with your disclosure on page 7 "[t]hat
there may be opportunities for the Trust to generate returns in excess of the Index through
airdrops and proof of stake which the Sponsor will endeavor to do where possible and
prudent."   Please revise for consistency, and disclose how generating returns in excess of
the Index is consistent with your investment strategy, including your disclosure that you
are a passive investment vehicle.  In addition, please disclose how the Trust will inform
investors of how these activities will impact the value of the Trust.  Also, please clearly
describe the Sponsor's policies regarding airdrops, including the criteria for accepting an
airdrop and how the Sponsor capitalizes on such airdrops.
13.We note your disclosure that the Sponsor uses the assets of the Trust for staking.  Please
identify the digital assets it uses for staking and whether it uses a third party for its staking
activities.  Please clarify whether the Sponsor maintains custody of the staked assets and
whether the staked assets could impact the monthly rebalancing of the Trust's assets.  In
addition, please add a risk factor that addresses the risks associated with using the Trust's
assets for staking activities.
14.Please also revise your filing to disclose the following:

•Disclose your accounting policy for staking;
•Disclose whether you have performed any staking services during any period
presented; and
•Quantify the associated revenues earned and any expenses incurred for each period

 FirstName LastNameHunter  Horsley
 Comapany NameBitwise 10 Crypto Index Fund
 May 24, 2021 Page 4
 FirstName LastNameHunter  Horsley
Bitwise 10 Crypto Index Fund
May 24, 2021
Page 4
presented.
Index Methodology, page 5
15.Please discuss in detail how the composite prices of the digital assets in the Index
are determined by applying the trade-volume weighting technique and the price deviation
analysis.  To the extent useful to understanding how the prices of the Index's digital assets
are determined, please consider including an illustrative example.
16.We note your disclosure on page 5 regarding the public exchanges the Sponsor selects to
calculate the value of the digital assets included in the Index.  Please clarify what you
mean by "regulatory compliance," and describe how the Sponsor determines the
"regulatory compliance, security and reliability of real-time price and trade volume
information and absence of abnormal withdrawal restrictions of crypto and fiat
currencies" of public exchanges.  In addition, please identify the exchanges that the
Sponsor currently uses in order to calculate the value of the digital assets included in the
Index, and clarify what you mean by "legitimate public exchanges" on page 6.
17.We note your disclosure that the ten coins in the Index may not always match the top 10
coins on popular websites like CoinMarketCap.com that do not use the Index's screening
methodology.  For each of the screening criterion, please identify those coins that would
be part of the Index based on their total market capitalization but for the particular
criterion.
Bitwise Crypto Index Committee, page 6
18.You state that the Index is evaluated and studied on an "ongoing basis" by the Bitwise
Crypto Index Committee.  Please revise to clarify whether the Committee has any
recurring or standing meetings to consider the Index and its constituent assets and the
frequency of those meetings.
One-Off Events, page 6
19.Please provide detailed disclosure here regarding the Index's provisions for Network
Distributions events.  In addition, please define the term "emissions."
20.We note your disclosure of one-off events, which includes references to trade suspensions,
hard forks and other “network distribution events” such as emissions, airdrops, and
staking.  We also note disclosure on page 4, which states that for one-off events the Trust
will follow the policies of the Index.  Please revise the Index Methodology section and
other relevant sections of your filing to include your accounting policies related to each of
these one-off events, including how and when these assets are initially recognized,
distributed, transferred or abandoned, as applicable, and disclose the impact of these
decisions on your investors. Please also disclose the fair value of any of these assets held
along with any other financial statement impact as a result of these one-off events for all
periods presented.

 FirstName LastNameHunter  Horsley
 Comapany NameBitwise 10 Crypto Index Fund
 May 24, 2021 Page 5
 FirstName LastNameHunter  Horsley
Bitwise 10 Crypto Index Fund
May 24, 2021
Page 5
Departures from the Index, page 7
21.Please disclose the criteria that the Sponsor will use to determine whether or not a coin is
fraudulent or otherwise at high risk to shareholders and how the Sponsor will notify
investors of a change in the types of assets held by the Trust.  In addition, please disclose
the "other assets" the Trust may hold and the factors the Sponsor will consider in deciding
to hold such assets. Please also disclose whether, and under what circumstances, the Trust
has differed from the Index in the assets it holds.
22.We note your disclosure that the Trust may differ from the Index in the coins it holds,
including if the Trust deems a digital asset in the Index to be a security.  However, you
also disclose that the Index will not select a digital asset that is at risk of being deemed a
security under U.S. federal securities laws.  Please clarify whether the Sponsor's
methodology differs from the Trust's methodology for determining whether a digital asset
may be a security, and disclose the policies of both the Trust and the Index if a digital
asset holding is deemed to be at risk of being a security.  Please also reconcile with your
disclosure on page 43 that the Trust intends to avoid investing in cryptocurrencies that
constitute securities under U.S. securities laws, while the Index has no such restriction in
its methodology.
Overview of Index Constituents
Overview of Changes to the Index Constituents since December 31, 2020, page 15
23.We note your disclosure that on January 29, 2021 the Bitwise Crypto Index Committee
added two new constituents to the Index.  Please disclose the digital assets that were
removed and the weight of each of the current constituents as of the most recent
practicable date.  In addition, please explain why the Committee made this change to the
Index.
Overview of Government Regulation, page 16
24.Please clarify that the Bitwise Framework is not a legal standard and that any assessment
made under that framework does not preclude legal or regulatory action based on the
presence of a security.  Please also clarify whether the Bitwise Framework is a risk-based
assessment.
Risk Factors, page 29
25.We note that a substantial majority of the Trust's assets are concentrated between two
digital assets, Bitcoin and Ether.  Please revise to discuss the specific risks associated with
those two digital assets that are material risks to the Trust's shareholders.
26.Please include risk factor disclosure describing the risk that the Index may be unable to
meet its stated purpose of tracking a basket of cryptocurrencies that represents the
majority of cryptocurrencies by market capitalization if the size of the constituent assets
continues to decrease relative to the total market capitalization.

 FirstName LastNameHunter  Horsley
 Comapany NameBitwise 10 Crypto Index Fund
 May 24, 2021 Page 6
 FirstName LastNameHunter  Horsley
Bitwise 10 Crypto Index Fund
May 24, 2021
Page 6
Cryptocurrencies are subject to volatile price fluctuations, page 35
27.Please revise to quantify the volatility of the digital assets in your portfolio and how that
volatility has impacted an investment in the Trust.
Transactions in cryptocurrencies may be irreversible, page 36
28.We note your disclosure in this risk factor addresses sending "contributions to the correct
digital wallet address."  Please disclose in your business section the circumstances in
which the Trust will deliver digital assets to shareholders.
The Sponsor is solely responsible for determining the value of Portfolio and Shares, page 37
29.Your disclosure on page 37 that the Sponsor has not engaged a third-party calculation
agent is inconsistent with your disclosure on page 77 that Theorem Trust Services LLC
will calculate the NAV of the Trust and share prices.  Please revise for clarity and
consistency.  In addition, please revise your business section to describe in detail how the
NAV of the Trust, the NAV per share and share prices are calculated as well as the
exchanges used.
The Bitwise 10 Crypto Index has a fairly limited history, page 42
30.You refer here and elsewhere to the obligations, actions and discretion of "Bitwise."
Please revise to clarify what entity you are referring to in these disclosures.
The Trust will not track the Index exactly, page 43
31.Please include a chart here or elsewhere comparing the performance of the Trust to the
Index.
Risks Related to Trust and Portfolio Investments, page 44
32.Please add a risk factor that discloses the risk that the number of Portfolio Crypto Assets
represented by a share will gradually decrease over time as the Trust's Portfolio Crypto
Assets are used to pay the Trust's expenses.
If shareholders enter into share lending arrangement , page 45
33.We note your disclosure on page 45 that the Trust or the Sponsor may be asked to provide
certain assurances or non-objections to lending arrangements with response to the Trust's
shares.  In an appropriate section of your registration statement, please disclose the factors
the Sponsor will consider in providing such assurances and non-objections to such
arrangements.
Shareholders may be required to have their Shares redeemed, page 45
34.Please disclose the situations in which shareholders may be required to have their shares
redeemed.  Please also reconc