SecProbe.io

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

 October 27, 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 Solana Staking ETF

 File No. 333-283391

 Dear Ms. Tillan, Mr. Brunhofer, Mr. Lin and Mr. Dobbie:

 Please see attached as Exhibit
A the fact sheet for Bitwise Solana Staking ETF.

 ********

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

 Sincerely yours,

 Chapman and Cutler llp

 By:
 /s/ Richard Coyle

 Richard Coyle

 EXHIBIT A

 Bitwise
Solana Staking ETF BSOL's principal investment strategy is to invest directly in Solana (SOL), while aiming to stake 100% of assets
to maximize Solana's staking rewards. The Fund is a professionally managed and cost-efficient ETP that is fully backed with SOL
held at one of the world's leading crypto asset custodians. BSOL is not suitable for all investors. An investment in the Fund is
subject to a high degree of risk, has the potential for significant volatility, and could result in significant or complete loss of investment.
The Fund is not an investment company registered under the Investment Company Act of 1940 (the "1940 Act"), and therefore
is not subject to the same protections as mutual funds or ETFs registered under the 1940 Act. Fund Details Ticker BSOL CUSIP 091948109
Exchange NYSE Inception Date October 27, 2025 AUM* Data pending Sponsor Bitwise Investment Advisers, LLC Distributions N/A * Assets Under
Management (AUM) reflect non- GAAP, non-audited estimates by Bitwise Investment Advisers, LLC. Please refer to important disclosures
at the end of this document. Fees Sponsor Fee* 0.20% + Other Expenses 0.00% = Gross Expense Ratio 0.20% – Fee Waiver** 0.20% =
Net Expense Ratio 0.00% * The Sponsor Fee includes custody charges for holding the Fund's assets charged by the custodian, as well
as customary fees and expenses of the fund administrator and auditor. ** For a period of three months commencing on the day the Shares
are initially listed on the Exchange, the Sponsor has agreed to waive the entire Sponsor Fee on the first $1 billion of Trust assets.
Brokerage and commission costs may apply. BSOL As of October 27, 2025 Why Invest? 1 Staked SOL Exposure in an ETP Wrapper. BSOL provides
cost-efficient exposure to the price movement of Solana (SOL). The Fund aims to stake 100% of its assets to maximize Solana's 7%+
average staking rewards.* 2 Solana's Upside Potential. As one of the fastest Layer 1 blockchains, Solana is a leading player in
the fastgrowing tokenization and stablecoin markets. Bitwise CIO Matt Hougan calls it "one of the most exciting crypto investment
opportunities that exists today." 3 An ETP Backed by Crypto Specialists. In choosing BSOL, investors gain access to a team of crypto
experts with the tools, insights, and specialized experience to help them navigate the space with confidence. * Staking reward rate is
based on the annualized 90-day average as of 10/22/25, with data from Helius. Rewards are subject to change and should not be considered
an indication of the Fund's performance. Performance (%) 1MO 3MO YTD 1YR 3YR 5YR SINCE INCEPTION BSOL (NAV) - - -
- - - - BSOL (Market Price) - - - - - - - Solana (SOL) - -
- - - - - Performance of greater than one year is annualized. The performance quoted represents past performance
and does not guarantee future results. Short-term performance, in particular, is not a good indication of the Fund's future performance,
and an investment should not be made based solely on returns. Investment return and principal value of an investment will fluctuate so
that an investor's shares, when sold or redeemed, may be worth more or less than the original cost. Current performance may be
lower or higher than the performance quoted. Performance data current to the most recent month end may be obtained by calling 1-415-707-3663.
Gross Staking Reward Rate - Net Staking Reward Rate - Reward rates are subject to change and are not guaranteed. Rates are
the average annualized rates over the last 90 days with data from Helius. See Glossary for definitions.

 BSOL | Bitwise Solana Staking ETF | As of Month XX, YYYY Glossary Beta
measures the volatility of the Fund price relative to the volatility in the market index. The Bloomberg U.S. Aggregate Bond Index is designed
to measure the performance of publicly issued U.S. dollar denominated investment-grade debt. Correlation measures the degree to which
a pair of variables are linearly related. Gold is represented by the spot gold price with data from Bloomberg. Gross Staking Reward Rate
is the total annual rate of staking rewards currently available on the Solana network when including inflation rewards, MEV rewards, and
block rewards. Net Staking Reward Rate is the total annual staking reward rate currently available on the Solana network after staking-related
fees are deducted from the gross reward rate. The S&P 500® TR Index, or Standard & Poor's 500 Total Return Index, is
a market-capitalization-weighted index of 500 leading publicly traded companies in the U.S. Solana is represented by the CME CF Solana-Dollar
Reference Rate - New York Variant (SOLUSD_NY). Staking is a foundational mechanism that ensures the security and sustainability of Proof
of Stake (PoS) blockchain networks like Solana. This decentralized consensus mechanism not only safeguards the network but also grants
rewards to participating investors in exchange for validating transactions on the blockchain. Standard Deviation is a statistical measurement
measuring return variability. About Bitwise Bitwise Asset Management is a global crypto asset manager with more than $15 billion in client
assets and a suite of over 30 crypto investment products spanning ETFs, separately managed accounts, private funds, hedge fund strategies,
and staking. The firm has a eight-year track record and today serves more than 4,000 private wealth teams, RIAs, family offices and institutional
investors as well as 15 banks and broker-dealers. The Bitwise team of over 100 technology and investment professionals is backed by leading
institutional investors and has offices in San Francisco, New York, and London. Risks and Important Information This material must be
accompanied by a prospectus. Please read the prospectus carefully before investing. To obtain a current prospectus visit bsoletf.com/
welcome. The Bitwise Solana Staking ETF (BSOL) is not suitable for all investors. An investment in BSOL is subject to a high degree of
risk, has the potential for significant volatility, and could result in significant or complete loss of investment. BSOL is not an investment
company registered under the Investment Company Act of 1940, as amended (the "1940 Act") and therefore is not subject to the
same protections as ETFs and mutual funds registered under the 1940 Act. An investment in BSOL is not a direct investment in Solana (SOL).
Shares of ETPs are bought and sold at market price (not NAV) and are not individually redeemed from the Fund. Brokerage commissions will
reduce returns. The NAV may not always correspond to the market price of SOL and, as a result, Creation Units may be created or redeemed
at a value that is different from the market price of the Shares. Authorized Participants' buying and selling activity associated
with the creation and redemption of Creation Units may adversely affect an investment in the Shares. The amount of SOL represented by
a Share will continue to be reduced during the life of the Fund due to the transfer of the Fund's SOL to pay for the Sponsor's
management fee, and to pay for litigation expenses or other extraordinary expenses. This dynamic will occur irrespective of whether the
trading price of the Shares rises or falls in response to changes in the price of SOL. There is no guarantee or assurance that the Fund's
methodology will result in the Fund achieving positive investment returns or outperforming other investment products. Investors may choose
to use the Fund as a means of investing indirectly in SOL. Because the value of the Shares is correlated with the value of the SOL held
by the Fund, it is important to understand the investment attributes of, and the market for, SOL. SOL Risk. There are significant risks
and hazards inherent in the SOL market that may cause the price of SOL to fluctuate widely. The Fund's SOL may be subject to loss,
damage, theft or restriction on access. Investors considering a purchase of Shares should carefully consider how much of their total assets
should be exposed to the SOL market, and should fully understand, be willing to assume, and have the financial resources necessary to
withstand the risks involved in the Fund's investment strategy. Liquidity Risk. The market for SOL is still developing and may be
subject to periods of illiquidity. During such times it may be difficult or impossible to buy or sell a position at the desired price.
Possible illiquid markets may exacerbate losses or increase the variability between the Fund's NAV and its market price. The lack
of active trading markets for the Shares may result in losses on investors' investments at the time of disposition of Shares. Regulatory
Risk. Future and current regulations by a U.S. or foreign government or quasi-governmental agency could have an adverse effect on an investment
in the Fund. Blockchain Technology Risk. Certain of the Fund's investments may be subject to the risks associated with investing
in blockchain technology. The risks associated with blockchain technology may not fully emerge until the technology is widely used. Blockchain
systems could be vulnerable to fraud, particularly if a significant minority of participants colluded to defraud the rest. Because blockchain
technology systems may operate across many national boundaries and regulatory jurisdictions, it is possible that blockchain technology
may be subject to widespread and inconsistent regulation. Staking Risk. The Trust intends to implement a staking program under which a
significant portion of the Trust's SOL will be staked. While staking Solana offers the potential to earn rewards in the form of
additional Solana tokens, it also exposes the Trust to several risks, such as loss of rewards, slashing penalties, and operational uncertainties.
Staking activities could impair the ability to satisfy redemption orders on a timely basis. Nondiversification Risk. The Fund is nondiversified
and will hold a single issue. As a result, a decline in the market value of a particular issue held by the Fund may affect the Fund's
value more than if it invested in a larger number of issuers. Recency Risk. The Fund is recently organized, giving prospective investors
a limited track record on which to base their investment decision. If the Fund is not profitable, the Fund may terminate and liquidate
at a time that is disadvantageous to Shareholders. Bitwise Investment Advisers, LLC serves as the sponsor of the Fund. Foreside Fund Services,
LLC serves as the Marketing Agent for BSOL, and is not affiliated with Bitwise Investment Advisers, LLC, Bitwise, or any of its affiliate

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 26, 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 Solana Staking
    ETF

    File No. 333-283391

Dear Ms. Tillan, Mr. Brunhofer, Mr. Lin and Mr. Dobbie:

This letter responds to
your comments regarding the registration statement filed on Form S-1 for the Bitwise Solana Staking ETF (formerly, the Bitwise
Solana ETF) (the “Trust”) with the Staff of the Securities and Exchange Commission (the “Staff”)
on September 12, 2025 (the “Registration Statement”). Capitalized terms used herein, but not otherwise defined,
have the meanings ascribed to them in the Registration Statement.

Comment 1 – Prospectus
Summary – Staking, page 3

You state here that the Sponsor
anticipates that it will engage in staking with respect to ___% of the Trust's Solana, except as necessary to pay (i) the Sponsor Fee,
(ii) any fees and expenses not assumed by the Sponsor; and (iii) to meet redemption requests. To the extent you expect the actual staking
percentage to be dynamic, please tell us, with a view towards revised disclosure, whether a current percentage of the Trust’s SOL
being staked will be made publicly available to investors on a regular basis, including on your website or otherwise.

Response to Comment 1

Pursuant to the Staff’s
comment, the referenced disclosure has been revised as set forth below, with the commitment to include on the Trust’s website on
a daily basis the percentage of its Solana that is currently being staked.

  Under normal circumstances, the Sponsor
anticipates that it will engage in staking with respect to approximately 100% of the Trust’s Solana, except for Solana reserved
by the Sponsor in its sole discretion to facilitate foreseeable redemption transactions, pay Trust fees and expenses or otherwise protect
the Trust and its assets. The Trust will disclose on its website the percentage of the Trust’s Solana that was staked as of the
beginning of each trading day.

September 26, 2025

Page 2

Comment 2 – Staking – Liquidity
Policies and Procedures, page 85

We note your response to prior
comment 3. Please confirm your understanding that we may have additional comments upon review of a materially complete description of
your staking program liquidity risk policies and procedures.

Response to Comment 2

The referenced portion of
the Registrant Statement has been revised to include a materially complete description of the Trust’s liquidity risk policies and
procedures.

* * * * * * * *

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

    Sincerely yours,

    Chapman and Cutler llp

    By:
    /s/ Richard Coyle

    Richard Coyle

September 12, 2025
Hunter Horsley
President
Bitwise Solana ETF
c/o Bitwise Investment Advisers, LLC
250 Montgomery Street, Suite 200
San Francisco, CA 94104
Re:Bitwise Solana ETF
Amendment No. 3 to Registration Statement on Form S-1
Filed August 29, 2025
File No. 333-283391
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 August 15, 2025 letter.
Amendment No. 3 to Registration Statement on Form S-1
Prospectus Summary
Staking, page 3
1.You state here that the Sponsor anticipates that it will engage in staking with respect
to ___% of the Trust's Solana, except as necessary to pay (i) the Sponsor Fee, (ii) any
fees and expenses not assumed by the Sponsor; and (iii) to meet redemption
requests. To the extent you expect the actual staking percentage to be dynamic, please
tell us, with a view towards revised disclosure, whether a current percentage of the
Trust's SOL being staked will be made publicly available to investors on a regular
basis, including on your website or otherwise.

September 12, 2025
Page 2
Staking
Liquidity Policies and Procedures, page 85
2.We note your response to prior comment 3. Please confirm your understanding that
we may have additional comments upon review of a materially complete description
of your staking program liquidity risk policies and procedures.
            Please contact Kate Tillan at 202-551-3604 or Mark Brunhofer at 202-551-3638 if
you have questions regarding comments on the financial statements and related
matters. Please contact David Gessert at 202-551-2326 or Justin Dobbie at 202-551-3469
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets
cc:Richard Coyle

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

August 29, 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 Solana ETF

    File No. 333-283391

Dear Ms. Tillan, Mr. Brunhofer, Mr. Lin and Mr. Dobbie:

This letter responds to your
comments regarding the registration statement filed on Form S-1 for the Bitwise Solana ETF (the “Trust”) with
the Staff of the Securities and Exchange Commission (the “Staff”) on August 15, 2025 (the “Registration Statement”).
Capitalized terms used herein, but not otherwise defined, have the meanings ascribed to them in the Registration Statement.

Comment 1 – Risk
Factors – Risks Associated with Staking – Solana staking may result in adverse tax consequences for Shareholders, page 44

Please revise your disclosure
so that it is consistent with your response to prior comment 5 that you intend to solely earn staking rewards in the form of additional Solana.
For example, on page 44, you disclose that “[t]he staking of the Trust’s Solana is expected to result in the Trust’s
receipt of staking proceeds in the form of additional Solana or cash” and, on page 128, you state that “[i]f the Trust were
to receive staking rewards, likely in the form of additional Solana, any such staking rewards received by the Trust would be reportable
to Shareholders as taxable income under current IRS guidance.”

Response to Comment 1

The references have been revised
to make clear that the Trust currently expects to receive staking rewards solely in the form of additional Solana.

August 29, 2025

Page 2

Comment 2 – The
Trust and Solana Prices – The CME CF Solana-Dollar Reference Rate New York Variant, page 81

We note your response to prior
comment 16 that you do not have a license agreement with the Benchmark Provider. Please tell us whether you intend to enter into an agreement
with the Benchmark Provider prior to effectiveness, and, if not, please explain whether you are authorized to value the net assets
of the Trust and its Shares on a daily basis with the Pricing Benchmark calculated by the Benchmark Provider.

Response to Comment 2

The Registrant confirms that
it intends to enter into a license agreement with the Benchmark Provider prior to effectiveness of the Registration Statement.

Comment 3 – Staking
– Liquidity Policies and Procedures, page 86

We note your response to prior
comment 2 and your disclosure in this section. Please revise to provide a complete description of your liquidity risk policies and procedures.
To the extent such policies and procedures are intended to be consistent with the exchange’s proposed generic listing standards,
please revise accordingly.

Response to Comment 3

The Registrant continues to
work to finalize its liquidity risk policies and procedures in a manner such that such policies and procedures comply with the Exchange’s
proposed generic listing standards. The Registration Statement will be revised to include a complete description of such policies and
procedures in a future amendment.

Comment 4 – Custody
of the Trust’s Assets, page 95

Refer to your response to
prior comment 18. Your disclosure on page 95 is inconsistent regarding the percentage of private keys that are held in the Cold Solana
Account. You disclose that a substantial portion of the private keys will be held in the Cold Solana Account with the remaining portion
held in the Hot Solana Account, and you also disclose that “[t]he Sponsor expects that all of the Trust’s assets and
private keys will be held in cold storage.” Please revise for clarity and consistency.

August 29, 2025

Page 3

Response to Comment 4

The referenced disclosure
has been revised as set forth below to further clarify that the Trust intends to maintain substantially all of the private keys in cold
storage or similarly secure technology.

The Solana Custodian will maintain substantially
all of the private keys associated with the Trust’s Solana in “cold storage” or similarly secure technology (the “Cold
Solana Account”). Similarly secure technology may include the usage of storage on hardware security modules (HSMs) that may connect
to the internet securely in order to broadcast transactions. While such connectivity is intended to be limited and secure, it may nonetheless
expose the system to cybersecurity risks, including potential vulnerabilities in software, firmware, or network architecture. Any compromise
of the HSM environment, including unauthorized access or exploitation of its internet-connected features, could result in the loss or
theft of digital assets, and may adversely affect the value of the Shares or the Trust’s ability to transact. Any remaining portion
of the Trust’s Solana holdings may be held in a “Hot Solana Account.” The Sponsor expects that substantially all of
the Trust’s assets and private keys will be held in cold storage or similarly secure technology of the Solana Custodian on an ongoing
basis.

Comment 5 – Creation
and Redemption of Shares – Creation Procedures, page 107

Refer to your response to
prior comment 21. Under the Agent Execution Model, the Trust may require the Authorized Participant to deliver the required cash in the
Trust’s Trading Balance for the Cash Creation Order. Please revise to disclose whether excess cash will be returned to the Authorized
Participant to the extent that the cash deposited by the Authorized Participant in the Trust’s Trading Balance exceeds the execution
price of the Solana acquired.

Response to Comment 5

Pursuant to the Staff’s
comment, the disclosure set forth below has been added to the section entitled “Creation and Redemption of Shares.”

If the amount of cash required to acquire the
requisite amount of Solana is less than the amount deposited by the Authorized Participant, the full amount of cash deposited by the Authorized
Participant will be returned to the Authorized Participant (at the Authorized Participant’s expense) and the Authorized Participant
will then re-send the correct amount.

*   *   *   *   *   *   *   *

August 29, 2025

Page 4

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 15, 2025
Hunter Horsley
President
Bitwise Solana ETF
c/o Bitwise Investment Advisers, LLC
250 Montgomery Street, Suite 200
San Francisco, CA 94104
Re:Bitwise Solana ETF
Amendment No. 2 to Registration Statement on Form S-1
Filed July 31, 2025
File No. 333-283391
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 3, 2025 letter.
Amendment No. 2 to Registration Statement on Form S-1
Risks Associated with Staking
Solana staking may result in adverse tax consequences for Shareholders, page 44
1.Please revise your disclosure so that it is consistent with your response to prior
comment 5 that you intend to solely earn staking rewards in the form of
additional Solana. For example, on page 44, you disclose that "[t]he staking of the
Trust's Solana is expected to result in the Trust's receipt of staking proceeds in the
form of additional Solana or cash" and, on page 128, you state that "[i]f the Trust were
to receive staking rewards, likely in the form of additional Solana, any such staking
rewards received by the Trust would be reportable to Shareholders as taxable income
under current IRS guidance."

August 15, 2025
Page 2
The Trust and Solana Prices
The CME CF Solana-Dollar Reference Rate-New York Variant, page 81
2.We note your response to prior comment 16 that you do not have a license agreement
with the Benchmark Provider. Please tell us whether you intend to enter into an
agreement with the Benchmark Provider prior to effectiveness, and, if not, please
explain whether you are authorized to value the net assets of the Trust and its Shares
on a daily basis with the Pricing Benchmark calculated by the Benchmark Provider.
Staking
Liquidity Policies and Procedures, page 86
3.We note your response to prior comment 2 and your disclosure in this section. Please
revise to provide a complete description of your liquidity risk policies and procedures.
To the extent such policies and procedures are intended to be consistent with the
exchange's proposed generic listing standards, please revise accordingly.
Custody of the Trust's Assets, page 95
4.Refer to your response to prior comment 18. Your disclosure on page 95 is
inconsistent regarding the percentage of private keys that are held in the Cold Solana
Account. You disclose that a substantial portion of the private keys will be held in the
Cold Solana Account with the remaining portion held in the Hot Solana Account, and
you also disclose that "[t]he Sponsor expects that all of the Trust's assets and private
keys will be held in cold storage." Please revise for clarity and consistency.
Creation and Redemption of Shares
Creation Procedures, page 107
5.Refer to your response to prior comment 21. Under the Agent Execution Model, the
Trust may require the Authorized Participant to deliver the required cash in the Trust's
Trading Balance for the Cash Creation Order. Please revise to disclose whether excess
cash will be returned to the Authorized Participant to the extent that the cash
deposited by the Authorized Participant in the Trust's Trading Balance exceeds the
execution price of the Solana acquired.
            Please contact Kate Tillan at 202-551-3604 or Mark Brunhofer at 202-551-3638 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 Crypto Assets
cc:Richard Coyle

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

July 31, 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 Solana ETF

    File No. 333-283391

Dear Ms. Tillan, Mr. Brunhofer, Mr. Lin and Mr. Dobbie:

This letter responds to your
comments regarding the registration statement filed on Form S-1 for the Bitwise Solana ETF (the “Trust”) with
the Staff of the Securities and Exchange Commission (the “Staff”) on June 13, 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

Please provide us a copy of
your fact sheet for our review.

Response to Comment 1

The Registrant will provide
the fact sheet in the future under separate cover.

July 31, 2025

Page 2

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

We note your disclosure that
“one or more” of the Trust Solana Accounts, designated as “Trust Staking Account(s),” permits the Solana held
therein to be staked in accordance with the Trust’s staking policy. Please revise to provide a materially complete description of
the Trust’s staking policy, including disclosure of the percentage of the Trust’s Solana to be staked.

Response to Comment 2

The Sponsor is still in the
process of making final determinations regarding the operation of the Trust’s staking program as it remains attentive to potential
developments in regulatory clarity. The operation of the staking program may be impacted by the “generic listing standards”
that the Securities and Exchange Commission’s Division of Trading and Markets are thought to be proposing in the near future. Furthermore,
the operation of the Trust’s staking program is heavily influenced by the activities that a Trust may undertake and maintain its
status as a grantor trust under federal tax laws. The Sponsor has received indications that in the near future further clarity may emerge
from the U.S. Department of the Treasury or pursuant to an Executive Order issued by the President of the United States regarding such
activities.

Nevertheless, the Sponsor
intends to stake the entirety of the Trust’s Solana. The Sponsor intends to meet redemption requests on a “T+2” basis,
meaning that the Trust will make redemption distributions on the second business day following a properly submitted and accepted Redemption
Order. This is designed to align with the “cooldown period” on the Solana Network, which is the period of time it takes for
staked Solana to become fully liquid and transferable following an un-stake request. In general, the cooldown period on the Solana Network
is expected to be 48 hours or less. When the Trust receives a Redemption Order, the Sponsor will cause an un-stake request to be submitted
for an amount of staked Solana sufficient to satisfy the Redemption Order. Once the cooldown period is complete, the Sponsor, on behalf
of the Trust, will have complete control over the Solana, including the ability to directly distribute the Solana in connection with an
In-Kind Redemption Order or sell it for cash in connection with a Cash Redemption Order.

Comment 3 – Prospectus
Summary – Overview of the Trust, page 1

You state that the Trust’s
investment objective is to seek to provide exposure to the value of Solana held by the Trust, less the expenses of the Trust’s operations
and other liabilities. Please revise to clarify whether your plans to earn rewards by staking a portion of your Solana are part of your
investment objective.

Response to Comment 3

Pursuant to the Staff’s
comment, the Trust’s investment objective has been revised as set forth below.

The Trust’s primary investment objective
is to seek to provide exposure to the value of Solana held by the Trust, less the expenses of the Trust’s operations and other liabilities.
The Trust’s secondary investment objective is to seek to earn staking rewards.

July 31, 2025

Page 3

Comment 4 – Prospectus
Summary – Solana and the Solana Network, page 1

Please revise to disclose
here the market capitalization of Solana. In addition, please provide quantitative disclosure here and in the first risk factor on page
11 regarding the historic volatility of the price of Solana.

Response to Comment 4

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

As of July 28, 2025, Solana had a market capitalization
of $100,344,506,829, according to CoinGecko.

Additionally, the referenced
risk disclosure has been revised as set forth below.

Solana has exhibited a historical annualized
volatility of 121.67% and maximum annual price decrease of 95.34%.

Comment 5 – Prospectus
Summary – The Trust’s Investment Objective and Strategies, page 5

Please revise your disclosures
throughout to clarify whether the Trust will receive staking rewards in the form of additional Solana and/or cash. As examples only, we
note the following:

 ● your
                                            disclosure on page 2 that “[a]s consideration for participating in staking activities,
                                            the Trust will receive a portion of the reward generated from such participation in the form
                                            of additional Solana...” (emphasis added);

 ● your
                                            disclosure on page 3 that the “Trust will receive a portion of the staking rewards
                                            related to [staking] activity, denominated in additional Solana or paid in cash” (emphasis
                                            added);

 ● your
                                            disclosure on page 108 that “[d]eposits of cash proceeds received by the Trust... from
                                            staking rewards will be used to acquire Solana” (emphasis added); and

 ● your
                                            disclosure on page 125 that, “If the Trust were to receive staking rewards, likely
                                            in the form of additional Solana, any such staking rewards received by the Trust would be
                                            reportable to Shareholders as taxable income under current IRS guidance” (emphasis
                                            added).

Please revise your disclosure
throughout for clarity and consistency.

Response to Comment 5

The referenced disclosure
has been revised to clarify that the Trust currently intends to solely earn staking rewards in the form of additional Solana.

July 31, 2025

Page 4

Comment 6 – Prospectus
Summary – Purchases and Sales of Solana, page 3

We note your disclosure in
the last paragraph on page 3 that purchases and sales of the Trust’s Solana may be facilitated through the Prime Execution Agent,
an affiliate of the Solana Custodian. Please revise in an appropriate section of the prospectus to describe the potential conflicts of
interest associated with such an arrangement and the impact it may have on price.

Response to Comment 6

The Registrant respectfully
declines to add the requested disclosure in the Prospectus Summary. The Trust intends to do substantially all of its acquisition and divestment
of Solana pursuant to In-Kind Creations and In-Kind Redemptions and, when an Authorized Participant effectuates a Cash Creation or Cash
Redemption, through the Trust Directed Trade Model, as is disclosed throughout the Registration Statement. It is considered very unlikely
that the Trust will purchase or sell Solana pursuant to the Agent Execution Model. Accordingly, the Registrant respectfully asserts that
the inclusion of such disclosure in the section of the Registration Statement entitled “Material Contracts – Prime Execution
Agreement,” where it currently exists (reproduced below), is more appropriate.

The Prime Execution Agreement provides that
the Prime Execution Agent is subject to certain conflicts of interest, including: (i) the Trust’s orders may be routed to the Prime
Execution Agent’s own execution venue where the Trust’s orders may be executed against other customers of the Prime Execution
Agent or with the Coinbase acting as principal, (ii) the beneficial identity of the counterparty purchaser or seller with respect to the
Trust’s orders may be unknown and therefore may inadvertently be another client of the Prime Execution Agent, (iii) the Prime Execution
Agent does not engage in front-running, but is aware of the Trust’s orders or imminent orders and may execute a trade for its own
inventory (or the account of an affiliate) while in possession of that knowledge and (iv) the Prime Execution Agent may act in a principal
capacity with respect to certain orders. As a result of these and other conflicts, when acting as principal, the Prime Execution Agent
may have an incentive to favor its own interests and the interests of its affiliates over the Trust’s interests.

July 31, 2025

Page 5

Comment 7 – Prospectus
Summary – The Trust’s Fees and Expenses, page 5

We note your disclosure on
page 6 that transfer fees with respect to on-chain transfers to and from a Trust Solana Account to a Solana Trading Counterparty, an Authorized
Participant or an Authorized Participant Designee will be paid by the Solana Custodian. Please revise to clarify whether the Solana Custodian
will pay such transfer fees using the Trust’s assets.

Response to Comment 7

Pursuant to the Staff’s
comment, the referenced disclosure has been revised to clarify that the Solana Custodian will not pay such transfer fees using the Trust’s
assets through the inclusion of the disclosure set forth below.

The Solana Custodian will not pay such transfer
fees using Trust assets.

Comment 8 – Prospectus
Summary – The Trust’s Fees and Expenses, page 5

We note your disclosure on
pages 6 and 86 that:

 ● the
                                            Trust is not responsible for paying any fees or costs associated with the transfer of Solana
                                            to the Sponsor; and

 ● “[t]he
                                            Trust may incur certain extraordinary, non-recurring expenses that are not assumed by the
                                            Sponsor, including, but not limited to,... Solana Network fees.”

Please revise to clarify when
the Trust is responsible for paying Solana Network fees.

Response to Comment 8

Pursuant to the Staff’s
comment, the referenced disclosure under the second bullet has been revised to clarify that the Trust is not responsible for paying Solana
Network transfer fees.

July 31, 2025

Page 6

Comment 9 – Risk
Factors – Solana is a relatively new technological innovation with a limited operating history, page 19

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

Response to Comment 9

Pursuant to the Staff’s
comment, the referenced risk factor has been revised to include the following disclosure.

Solana began trading in April 2020 and in the
United States in September 2020.

Comment 10 – Risk
Factors – The Solana Network could be vulnerable to attacks..., page 29

Please expand this risk factor
to discuss any risks from other potential forms of attack against the Solana Network, including, for example, “the significant disruption,
later attributed to a type of denial of service attack,” that the Solana Network experienced on September 14, 2021, as disclosed
on page 74 under “Forms of Attack Against the Solana Network.”

Response to Comment 10

Pursuant to the Staff’s
comment, the Registration Statement was revised to include the following as the second risk factor in the section entitled Risk Factors
– Risks Associated with Solana and the Solana Network” to highlight not only the September 14, 2021 outage but other known
outages as well.

Solana is a relatively new technological
innovation with a limited operating history. The Solana Network may not function as intended, which could have an adverse impact on the
value of Solana therefore the value of Shares.

The Solana Protocol was conceived in 2017 and
serves as the underlying architecture and rules pursuant to which the Solana Network operates. Solana began trading in April 2020 and
in the United States in September 2020. One notable element of the Solana Protocol was the introduction of Proof-of-History (“PoH”)
timestamping mechanism. PoH is a timestamping mechanism that automatically orders on-chain transactions by creating a historical record
that proves an event has occurred at a specific moment in time. PoH is intended to provide a transaction processing speed and capacity
advantage over other blockchain networks like the Bitcoin network and the Ethereum network, which rely on sequential production of blocks
and can lead to delays caused by validator confirmations.

July 31, 2025

Page 7

However, PoH is a relatively new blockchain
technology that is not widely used and may not function as intended. For example, it may require more specialized equipment to participate
in the network and fail to attract a significant number of users. In addition, there may be flaws in the cryptography underlying PoH specifically
or the Solana Network generally, including flaws that affect functionality of the Solana Network, the proof-of-stake consensus algorithm,
a particular client software implementation, or a user’s wallet software, or make the network vulnerable to attack.

The Solana Network has suffered network-level
outage incidents over the past five years. For example, in 2020, the Solana Network experienced an outage attributed to a bug in the block
propagation mechanism, and was offline for at least six hours. On September 14, 2021, the Solana Network experienced a significant disruption,
later attributed to a type of denial of service attack, and was offline for 17 hours, only returning to full functionality 24 hours later.
During the restart, a second integer overflow bug was discovered and patched. In January 2022, during a time of high network congestion,
the Solana Network experienced degraded performance and partial outages. The disruption was attributed to bots spamming excessive duplicate
transactions, significantly reducing network capacity. Blocks took longer than expected to process, leading to transaction success rates
dropping by as much as seventy (70) percent. In April 2022, the Solana Network experienced an unprecedented surge in transaction requests,
attributed to bots trying to secure newly minted NFTs through the Metaplex Candy Machine program. This minting mechanism operated on a
first-come, first-served basis, creating a strong economic incentive to flood the network with transactions and win the mint. As transaction
volume skyrocketed, validators ran out of memory and crashed, ultimately stalling consensus. Insufficient voting throughput prevented
the finalization of earlier blocks, preventing abandoned forks from being cleaned up. As a result, validators became overwhelmed by the
sheer number of forks they had to evaluate, exceeding their capacity even after restarts and requiring manual intervention to restore
the network. The Solana Network was offline for at least eight (8) hours. In June 2022, the Solana Network experienced a bug with so-called
“durable nonce” transactions leading to consensus failures. The Solana Network was offline for at least two and a half hours.
In September 2022, the Solana Network experienced a bug attributed to validators erroneously producing duplicate blocks at the same block
height. The Solana Network was offline for at least eight and a half

July 3, 2025
Hunter Horsley
President
Bitwise Solana ETF
c/o Bitwise Investment Advisers, LLC
250 Montgomery Street, Suite 200
San Francisco, CA 94104
Re:Bitwise Solana ETF
Amendment No. 1 to Registration Statement on Form S-1
Filed June 13, 2025
File No. 333-283391
Dear Hunter Horsley:
            We have reviewed 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.
Amendment No. 1 to Registration Statement on Form S-1
General
1.Please provide us a copy of your fact sheet for our review.
Prospectus Summary
Overview of the Trust, page 1
2.We note your disclosure that "one or more" of the Trust Solana Accounts, designated
as "Trust Staking Account(s)," permits the Solana held therein to be staked in
accordance with the Trust's staking policy. Please revise to provide a materially
complete description of the Trust's staking policy, including disclosure of the
percentage of the Trust's Solana to be staked.
You state that the Trust's investment objective is to seek to provide exposure to the
value of Solana held by the Trust, less the expenses of the Trust's operations and other 3.

July 3, 2025
Page 2
liabilities. Please revise to clarify whether your plans to earn rewards by staking a
portion of your Solana are part of your investment objective.
Solana and the Solana Network, page 1
4.Please revise to disclose here the market capitalization of Solana. In addition, please
provide quantitative disclosure here and in the first risk factor on page 11 regarding
the historic volatility of the price of Solana.
The Trust's Investment Objective and Strategies, page 2
5.Please revise your disclosures throughout to clarify whether the Trust will receive
staking rewards in the form of additional Solana and/or cash. As examples only, we
note the following:
•your disclosure on page 2 that "[a]s consideration for participating in staking
activities, the Trust will receive a portion of the reward generated from such
participation in the form of additional Solana ..." (emphasis added);
•your disclosure on page 3 that the "Trust will receive a portion of the staking
rewards related to [staking] activity, denominated in additional Solana or paid in
cash" (emphasis added);
•your disclosure on page 108 that "[d]eposits of cash proceeds  received by the
Trust... from staking rewards will be used to acquire Solana" (emphasis added);
and
•your disclosure on page 125 that, "If the Trust were to receive staking rewards,
likely in the form of additional Solana , any such staking rewards received by the
Trust would be reportable to Shareholders as taxable income under current IRS
guidance" (emphasis added).
Please revise your disclosure throughout for clarity and consistency.
Purchases and Sales of Solana, page 3
6.We note your disclosure in the last paragraph on page 3 that purchases and sales of the
Trust's Solana may be facilitated through the Prime Execution Agent, an affiliate of
the Solana Custodian. Please revise in an appropriate section of the prospectus to
describe the potential conflicts of interest associated with such an arrangement and the
impact it may have on price.
The Trust's Fees and Expenses, page 5
7.We note your disclosure on page 6 that transfer fees with respect to on-chain transfers
to and from a Trust Solana Account to a Solana Trading Counterparty, an Authorized
Participant or an Authorized Participant Designee will be paid by the Solana
Custodian. Please revise to clarify whether the Solana Custodian will pay such
transfer fees using the Trust's assets.
We note your disclosure on pages 6 and 86 that:
•the Trust is not responsible for paying any fees or costs associated with the
transfer of Solana to the Sponsor; and
"[t]he Trust may incur certain extraordinary, non-recurring expenses that are not •8.

July 3, 2025
Page 3
assumed by the Sponsor, including, but not limited to,... Solana Network fees."
Please revise to clarify when the Trust is responsible for paying Solana Network fees.
Risk Factors
Solana is a relatively new technological innovation with a limited operating history, page 19
9.To provide context for this risk, please specifically state how long Solana has been
traded, and how long it has been traded in the United States.
The Solana Network could be vulnerable to attacks..., page 29
10.Please expand this risk factor to discuss any risks from other potential forms of attack
against the Solana Network, including, for example, "the significant disruption, later
attributed to a type of denial of service attack," that the Solana Network experienced
on September 14, 2021, as disclosed on page 74 under "Forms of Attack Against the
Solana Network."
Staking activities subject the Trust to risks..., page 41
11.On page 42, you disclose that the Trust "intends to manage liquidity by maintaining a
portion of its Solana in an unstaked, freely transferable form" and the Trust may "rely
on alternative liquidity arrangements." In an appropriate section of the prospectus,
please revise to disclose the material terms of any policies and procedures you have in
place to manage liquidity in this regard. Please also describe in greater detail the risks
posed to an effective arbitrage mechanism.
Possible illiquid markets may exacerbate losses or increase..., page 49
12.To provide context for this risk, please provide quantitative disclosure discussing the
size and liquidity of the Solana market, and compare the size and liquidity of the
Solana market to that of crypto assets that underlie other currently available exchange
traded products.
The IRS may disagree with or seek to challenge the Trust's treatment as a grantor trust, page
57
13.Please revise this risk factor to describe in greater detail the reasons for the
uncertainty associated with the Sponsor's position that the Trust is properly treated as
a grantor trust. Please also describe the consequences to the Trust and its shareholders
if the Trust does not qualify as a grantor trust.
Solana, Solana Market and Regulation of Solana
Solana Market and Solana Digital Asset Trading Platforms, page 72
14.Please revise to add a brief discussion of the Solana futures markets.
The Trust and Solana Prices
Staking, page 77
We note your disclosure that, "Under the Staking Agreement, the Staking Agent is
entitled to a percentage of the staking rewards generated by the Trust's staking
program. In addition, the Sponsor may be entitled to receive a percentage of the 15.

July 3, 2025
Page 4
staking rewards generated by the Trust's staking program." Please address the
following in your next amendment or response letter, as applicable:
•Revise to disclose in greater detail the material terms of the Staking Agreement.
Please provide quantified disclosure regarding the percentages of the staking
rewards to which the parties (i.e., the Trust, the Sponsor and the Staking Agent)
are entitled and/or an explanation of how such amounts are determined. Also,
please disclose the term of the agreement and the termination provisions thereof,
as applicable.
•Revise to disclose the circumstances under which the Sponsor "may" be entitled
to receive a percentage of the staking rewards, as you state.
•Revise to identify the Staking Agent, or tell us when you intend to do so.
Pricing Benchmark Methodology, page 80
16.We note your disclosure on page 82 that the Benchmark Provider data is used under
license as a source of information for the Trust's products. When available, please
disclose the material terms of any license agreement that the Benchmark Provider and
the Sponsor have entered into, including the obligations of each party and the term
and termination provisions. Please also file the agreement as an exhibit to your
registration statement if required by Item 601 of Regulation S-K.
Calculation of NAV, page 83
17.Please revise to disclose whether the Sponsor has agreements with any third parties
for use of their valuation methods, and disclose whether the Sponsor has a license to
use a secondary index. If so, please identify the third parties and the secondary index
and describe how the value of Solana is calculated by the valuation methods of such
third parties and the secondary index.
Custody of the Trust's Assets, page 92
18.You disclose that the Solana Custodian will keep a "substantial portion" of the private
keys associated with the Trust's Solana in cold storage or "similarly secure
technology" with any remainder held in a Hot Solana Account. Please revise to
disclose the percentage of the Solana that is held in cold storage and describe the
"similarly secure technology" used to hold the private keys.
Creation and Redemption of Shares, page 103
19.Please revise to disclose whether any costs or transaction fees associated with
creations and redemptions are payable by the Trust.
20.Please revise to identify the Authorized Participants that have Authorized Participant
Agreements that allow for only cash, only in-kind, and both cash and in-kind creations
and redemptions.
Creation Procedures, page 104
21.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 Solana acquired.

July 3, 2025
Page 5
Conflicts of Interest, page 108
22.Please revise this section to address any potential conflicts of interest between the
Trust and the Prime Execution Agent, the Trade Credit Lender and the Solana Trading
Counterparties, as applicable.
Governing Law; Consent to Delaware Jurisdiction, page 114
23.We note the statement on page 114 that each Shareholder consents "to the exclusive
jurisdiction of the courts of the State of Delaware and any federal courts located in
Delaware" and that, pursuant to the Trust Agreement, such clause "shall not apply to
causes of action for violations of U.S. federal or state securities laws." Please direct us
to the portion of the Trust Agreement that contains these provisions.
            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 Kate Tillan at 202-551-3604 or Mark Brunhofer at 202-551-3638 if
you have questions regarding comments on the financial statements and related
matters. Please contact David Lin at 202-551-3552 or Justin Dobbie at 202-551-3469 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets
cc:Richard Coyle

December 4, 2024
Hunter Horsley
President
Bitwise Solana ETF
c/o Bitwise Investment Advisers, LLC
250 Montgomery Street, Suite 200
San Francisco, CA 94104
Re:Bitwise Solana ETF
Registration Statement on Form S-1
Filed November 21, 2024
File No. 333-283391
Dear Hunter Horsley:
            We have reviewed your registration statement and have the following comment.
Registration Statement on Form S-1
General
1.You state that the investment objective of the Trust is to provide exposure to the price
of Solana and that you will meet the objective by holding Solana. The Commission
has stated that Solana is offered and sold as a security under the federal securities
laws. In that regard, we refer you to the complaints filed by the Commission against
Binance Holdings Limited, BAM Trading Services Inc., BAM Management US
Holdings Inc. and Changpeng Zhao, Coinbase, Inc. and Coinbase Global, Inc., and
Payward, Inc. and Payward Ventures, Inc. Therefore, the Trust appears to meet the
definition of an investment company under the Investment Company Act of 1940.
Please file a request for withdrawal of the registration statement.

December 4, 2024
Page 2
            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.
            Please contact Sonia Bednarowski at 202-551-3666 or Sandra Hunter Berkheimer at
202-551-3758 with any questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets