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 21shares
us llc

 477 Madison Avenue, 6 th Floor

 New York, NY 10022

 VIA EDGAR

 December 9, 2025

 Division of Corporation Finance

 Office of Crypto Assets

 Securities and Exchange Commission

 Division of Investment Management

 100 F Street, N.E.

 Washington, D.C. 20549

 Re: 21Shares
 XRP ETF

 Amendment No.5 to Registration Statement
 on Form S-1

 Filed December 8, 2025

 SEC File No. 333-282942

 To Whom It May Concern:

 Pursuant to Rule 461 under the Securities Act of 1933,
as amended, 21Shares XRP ETF (the "Registrant") hereby requests that the effective date of the above-referenced Registration
Statement, as amended, (the "Registration Statement") be accelerated so that the Registration Statement may become effective
no earlier than 5:00 p.m., Eastern Time, on December 10, 2025, or as soon as practicable thereafter.

 The Registrant requests that notification of such
effectiveness be made by telephone call to Allison Fumai and Anna Tomczyk of Dechert LLP, legal counsel to the Registrant, at 212-698-3526
and 212-641-5626, respectively.

 Very truly yours,

 21shares XRP etf

 21Shares US LLC, as Sponsor of the Trust

 By:
 /s/ Duncan Moir

 Name:
 Duncan Moir

 Title:
 President

 * The registrant
is a trust, and the person is signing in his capacity as officer of 21Shares US LLC, the Sponsor of the registrant.

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 VIA EDGAR

 December 8, 2025

 Division of Corporation Finance

 Office of Crypto Assets
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549

 Re:
 21Shares XRP ETF

 Amendment No. 5 to Registration Statement on Form S-1

 Filed December 8, 2025

 File No. 333-282942

 To Whom it May Concern:

 On behalf of 21Shares XRP ETF (the " Trust "),
submitted herewith via the EDGAR system are the Trust's responses to the comments of the staff of the Office of Crypto Assets of
the Division of Corporation Finance (the " Staff ") of the Securities and Exchange Commission (the " SEC ")
that the Staff provided in correspondence dated December 5, 2025 with respect to the Trust's registration statement on Form S-1,
as amended (the " Registration Statement "), filed on November 20, 2025.

 For your convenience, we have restated your comments
below followed by our responses. Capitalized terms used but not defined in this letter have the meaning given to them in Amendment No. 5
to the Registration Statement filed by the Trust on the date hereof (such registration statement being referred to herein as the " Pre-Effective
Amendment "). We have incorporated any changes referenced below into the Pre-Effective Amendment.

 Comment 1 : General: We note your disclosure on pages 88 and
95 that on December 17, 2024, the Trust issued to Ripple Markets 10,000,000 Shares in exchange for 100,000,000 XRP. Please expand your
disclosure to convert the aggregate purchase price of 100,000,000 XRP into USD on an aggregate and per share basis. Please also provide
disclosure regarding this sale in the prospectus summary and under Recent Sales of Unregistered Securities as required by Item
701 of Regulation S-K. In addition, please disclose in your summary any relationship or affiliation between Ripple Markets and Ripple
Labs and revise your beneficial ownership disclosure on page 95 to identify the natural person(s) with voting and dispositive control
over the shares held by Ripple Markets and to disclose a business, mailing or residence address as required by Item 403(a) of Regulation
S-K.

 Response : With respect to the Staff's
comment, the Trust advises the Staff that the Trust has (i) revised disclosure on page 88 of the Pre-Effective Amendment to disclose
the purchase price of the Shares acquired by Ripple Markets on an aggregate and per Share USD basis; (ii) disclosed such sale in the Prospectus
Summary section on page 9 of the Pre-Effective Amendment under the caption "Prospectus Summary" and on page II-1 of the
Pre-Effective Amendment under the caption "Recent Sales of Unregistered Securities"; and (iii) revised page 95 of the Pre-Effective
Amendment to identify the person with voting and dispositive control over the shares held by Ripple Markets as well as to disclose the
affiliation between Ripple Markets and Ripple Labs.

 Comment 2: XRP, XRP Markets and Regulation
of XRP, page 58: We note your various references to bitcoin in describing XRP and the XRP Ledger in this section. Please add disclosure
comparing the aggregate value of outstanding XRP to that of bitcoin.

 Response: With respect to the Staff's
comment, the Trust advises the Staff that has revised page 58 of the Pre-Effective Amendment to disclose the aggregate value of outstanding
XRP and bitcoin relative to one another.

 Comment 3: Notes to the Financial Statements,
Note 4. Trust Expenses, page F-11: You disclose here that the Sponsor Fee of 0.25% per annum is accrued daily and paid in XRP. On pages
6 and 74, you indicate that the Sponsor Fee is 0.50%, accrued daily and pay able
in XRP weekly in arrears. Please address the following:

 ● Please
 reconcile for us the inconsistency between the 0.25% and 0.50% disclosed; and

 ● It
 app ears that the Sponsor
 Fees recorded were significantly greater than the annual rates disclosed. Please clarify
 for us what the historical rate was and when the rate changed or will change.

 Response: With respect to the
Staff's comment, the Trust advises the Staff that the Trust has revised page F-11 of the Pre-Effective Amendment to correct a
previous clerical error that reflected the Sponsor Fee rate at 0.25% instead of 2.50%. The Trust further advises the Staff that the
Trust has revised pages 6 and 74 of the Pre-Effective Amendment to reflect the Sponsor Fee rate applicable to the Trust as a public
trust will be 0.30%. The Trust advises the Staff that the 2.50% Sponsor Fee Rate disclosed in the F-pages to the Pre-Effective
Amendment is only applicable to the Trust's operations while a private trust and that the 0.30% Sponsor Fee rate will be
applicable to the Trust starting on the date that the Trust becomes a publicly traded trust.

 Should members of the Staff have any questions
or comments concerning this letter, please call the undersigned at 212-698-3526.

 Sincerely,

 /s/ Allison M. Fumai

 Allison M. Fumai, Esq.

 Dechert LLP

December 5, 2025
Duncan Moir
President
21Shares XRP ETF
c/o 21Shares US LLC
477 Madison Avenue, 6th Floor
New York, NY 10022
Re:21Shares XRP ETF
Amendment No. 4 to Registration Statement on Form S-1
Filed November 20, 2025
File No. 333-282942
Dear Duncan Moir:
            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 September 18, 2025
letter.
Amendment No. 4 to Registration Statement on Form S-1
General
We note your disclosure on pages 88 and 95 that on December 17, 2024, the Trust
issued to Ripple Markets 10,000,000 Shares in exchange for 100,000,000 XRP. Please
expand your disclosure to convert the aggregate purchase price of 100,000,000 XRP
into USD on an aggregate and per share basis. Please also provide disclosure
regarding this sale in the prospectus summary and under Recent Sales of Unregistered
Securities  as required by Item 701 of Regulation S-K. In addition, please disclose in
your summary any relationship or affiliation between Ripple Markets and Ripple Labs
and revise your beneficial ownership disclosure on page 95 to identify the natural 1.

December 5, 2025
Page 2
person(s) with voting and dispositive control over the shares held by Ripple Markets
and to disclose a business, mailing or residence address as required by Item 403(a) of
Regulation S-K.
XRP, XRP Markets and Regulation of XRP, page 58
2.We note your various references to bitcoin in describing XRP and the XRP Ledger in
this section. Please add disclosure comparing the aggregate value of outstanding XRP
to that of bitcoin.
Notes to the Financial Statements
Note 4. Trust Expenses, page F-11
3.You disclose here that the Sponsor Fee of 0.25% per annum is accrued daily and paid
in XRP. On pages 6 and 74, you indicate that the Sponsor Fee is 0.50%, accrued daily
and payable in XRP weekly in arrears. Please address the following:
•Please reconcile for us the inconsistency between the 0.25% and 0.50% disclosed
rates.
•It appears that the Sponsor Fees recorded were significantly greater than the
annual rates disclosed. Please clarify for us what the historical rate was and when
the rate changed or will change.
            Please contact David Irving at 202-551-3321 or Mark Brunhofer at 202-551-3638 if
you have questions regarding comments on the financial statements and related
matters. Please contact Irene Paik at 202-551-6553 or Justin Dobbie at 202-551-3469 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets
cc:Allison Fumai

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 VIA EDGAR

 November 20, 2025

 Division of Corporation Finance

 Office of Crypto Assets
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549

 Re:
 21Shares XRP ETF

 Amendment No. 2 to Registration Statement on Form S-1

 Filed October 10, 2025

 File No. 333-282942

 To Whom it May Concern:

 On behalf of 21Shares XRP ETF (the " Trust "),
submitted herewith via the EDGAR system are the Trust's supplemental responses to the correspondence filed on October 10, 2025.
The correspondence was filed in response to the comments of the staff of the Office of Crypto Assets of the Division of Corporation Finance
(the " Staff ") of the Securities and Exchange Commission (the " SEC ") that the Staff provided in correspondence
dated September 18, 2025 with respect to the Trust's registration statement on Form S-1, as amended (the " Registration
Statement "), filed on August 22, 2025.

 For your convenience, we have restated your comments
below followed by our responses. Capitalized terms used but not defined in this letter have the meaning given to them in Amendment No. 4
to the Registration Statement filed by the Trust on the date hereof (such registration statement being referred to herein as the " Pre-Effective
Amendment "). We have incorporated any changes referenced below into the Pre-Effective Amendment.

 With Respect to the Staff's Correspondence
dated September 18, 2025:

 Comment 8 : United States Federal
Income Tax Consequences, page 104: We note that you discussion of tax consequences is based on the assumption that the Fund will be
treated as a grantor trust for U.S. federal income tax purposes. Please revise to provide an opinion of counsel as to grantor trust
status and describe the reasons for and level of any uncertainty, if applicable.

 Response : With respect to the Staff's comment, the Trust
supplementarily advises the Staff that it has further revised disclosure on Page 110 of the Pre-Effective Amendment and has filed as
Exhibit 8.1 to the Pre-Effective Amendment a Tax Opinion of Dechert LLP.

 Should members of the Staff have any questions
or comments concerning this letter, please call the undersigned at 212-698-3526.

 Sincerely,

 /s/ Allison M. Fumai

 Allison M. Fumai, Esq.

 Dechert LLP

CORRESP
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VIA EDGAR

October 10, 2025

Division of Corporation Finance

Office of Crypto Assets

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

    Re:
    21Shares XRP ETF

    Amendment No. 1 to Registration Statement on Form S-1

    Filed August 22, 2025

    File No. 333-282942

To Whom it May Concern:

On behalf of 21Shares XRP ETF (the “Trust”),
submitted herewith via the EDGAR system are the Trust’s responses to the comments of the staff of the Office of Crypto Assets of
the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”)
that the Staff provided in correspondence dated September 18, 2025 with respect to the Trust’s registration statement on Form
S-1, as amended (the “Registration Statement”), filed on August 22, 2025.

For your convenience, we have restated your comments
below followed by our responses. Capitalized terms used but not defined in this letter have the meaning given to them in Amendment No. 2
to the Registration Statement filed by the Trust on the date hereof (such registration statement being referred to herein as the “Pre-Effective
Amendment”). We have incorporated any changes referenced below into the Pre-Effective Amendment.

General

Comment 1: To the extent that you intend
to use a fact sheet, please provide us with a copy for our review.

Response: With respect to the Staff’s comment, the Trust
confirms that it is not currently using a fact sheet, but in the event the Trust does use one, it will provide the fact sheet supplementary
to the Staff.

Cover Page

Comment 2: Please disclose the price per
share that will be paid by the Initial Seed Creation Investor for the Initial Seed Creation Baskets.

Response: With respect to the Initial Seed Creation Baskets,
the Trust has not yet identified the price per share that will be paid by the Initial Seed Creation Investor but will do so in a subsequent
filing.

Risk Factors, page 13

Comment 3: Under an appropriately captioned
risk factor heading, please address the April 2025 malware attack on the JavaScript library for the XRP Ledger.

Response: With respect to the Staff’s
comment, the Trust has revised the disclosure on page 33 of the Pre-Effective Amendment to provide disclosure relating to the April 2025
JavaScript Library malware attack.

The significant holdings of XRP by Ripple
Labs and other early stakeholders, page 15

Comment 4: Please revise to discuss, to
the extent material, any of the founders or early stakeholders who hold significant stake in XRP, including, for example, Chris Larsen.

Response: With respect to the Staff’s comment, the Trust has revised the
disclosure on page 15 of the Pre-Effective Amendment to provide additional disclosure relating to the founders and early stakeholders
of XRP who hold significant stakes in XRP, including Mr. Chris Larsen.

The trading prices of many digital assets,
page 17

Comment 5: Please revise to provide quantitative
examples of XRP’s historic volatilities.

Response: With respect to the Staff’s comment, the Trust has revised the
disclosure on page 17 of the Pre-Effective Amendment to provide quantitative examples of historical volatilities in XRP’s market
price.

XRP, XRP Markets and Regulation of XRP,
page 57

Comment 6: Please revise this section to
address the following:

 · Further discuss the background of, and the roles and functions of Ripple Labs and the XRP Ledger Foundation
within the XRP ecosystem.

 · Disclose the nature and number of decentralized applications developed on the XRP ledger, as well as active
developers, to the extent known.

Response: With respect to the Staff’s comment, the Trust has revised the
disclosure on page 58 of the Pre-Effective Amendment to provide greater disclosure surrounding the roles and functions of Ripple Labs
and the XRP Ledger Foundation. The Trust has also revised disclosure on page 59 of the Pre-Effective Amendment to provide enhanced disclosure
about the nature and scope of decentralized applications developed on the XRP Ledger.

The Trust and XRP Prices – Use of
the CME CF Ripple – Dollar Reference Rate – New York Variant, page 65

Comment 7: Please revise to provide a brief
description of each of the Constituent Exchanges comprising the Pricing Benchmark, including where each platform is located and how they
are licensed or regulated.

Response: With respect to the Staff’s comment, the Trust has revised the
disclosure on page 68 of the Pre-Effective Amendment to provide greater disclosure as to each of the Constituent Exchanges comprising
the Pricing Benchmark, including where they’re located and how each is licensed or regulated.

    2

United States Federal Income Tax Consequences,
page 104

Comment 8: We note that you discussion
of tax consequences is based on the assumption that the Fund will be treated as a grantor trust for U.S. federal income tax purposes.
Please revise to provide an opinion of counsel as to grantor trust status and describe the reasons for and level of any uncertainty, if
applicable.

Response: With respect to the Staff’s comment, the Trust respectfully advises
the Staff that it has existing disclosure on page 107 of the Pre-Effective Amendment, which has been reproduced below (emphasis added):

“The following discussion describes
the material U.S. federal income tax consequences associated with the purchase, ownership and disposition of Shares by a U.S. Shareholder,
and certain U.S. federal income consequences that may apply to an investment in Shares by a Non-U.S. Shareholder. The discussion
represents, insofar as it describes conclusions as to U.S. federal income tax law and subject to the limitations and qualifications
described below, the opinion of Dechert LLP. The opinion of Dechert LLP, however, is not binding on the United States Internal
Revenue Service (the “IRS”) or on the courts, and does not preclude the IRS from taking a contrary position.”

Should members of the Staff have any questions
or comments concerning this letter, please call the undersigned at 212-698-3526.

    Sincerely,

    /s/ Allison M. Fumai

    Allison M. Fumai, Esq.

    Dechert LLP

3

September 18, 2025
Duncan Moir
President
21Shares XRP ETF
c/o 21Shares US LLC
477 Madison Avenue, 6th Floor
New York, NY 10022
Re:21Shares XRP ETF
Amendment No. 1 to Registration Statement on Form S-1
Filed August 22, 2025
File No. 333-282942
Dear Duncan Moir:
            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.To the extent that you intend to use a fact sheet, please provide us with a copy for our
review.
Cover Page
2.Please disclose the price per share that will be paid by the Initial Seed Creation
Investor for the Initial Seed Creation Baskets.
Risk Factors, page 13
3.Under an appropriately captioned risk factor heading, please address the April 2025
malware attack on the JavaScript library for the XRP Ledger.

September 18, 2025
Page 2
The significant holdings of XRP by Ripple Labs and other early stakeholders, page 15
4.Please revise to discuss, to the extent material, any of the founders or early
stakeholders who hold a significant stake in XRP, including, for example, Chris
Larsen.
The trading prices of many digital assets, page 17
5.Please revise to provide quantitative examples of XRP's historic volatilities.
XRP, XRP Markets and Regulation of XRP, page 57
6.Please revise this section to address the following:
•Further discuss the background of, and the roles and functions of Ripple Labs and
the XRP Ledger Foundation within the XRP ecosystem.
•Disclose the nature and number of decentralized applications developed on the
XRP Ledger, as well as active developers, to the extent known.
The Trust and XRP Prices
Use of the CME CF Ripple - Dollar Reference Rate - New York Variant, page 65
7.Please revise to provide a brief description of each of the Constituent Exchanges
comprising the Pricing Benchmark, including where each platform is located and how
they are licensed or regulated.
United States Federal Income Tax Consequences, page 104
8.We note that your discussion of tax consequences is based on the assumption that the
Fund will be treated as a grantor trust for U.S. federal income tax purposes. Please
revise to provide an opinion of counsel as to grantor trust status and describe the
reasons for and level of any uncertainty, if applicable.
            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.

September 18, 2025
Page 3
            Please contact David Irving at 202-551-3321 or Mark Brunhofer at 202-551-3638 if
you have questions regarding comments on the financial statements and related
matters. Please contact Lulu Cheng at 202-551-3811 or Sandra Hunter Berkheimer at 202-
551-3758 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets
cc:Neel Maitra

November 8, 2024
Ophelia Snyder
President
21Shares Core XRP Trust
477 Madison Avenue, 6th Floor
New York, NY 10022
Re:21Shares Core XRP Trust
Registration Statement on Form S-1
Filed November 1, 2024
File No. 333-282942
Dear Ophelia Snyder:
            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 reflect the performance of the
price of XRP and that you will meet the objective by holding XRP. The Commission
has stated that XRP is offered and sold as a security under the federal securities laws.
In that regard, we refer you to the complaint filed by the Commission in SEC v. Ripple
Labs, Inc., No. 20-cv10832 (S.D.N.Y.), and the Commission’s pending appeal in SEC
v. Ripple Labs Inc., No. 24- 2648 (2d Cir.). 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.

November 8, 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 Justin Dobbie at 202-551-3469 with any questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets
cc:Allison M. Fumai, Esq.