SecProbe.io

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 1
 filename1.htm

 21shares us llc

 477 Madison Avenue, 6 th
Floor

 New York, NY 10022

 VIA EDGAR

 November 17, 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 Solana ETF

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

 Filed November 17, 2025
SEC File No. 333-280557

 To Whom It May Concern:

 Pursuant to Rule 461 under the Securities Act
of 1933, as amended, 21Shares Solana 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 November 17, 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 SOLANA 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 her
capacity as officer of 21Shares US LLC, the Sponsor of the registrant.

CORRESP
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 filename1.htm

 VIA EDGAR

 November 17, 2025

 Division of Corporation Finance

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

 Re:
 21Shares Solana ETF

 Amendment No. 2 and Amendment No. 3 to Registration Statement on Form S-1

 Filed July 30, 2025 and August 29, 2025

 File No. 333-280557

 To Whom it May Concern:

 On behalf of 21Shares Solana ETF (the " Trust "),
submitted herewith via the EDGAR system are the Trust's supplemental responses to the correspondence filed on August 29, 2025 and
September 29, 2025. Each 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 August 15, 2025 and September 12, 2025 with respect to the Trust's registration
statement on Form S-1, as amended (the " Registration Statement "), filed on July 30, 2025 and August 29, 2025, respectively.

 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.

 With Respect to the Staff's Correspondence
dated August 15, 2025:

 Comment 3 : We note your disclosure that
you may seek to use or hold liquid staking tokens. To the extent you intend to list your shares under the exchange's proposed generic
listing standards, please tell us why you believe you are permitted to hold liquid staking tokens. Otherwise, please revise to remove
references to using or holding liquid staking tokens or to clarify that they are not a permissible holding.

 Response : With respect to the Staff's
comment, the Trust supplementarily advises the Staff that it has revised the disclosure on pages 1 and 3 of the Pre-Effective Amendment
to remove references to using or holding liquid staking tokens.

 With Respect to the Staff's Correspondence
dated September 12, 2025:

 Comment 6 : United States Federal Income Tax Consequences, page
121: We note that your discussion of tax consequences is based on the assumption that the Trust will be treated as a grantor trust for
U.S. federal income tax purposes. Please revise to provide an opinion as to the tax consequences and describe the reasons for and level
of any uncertainty associated with grantor trust status.

 Response : With respect to the Staff's comment, the Trust
supplementarily advises the Staff that it has further revised disclosure on Page 130 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

September 26, 2025

Division of Corporation Finance

Office of Crypto Assets

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

    Re:
    21Shares Solana ETF

    Amendment No. 3 to Registration Statement on Form S-1

    Filed August 29, 2025

    File No. 333-280557

To Whom it May Concern:

On behalf of 21Shares Solana 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 12, 2025 with respect to the Trust’s registration statement on Form
S-1, as amended (the “Registration Statement”), filed on August 29, 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.

General

Comment 1: We note the revisions you made
in response to prior comment 1 regarding the Trust’s staking model. Please revise to address the following:

 ● Disclose the percentage of the
overall rewards amount, or the Staking Provider Consideration, that will be paid to Coinbase Crypto Services, LLC, under the Staking
Services Agreement.

 ● Disclose when rewards from staking
will be shared, distributed, or added to the assets of the Trust.

Response: With respect to the Staff’s comment, the Trust
has revised the disclosure on pages 5 and 97 of the Pre-Effective Amendment.

Comment 2: We note your response to prior
comment 1. Under an appropriately captioned heading, 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 confirm and revise your disclosure accordingly.

Response: With respect to the Staff’s comment, the Trust
has revised the disclosure on page 97 of the Pre-Effective Amendment.

Comment 3: We note your disclosure that
you may seek to use or hold liquid staking tokens. To the extent you intend to list your shares under the exchange’s proposed generic
listing standards, please tell us why you believe you are permitted to hold liquid staking tokens. Otherwise, please revise to remove
references to using or holding liquid staking tokens or to clarify that they are not a permissible holding.

Response: The Trust respectfully advises the Staff that it believes it is permitted
to hold liquid staking tokens for the following reasons:

 1. Liquid Staking Tokens are Not Securities or Derivatives

First, the Staff has clarified in its Statement
release entitled “Statement on Certain Liquid Staking Activities” that liquid staking tokens are receipts for the underlying
crypto assets deposited for staking. As such, these liquid staking tokens (or, in the Staff’s preferred usage, the “Staking
Receipt Tokens”) are not securities under Section 2(a)(1) of the Securities Act of 1933, as amended, or under Section 3(a)(10) of
the Securities Exchange Act of 1934, as amended. Nor are the Staking Receipt Tokens any of the derivatives specifically enumerated in
the definition of “security” in either of those provisions.

Second, a Staking Receipt Token is a receipt,
which is an instrument certifying that a stated amount of SOL has been deposited with the liquid staking provider issuing the receipt,
because it evidences the holder’s ownership of the deposited SOL. But a Staking Receipt Token is not a receipt for a security
because the deposited SOL is not a security.

Third, based on the Staff’s statement
on protocol staking, since the staking of SOL does not result in the creation or offering of a security, the Trust may stake its SOL.
Based on the Staff’s statement on liquid staking, the Trust may also engage in liquid staking of its staked SOL, since the Staking
Receipt Tokens are merely receipts representing beneficial ownership of the underlying staked SOL.

 2. The Trust Can Hold/Use Liquid Staking Tokens Consistent With the Exchange’s Generic Listing Standards

Under Cboe BZX Exchange, Inc.’s (the
“Exchange”) generic listing standards, as approved by the SEC, the Trust may engage in both the staking and liquid
staking of SOL.

In accordance with the generic listing standards,
the Trust holds SOL, a commodity, on the basis of which the Trust issues Commodity-Based Trust Shares in accordance with the Exchange’s
rules. SOL, the commodity held by the Trust, underlies a futures contract that has been made available to trade on a designated contract
market (“DCM”) for at least six months; and the Exchange has a comprehensive surveillance sharing agreement, whether directly
or through common membership in Intermarket Surveillance Group, with such DCM.

The proposed generic listing standards for
Commodity-Based Trust Shares generally provide that, if a trust has on a daily basis less than 85% of its assets readily available to
meet redemption requests, the trust must have written liquidity risk policies and procedures reasonably designed to address the risk that
it could not meet requests to redeem shares issued by the trust without significant dilution of remaining shareholders’ interest
in the trust.

The Trust meets these generic listing standards.
The Trust has written liquidity risk policies and procedures reasonably designed to address the redemption risks specified in the generic
listing standards. In accordance with the generic listing standards, those liquidity policies address:

 (i) The Trust’s investment strategy and liquidity of the Trust’s assets during normal and stressed conditions, including holdings
in derivatives and whether the investment strategy is appropriate for effective and efficient arbitrage;

 (ii) Holdings of cash and cash equivalents, as well as borrowing arrangements and other funding sources; and

 (iii) The percentage and description of the Trust’s assets that are segregated, pledged, hypothecated, encumbered, or otherwise restricted
or prevented from being liquidated, sold, transferred, or assigned.

The Staking Receipt Tokens enhance the liquidity of the underlying
staked SOL, rather than encumbering or restricting the underlying SOL from being liquidated, sold, transferred, or assigned within one
business day.

Accordingly, the Sponsor believes that the Trust can use and/or hold
liquid staking tokens consistent with the Exchange’s generic listing guidelines.

    2

Prospectus Summary – The Trust’s
Investment Objective, page 3

Comment 4: We note your revised disclosure
here in response to comment 1 that while the Trust may stake a maximum of 100% of its SOL holdings, the precise percentage to be staked
will be based on the estimated liquidity needs of the Trust and other factors, as determined by the Sponsor. Please revise to quantify
the percentage of the Trust’s SOL you intend to stake under normal circumstances in light of the liquidity needs and other factors you
identify in your disclosure, or tell us why you are unable to do so. Please also 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: With respect to the Staff’s
comment, the Trust has revised the disclosure on pages 4, 29 and 97.

The Trust and SOL Prices – Overview
of the Trust, page 82

Comment 5: We note the revisions you made
on page 28 in response to prior comment 4 and we reissue the comment. Refer to your disclosure that staked SOL is temporarily locked and
inaccessible during the bonding and unbonding periods. Please revise here to disclose with specificity the bonding and unbonding periods
associated with staking SOL, discuss how they affect liquidity and disclose the material terms of any policies and procedures you have
in place to manage liquidity and maintain effective arbitrage in light of any staking program you undertake.

Response: The Trust respectfully advises
the Staff that it has existing disclosure on page 28 of the Pre-Effective Amendment regarding the unbonding period associated with staking
SOL (“The historical average unbonding period for staked SOL was 2-4 days, with the epoch length decreasing over the last year
to below 2 days. However, the unbonding period also may be longer than anticipated based on network activity.”). With respect to
the Staff’s comment, the Trust has revised the disclosure on pages 5, 28 and 82 of the Pre-Effective Amendment.

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 12, 2025
Duncan Moir
President
21Shares Core Solana ETF
c/o 21Shares US LLC
477 Madison Avenue, 6th Floor
New York, NY 10022
Re:21Shares Core Solana ETF
Amendment No. 3 to Registration Statement on Form S-1
Filed August 29, 2025
File No. 333-280557
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 August 15, 2025 letter.
Amendment No. 3 to Draft Registration Statement on Form S-1
General
1.We note the revisions you made in response to prior comment 1 regarding the Trust's
staking model. Please revise to address the following:
•Disclose the percentage of the overall rewards amount, or the Staking Provider
Consideration, that will be paid to Coinbase Crypto Services, LLC, under
the Staking Services Agreement.
•Disclose when rewards from staking will be shared, distributed, or added to the
assets of the Trust.

September 12, 2025
Page 2
2.We note your response to prior comment 1. Under an appropriately captioned
heading, 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 confirm
and revise your disclosure accordingly.
3.We note your disclosure that you may seek to use or hold liquid staking tokens. To the
extent you intend to list your shares under the exchange's proposed generic listing
standards, please tell us why you believe you are permitted to hold liquid staking
tokens.  Otherwise, please revise to remove references to using or holding liquid
staking tokens or to clarify that they are not a permissible holding.
Prospectus Summary
The Trust's Investment Objective, page 3
4.We note your revised disclosure here in response to comment 1 that while the Trust
may stake a maximum of 100% of its SOL holdings, the precise percentage to be
staked will be based on the estimated liquidity needs of the Trust and other factors, as
determined by the Sponsor. Please revise to quantify the percentage of the Trust's
SOL you intend to stake under normal circumstances in light of the liquidity needs
and other factors you identify in your disclosure, or tell us why you are unable to do
so. Please also 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.
The Trust and SOL Prices
Overview of the Trust, page 82
5.We note the revisions you made on page 28 in response to prior comment 4 and we
reissue the comment. Refer to your disclosure that staked SOL is temporarily locked
and inaccessible during the bonding and unbonding periods. Please revise here to
disclose with specificity the bonding and unbonding periods associated with staking
SOL, discuss how they affect liquidity and disclose the material terms of any policies
and procedures you have in place to manage liquidity and maintain effective arbitrage
in light of any staking program you undertake.
            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 David Gessert at 202-551-2326 or Sandra Hunter Berkheimer at 202-
551-3758 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets
cc:Allison M. Fumai, Esq.

CORRESP
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VIA EDGAR

August 29, 2025

Division of Corporation Finance

Office of Crypto Assets

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

    Re:
    21Shares Solana ETF

    Registration Statement on Form S-1

    Filed July 30, 2025

    File No. 333-280557

To Whom it May Concern:

On behalf of 21Shares Solana 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 August 15, 2025 with respect to the Trust’s registration statement on Form S-1,
as amended (the “Registration Statement”), filed on July 30, 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.
3 to the Registration Statement filed by the Company 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: Please revise your disclosure to clarify if
the Trust plans to stake its SOL when the product launches. In addition, and if so, please revise to:

 a. Provide a materially complete description of your planned
staking program, policies and procedures;

 b. Disclose the percentage of the Trust's SOL to be staked;

 c. Include the material terms of any agreements with Staking
Providers and summarize the responsibilities and duties of the Staking Providers. Refer to Item 601(b)(10) of Regulation S-K and file
your material agreement(s) with Staking Providers as an exhibit to your registration statement;

 d. Disclose how and when rewards from staking will be shared,
distributed, or added to the assets of the Trust and how this will work; and

 e. Disclose any policies with respect to the use of proceeds
from staking rewards and quantify the portion of staking rewards that all involved parties will receive.

Please also confirm your understanding that we may have additional
comments upon review of a materially complete description of your staking program. In addition, to the extent your liquidity risk policies
and procedures for your staking program are intended to be consistent with the exchange's proposed generic listing standards, please revise
your disclosure accordingly.

Response: With respect to the Staff’s comment, the
Trust has revised disclosure on pages 5 and 97 of the Pre-Effective Amendment. The Trust confirms its understanding that the Staff may
have additional comments upon review of a materially complete description of the Trust’s staking program.

Comment 2: General: We note your disclosure
that the Sponsor may "seek to utilize alternative means to engage in Staking Activities." Please revise to disclose the "alternative
means" to which you are referring in addition to liquid staking tokens.

Response: With respect to the Staff’s comment, the Trust
has revised disclosure on the cover page of the prospectus included in the Pre-Effective Amendment in addition to pages 1 and 3 thereof.

Comment 3: Prospectus Summary: The Staking
Services Provider, page 8: We note your disclosure that the Sponsor plans to engage one or more third party Staking Services Providers.
To the extent the Trust engages additional Staking Services Providers, please revise to discuss the factors that will be used to determine
how much SOL to allocate among multiple Staking Services Providers.

Response: With respect to the Staff’s comment, the Trust
has revised disclosure on the cover page of the prospectus included in the Pre-Effective Amendment in addition to pages 1 and 3 thereof.

Comment 4: The Trust and SOL Prices: Overview of the Trust, page
80: We note your disclosure that staked SOL is temporarily locked and inaccessible during the bonding and unbonding periods. Please revise
to disclose with specificity the bonding and unbonding periods associated with staking SOL, discuss how they affect liquidity and disclose
the material terms of any policies and procedures you have in place to manage liquidity and maintain effective arbitrage in light of any
staking program you undertake.

Response: With respect to the Staff’s comment, the Trust
has revised disclosure on page 28 of the Pre-Effective Amendment.

Comment 5: Custody of the Trust's Assets, page 92: We note your
statement here and on page 8 that the Custodian will keep a "substantial portion" of the private keys associated with the Trust’s
SOL in “cold storage” or similarly secure technology. We also note your disclosure on page 8 that "[a]ll of the Trust’s
assets and private keys will be held in cold storage of the SOL Custodian on an ongoing basis." Please revise for consistency.

Response: With respect to the Staff’s comment, the Trust
has revised disclosure on pages 11 and 94 of the Pre-Effective Amendment.

Comment 6: United States Federal Income Tax Consequences, page 121:
We note that your discussion of tax consequences is based on the assumption that the Trust will be treated as a grantor trust for U.S.
federal income tax purposes. Please revise to provide an opinion as to the tax consequences and describe the reasons for and level of
any uncertainty associated with grantor trust status.

Response: With respect to the Staff’s comment, the Trust
has revised disclosure on page 125 of the Pre-Effective Amendment.

    2

Comment 7: United States Federal Income Tax Consequences, page 121:
Please revise this section and your risk factors to address the tax consequences of the Trust's staking program.

Response: With respect to the Staff’s comment, the Trust
has revised disclosure on page 125 of the Pre-Effective Amendment. The Trust respectfully advises the Staff that there is an existing
risk factor titled “[t]he treatment of staking in a grantor trust for U.S. federal income tax purposes is still developing”
on page 74 of the Registration Statement that addresses the tax consequences of the Trust’s staking program.

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

August 15, 2025
Duncan Moir
President
21Shares Core Solana ETF
c/o 21Shares US LLC
477 Madison Avenue, 6th Floor
New York, NY 10022
Re:21Shares Core Solana ETF
Amendment No. 2 to Registration Statement on Form S-1
Filed July 30, 2025
File No. 333-280557
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 July 3, 2025 letter.
Amendment No. 2 to Registration Statement on Form S-1
General
Please revise your disclosure to clarify if the Trust plans to stake its SOL when the
product launches. In addition, and if so, please revise to:
•Provide a materially complete description of your planned staking program,
policies and procedures;
•Disclose the percentage of the Trust's SOL to be staked;
Include the material terms of any agreements with Staking Providers and
summarize the responsibilities and duties of the Staking Providers. Refer to Item
601(b)(10) of Regulation S-K and file your material agreement(s) with Staking •1.

August 15, 2025
Page 2
Providers as an exhibit to your registration statement;
•Disclose how and when rewards from staking will be shared, distributed, or added
to the assets of the Trust and how this will work; and
•Disclose any policies with respect to the use of proceeds from staking rewards and
quantify the portion of staking rewards that all involved parties will receive.
Please also confirm your understanding that we may have additional comments upon
review of a materially complete description of your staking program. In addition, to
the extent your liquidity risk policies and procedures for your staking program are
intended to be consistent with the exchange's proposed generic listing standards,
please revise your disclosure accordingly.
2.We note your disclosure that the Sponsor may "seek to utilize alternative means to
engage in Staking Activities." Please revise to disclose the "alternative means" to
which you are referring in addition to liquid staking tokens.
Prospectus Summary
The Staking Services Provider, page 8
3.We note your disclosure that the Sponsor plans to engage one or more third party
Staking Services Providers.  To the extent the Trust engages additional Staking
Services Providers, please revise to discuss the factors that will be used to determine
how much SOL to allocate among multiple Staking Services Providers.
The Trust and SOL Prices
Overview of the Trust, page 80
4.We note your disclosure that staked SOL is temporarily locked and inaccessible
during the bonding and unbonding periods. Please revise to disclose with specificity
the bonding and unbonding periods associated with staking SOL, discuss how they
affect liquidity and disclose the material terms of any policies and procedures you
have in place to manage liquidity and maintain effective arbitrage in light of any
staking program you undertake.
Custody of the Trust's Assets, page 92
5.We note your statement here and on page 8 that the Custodian will keep a "substantial
portion" of the private keys associated with the Trust’s SOL in “cold storage” or
similarly secure technology. We also note your disclosure on page 8 that "[a]ll of the
Trust’s assets and private keys will be held in cold storage of the SOL Custodian on
an ongoing basis." Please revise for consistency.
United States Federal Income Tax Consequences, page 121
6.We note that your discussion of tax consequences is based on the assumption that the
Trust will be treated as a grantor trust for U.S. federal income tax purposes. Please
revise to provide an opinion as to the tax consequences and describe the reasons for
and level of any uncertainty associated with grantor trust status.

August 15, 2025
Page 3
7.Please revise this section and your risk factors to address the tax consequences of the
Trust's staking program.
            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 David Gessert at 202-551-2326 or Sandra Hunter Berkheimer at 202-
551-3758 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets
cc:Allison M. Fumai, Esq.

CORRESP
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VIA EDGAR

July 30, 2025

Division of Corporation Finance

Office of Crypto Assets

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

    Re:
    21Shares Core Solana ETF

    Registration Statement on Form S-1

    Filed June 13, 2025

    File No. 333-280557

To Whom it May Concern:

On behalf of 21Shares Core Solana 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 July 3, 2025 with respect to the Trust’s registration statement on Form S-1, as
amended (the “Registration Statement”), filed on June 13, 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 Company on the date hereof (such registration statement being referred to herein as the “Pre-Effective
Amendment”). We will incorporate any changes referenced below into the Pre-Effective Amendment.

Comment 1: General: 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 supplementarily to the Staff.

Comment 2: Cover Page: Please identify the
initial Authorized Participant here. Please also identify the initial purchaser(s) that will be acting as an underwriter. Additionally,
please revise the cover page to disclose the price per Share of the initial Basket, and disclose the aggregate price of the initial Basket.

Response: With respect to the initial Authorized
Participant, the Trust has not yet identified the initial Authorized Participant but will do so in a subsequent filing. With respect to
the initial purchaser, the Trust respectfully advises the Staff that the Trust will identify the initial purchaser acting as a statutory
underwriter in a subsequent filing. With respect to the price per Share and aggregate price of the initial Basket(s), the Trust respectfully
advises the Staff that the Trust will identify the price per Share and aggregate price of the initial Basket(s) in a subsequent filing.

Comment 3: Cover Page: We note your
disclosure throughout regarding cash creations and redemptions. We also note your disclosure on page 77
that "Authorized Participants will deliver SOL to the Trust's account with the SOL Custodian in exchange for Shares of the
Trust, and the Trust, through the SOL Custodian, will deliver SOL to Authorized Participants when those Authorized Participants
redeem Shares."  Please revise your cover page to clarify if in-kind creations and redemptions will be available
when the product launches, and similarly revise your disclosure throughout as applicable.

Response: With respect to the Staff’s comment, the Trust
has revised the disclosure on cover page and throughout the Pre-Effective Amendment to clarify that in-kind creations and redemptions
will be available when the Trust launches.

Comment 4: Prospectus Summary – SOL
and the Solana Network, page 1. Please balance your disclosure that "[n]o single entity owns or operates the Solana
network" by discussing the influence over the direction of the development of the Solana network that Solana Labs and
the Solana Foundation may exert. In this regard, we note your disclosure in the last paragraph on page 18.

Response: With respect to the Staff’s
comment, the Trust has revised the disclosure on pages 2 and 18 of the Pre-Effective Amendment to synthesize these statements.

Comment 5: Principal Investment Risks of an
Investment in the Trust – Risks Associated with SOL and the Solana Network, page 14. Please update the price of SOL as of
a more recent date in the first bullet on the top of page 15. Please make corresponding revisions throughout your prospectus.

Response: With respect to the Staff’s
comment, the Trust has revised the disclosure on pages 15 and 18 of the Pre-Effective Amendment to provide more recent price information
for SOL.

Comment 6: United States Federal Income Tax
Consequences – Taxation of the Trust, page 19. Please revise your disclosure to specify whether you will receive an opinion from
counsel regarding the classification of the Trust as a grantor trust for U.S. federal income tax purposes.

Response: With respect to the Staff’s
comment, the Trust respectfully directs the Staff to the disclosure in the Pre-Effective Amendment on page 121.

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

July 3, 2025
Duncan Moir
President
21Shares Core Solana ETF
c/o 21Shares US LLC
477 Madison Avenue, 6th Floor
New York, NY 10022
Re:21Shares Core Solana ETF
Amendment No. 1 to Registration Statement on Form S-1
Filed June 13, 2025
File No. 333-280557
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 identify the initial Authorized Participant here. Please also identify the initial
purchaser(s) that will be acting as an underwriter. Additionally, please revise the
cover page to disclose the price per Share of the initial Basket, and disclose the
aggregate price of the initial Basket.
We note your disclosure throughout regarding cash creations and redemptions. We
also note your disclosure on page 77 that "Authorized Participants will deliver SOL to
the Trust's account with the SOL Custodian in exchange for Shares of the Trust, and 3.

July 3, 2025
Page 2
the Trust, through the SOL Custodian, will deliver SOL to Authorized Participants
when those Authorized Participants redeem Shares."  Please revise your cover page to
clarify if in-kind creations and redemptions will be available when the product
launches, and similarly revise your disclosure throughout as applicable.
Prospectus Summary
SOL and the Solana Network, page 1
4.Please balance your disclosure that "[n]o single entity owns or operates the Solana
network" by discussing the influence over the direction of the development of the
Solana network that Solana Labs and the Solana Foundation may exert. In this regard,
we note your disclosure in the last paragraph on page 18.
Principal Investment Risks of an Investment in the Trust
Risks Associated with SOL and the Solana network, page 14
5.Please update the price of SOL as of a more recent date in the first bullet on the top of
page 15. Please make corresponding revisions throughout your prospectus.
United States Federal Income Tax Consequences
Taxation of the Trust, page 119
6.Please revise your disclosure to specify whether you will receive an opinion from
counsel regarding the classification of the Trust as a grantor trust for U.S. federal
income tax purposes.
            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 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 David Gessert at 202-551-2326 or Sandra Hunter Berkheimer at 202-551-3758
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets
cc:Allison M. Fumai, Esq.

July 17, 2024
Ophelia Snyder
President
21Shares Core Solana ETF
477 Madison Avenue, 6th Floor
New York, New York 10022
Re:21Shares Core Solana ETF
Registration Statement on Form S-1
Filed June 28, 2024
File No. 333-280557
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 Solana and that you will meet the objective by holding Solana. The Commission
has stated that Solana meets the definition of 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.

July 17, 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 Austin Stanton at 202-551-2197 or Sandra Hunter Berkheimer at 202-551-
3758 with any questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets
cc:Allison M. Fumai