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 Document VanEck Avalanche ETF c/o VanEck Digital Assets, LLC 666 Third Avenue, 9 th Floor New York, New York 10017 January 21, 2026 VIA EDGAR Mr. David Gessert, Esq. Ms. Sandra Hunter Berkheimer, Esq. Office of Crypto Assets United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Re: Request for Acceleration of Effectiveness VanEck Avalanche ETF Registration Statement on Form S-1 File No. 333-285831 Dear Mr. Gessert and Ms. Berkheimer: In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Securities Act”), VanEck Avalanche ETF (the “Trust”) hereby requests that the effectiveness for the above-captioned Registration Statement on Form S-1 (as amended through the date hereof) filed under the Securities Act be accelerated to 12:00 p.m., New York City time, on January 23, 2026, or as soon thereafter as practicable. The Trust hereby confirms that it is aware of its obligations under the Securities Act and the Securities Exchange Act of 1934, as amended. Should you have any questions or require any additional information with respect to this filing, please contact Tae Ho Cho at (212) 878-8506 or Jason D. Myers at (212) 878-8324. Sincerely, VanEck Digital Assets, LLC Sponsor of VanEck Avalanche ETF By: /s/ Matthew A. Babinsky Name: Matthew A. Babinsky Title: Vice President cc: Jan F. van Eck, VanEck Digital Assets, LLC John J. Crimmins, VanEck Digital Assets, LLC Jonathan R. Simon, VanEck Digital Assets, LLC Matthew A. Babinsky, VanEck Digital Assets, LLC Tae Ho Cho, Clifford Chance US LLP Jason D. Myers, Clifford Chance US LLP Jesse Overall, Clifford Chance US LLP Kimara E. Davis, Clifford Chance US LLP

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 Document CLIFFORD CHANCE US LLP TWO MANHATTAN WEST 375 9TH AVENUE NEW YORK, NY 10001 TEL +1 212 878 8000 FAX +1 212 878 8375 www.cliffordchance.com January 20, 2026 VIA EDGAR Mr. David Gessert, Esq. Ms. Sandra Hunter Berkheimer, Esq. Office of Crypto Assets United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Re: VanEck Avalanche ETF Amendment No. 4 to Registration Statement on Form S-1 Filed January 16, 2026 File No. 333-285831 Dear Mr. Gessert and Ms. Berkheimer: On behalf of our client, VanEck Avalanche ETF (the “Trust”), we transmit this letter for filing in connection with the Trust’s Amendment No. 4 to Registration Statement on Form S-1 filed January 16, 2026 (the “Amended Registration Statement”). The Trust supplementally advises the Staff that the Trust intends to use a fact sheet, substantially as set forth on Annex A attached hereto. Defined terms used in Annex A but not otherwise defined have the meanings ascribed to them in the Amended Registration Statement. Should the Staff have any questions or comments regarding any of the foregoing, please do not hesitate to call me at (212) 878-3180 or Jason D. Myers at (212) 878-8324. Sincerely, /s/ Clifford R. Cone Clifford R. Cone cc: Jan F. van Eck, VanEck Digital Assets, LLC. Jonathan R. Simon, VanEck Digital Assets, LLC Matthew A. Babinsky, VanEck Digital Assets, LLC Jason D. Myers, Clifford Chance US LLP Jesse Overall, Clifford Chance US LLP Tae Ho Cho, Clifford Chance US LLP Annex A VAVX VanEck Avalanche ETF As of December 31, 2025 Fund Details About VAVX Trust Ticker VAVX Intraday NAV (IIV) VAVXIV The Trust's investment objective is to reflect the performance of the price of AVAX, and rewards from staking a portion of the Trust's AVAX, to the extent the Sponsor in its sole discretion determines that the Trust may do so without undue legal or regulatory risk, such as, without limitation, by jeopardizing the Trust’s ability to qualify as a grantor trust for U.S. federal income tax purposes, less the expenses of the Trust’s operations. Exchange Nasdaq Inception Date 11/20/25 Performance History: Average Annual Total Returns* (%) Sponsor VanEck Digital Assets, LLC Custodian Anchorage Digital Bank N.A. Coinbase Custody Trust Company, LLC Marketing Agent Van Eck Securities Corporation Trustee Delaware Trust Company Total Net Assets ($M) 0.00 Month End as of 12/31/25 1 MO 3 MO YTD 1 YR 3 YR 5 YR 10 YR LIFE † Quarter End as of 12/31/25 1 MO 3 MO YTD 1 YR 3 YR 5 YR 10 YR LIFE † Fees and Expenses* *Returns less than one year are not annualized. Expense Ratio  - % †Share price is calculated from --, which corresponds to the date the Shares commenced public trading. Net asset value returns are calculated from --, which is the inception date of the Trust. An investment in the VanEck Avalanche ETF (“VAVX,” or the “Trust”) is subject to significant risk and may not be suitable for all investors. The value of Avalanche is highly volatile, and you can lose your entire principal investment. VAVX 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. An investment in the Trust is subject to risks which include, but are not limited to, the historically and potentially future extreme volatility of AVAX, various potential factors that may adversely affect the liquidity of Trust shares, the limited history of the Index from which the value of AVAX and hence the value of Trust shares will be determined, potential threats to the Trust’s AVAX custodians, and the unregulated nature and lack of transparency surrounding the operations of AVAX trading platforms, all of which may ultimately adversely affect the value of shares of the Trust. Please note that this is not an exhaustive list of risks pertaining to the Trust. Please read carefully the prospectus for a complete list of potential risks. The performance data quoted represents past performance. Past performance is not a guarantee of future results. Investment return and principal value of an investment will fluctuate so that an investor's shares, when redeemed, may be worth more or less than their original cost. Performance may be lower or higher than performance data quoted. Please call 800.826.2333 or visit vaneck.com for performance current to the most recent month ended. The "Net Asset Value" (NAV) of the Trust is determined at the close of each business day, and represents the dollar value of one share of the Trust; it is calculated by taking the total assets of the Trust, subtracting total liabilities, and dividing by the total number of shares outstanding. The NAV is not necessarily the same as the Trust's intraday trading value. Investors should not expect to buy or sell shares at NAV. VAVX VanEck Avalanche ETF As of December 31, 2025 Staking Yields Percentage Staked —  Staking Yield on Staked AVAX —  Gross Staking Yield —  Net Staking Yield —  “Staking” refers to delegating a portion of the Fund’s AVAX to third-party validators on the Avalanche network for potential protocol rewards. Gross yield is shown before taxes and fees while net yield reflects them; both are based on net assets per share. Staking yield is not a separate shareholder payment—any rewards or losses affect the Fund’s NAV and performance. Staking entails liquidity, operational, validator, counterparty, and slashing risks, among others. See disclosures below and the prospectus for more information. The staking yield figures presented are estimates based on anticipated staking rewards and may differ from the yield recognized by the Fund on a daily basis. Important Disclosure This material must be preceded or accompanied by a prospectus. An investment in the VanEck Avalanche ETF ("VAVX" or the "Trust") may not be suitable for all investors. Before investing, you should carefully consider the Trust's investment objectives, risks, charges, and expenses. Investing involves significant risk, and you could lose money on an investment in the Trust. The value of Avalanche (AVAX) is highly volatile, and the value of the Trust’s shares could decline rapidly, including to zero. You could lose your entire principal investment. For a more complete discussion of the risk factors relative to the Trust, carefully read the prospectus. The Trust's investment objective is to reflect the performance of the price of Avalanche (“AVAX”) and rewards from staking a portion of the Trust’s AVAX, less the expenses of the Trust's operations. The Trust is a passive investment vehicle that does not seek to pursue any investment strategy beyond reflecting the performance of the price of AVAX and any rewards from staking a portion of the Trust’s AVAX. The Trust is not an investment company registered under the Investment Company Act of 1940 (“1940 Act”) or a commodity pool for the purposes of the Commodity Exchange Act (“CEA”). Shares of the Trust are not subject to the same regulatory requirements as mutual funds. As a result, shareholders of VAVX do not have the protections associated with ownership of shares in an investment company registered under the 1940 Act or the protections afforded by the CEA. An investment in the Trust is subject to risks which include, but are not limited to, the historically and potentially future extreme volatility of AVAX, various potential factors that may adversely affect the liquidity of Trust shares, the limited history of the Index from which the value of AVAX and hence the value of Trust shares will be determined, potential threats to the Trust’s AVAX custodians, and the unregulated nature and lack of transparency surrounding the operations of AVAX trading platforms, all of which may ultimately adversely affect the value of shares of the Trust. Staking Risks: As part of its strategy, the Trust intends to stake a portion of its AVAX via third-party staking service providers, which ientails a number of risks. AVAX that is staked will undergo activation and de-activation (or withdrawal) periods during which it is locked up and inaccessible, meaning the Trust may not be able to quickly liquidate these assets to satisfy redemption requests—particularly in volatile or stressed market conditions. Validators to which AVAX is delegated may behave improperly or suffer performance failures (e.g., downtime or misconfiguration), and in some cases “slashing” or protocol-imposed penalties may apply for such misbehavior, resulting in a loss of staked AVAX. There is counterparty and operational risk associated with the staking service providers (and the custodians facilitating staking), including reliance on their security, compliance, and ability to operate under adverse conditions. Additionally, staking rewards are subject to fees and possible withholding obligations, and the timing, amount and recognition (for tax purposes) of staking rewards may be uncertain. Finally, regulatory or legal changes—such as a U.S. federal income tax law or securities regulations—could affect whether staking activities or liquid staking tokens may be used, or whether they jeopardize the Trust’s qualification (e.g., as a grantor trust) or impose unanticipated costs. Please note that this is not an exhaustive list of risks pertaining to the Trust. Please read carefully the prospectus for a complete list of potential risks. Because shares of the Trust are intended to reflect the price of the AVAX held in the Trust, the market price of the shares is subject to fluctuations similar to those affecting AVAX prices. Additionally, shares of the Trust are bought and sold at market price, not at net asset value (“NAV”). Brokerage commissions will reduce returns. Trust shares trade like stocks, are subject to investment risk, and will fluctuate in market value. The value of Trust shares relates directly to the value of the AVAX held by the Trust (less its expenses), and fluctuations in the price of AVAX could materially and adversely affect an investment in the shares. The price received upon the sale of the shares, which trade at market price, may be more or less than the value of the AVAX represented by them. The Trust does not generate any income, and as the Trust regularly issues shares to pay for the Sponsor’s ongoing expenses, the amount of AVAX represented by each Share will decline over time. This content is published in the United States for residents of specified countries. Investors are subject to securities and tax regulations within their applicable jurisdictions that are not addressed in this content. Nothing in this content should be considered a solicitation to buy or an offer to sell shares of any investment in any jurisdiction where the offer or solicitation would be unlawful under the securities laws of such jurisdiction, nor is it intended as investment, tax, financial, or legal advice. Investors should seek such professional advice for their particular situation and jurisdiction. The Sponsor of the Trust is VanEck Digital Assets, LLC. The Marketing Agent for the Trust is Van Eck Securities Corporation. VanEck Digital Assets, LLC, and Van Eck Securities Corporation are wholly-owned subsidiaries of Van Eck Associates Corporation. © Van Eck Associates Corporation, 666 Third Avenue, New York, NY 10017 Phone: 800.826.2333 Email: info@vaneck.com VanEck mutual funds and ETFs are distributed by Van Eck Securities Corporation, Distributor, a wholly owned subsidiary of Van Eck Associates Corporation. 666 Third Avenue, New York, NY 10017 © 2026 VanEck. VanEck®, VanEck Access the opportunities®, and the stylized VanEck design® are trademarks of Van Eck Associates Corporation. FUND TICKER: VAVX      800.826.2333      VANECK.COM

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 Document CLIFFORD CHANCE US LLP TWO MANHATTAN WEST 375 9TH AVENUE NEW YORK, NY 10001 TEL +1 212 878 8000 FAX +1 212 878 8375 www.cliffordchance.com January 15, 2026 VIA EDGAR Mr. David Gessert, Esq. Ms. Sandra Hunter Berkheimer, Esq. Office of Crypto Assets United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Re: VanEck Avalanche ETF Amendment No. 3 to Registration Statement on Form S-1 Filed December 18, 2025 File No. 333-285831 Response to Staff comment received by letter dated January 15, 2026 Dear Mr. Gessert and Ms. Berkheimer: On behalf of our client, VanEck Avalanche ETF (the “ Trust ”), set forth below are the Trust’s response to the comment received from the staff (the “ Staff ”) of the Securities and Exchange Commission (the “ Commission ”) by letter dated January 15, 2026 (the “ Comment Letter ”) in connection with the Trust’s Amendment No. 3 to the Registration Statement on Form S-1 (the “ Registration Statement ”), which was filed with the Commission on December 18, 2025. Concurrently with the filing of this response letter, the Trust is filing Amendment No. 4 to the Registration Statement (the “ Amended Registration Statement ”). Where noted in the response below, the Amended Registration Statement has been updated in response to the Staff’s comment. The page reference in the response below is to the page of the Amended Registration Statement, unless otherwise specified. Defined terms used herein but not otherwise defined have the meanings ascribed to them in the Amended Registration Statement. Amendment No. 3 to Registration Statement on Form S-1 General 1. We note your disclosure that “[c]urrently the Trust intends to have a target staking percentage of 70% of the Trust’s AVAX holdings, subject to the Staking Policy and fluctuations during the ramp-up staking period.” We also note your disclosure that “[u]nder normal circumstances, the Sponsor will seek to stake all of the Trust’s AVAX Mr. David Gessert, Esq. Ms. Sandra Hunter Berkheimer, Esq. United States Securities and Exchange Commission January 15, 2026 Page 2 except for AVAX reserved by the Sponsor in its sole discretion to facilitate foreseeable redemption transactions, pay Trust expenses or otherwise protect the Trust and its assets.” Please revise to reconcile your disclosure regarding the amount of AVAX you will stake and to clarify what you mean by “normal circumstances.” In response to the Staff's comment, the Trust has revised the disclosure on page 3 of the Prospectus to reconcile its disclosure regarding the amount of AVAX the Trust seeks to stake and to clarify the meaning of “normal circumstances.” Should the Staff have any additional questions or comments regarding any of the foregoing, please do not hesitate to call me at (212) 878-3180 or Jason D. Myers at (212) 878-8324. Very truly yours, /s/ Clifford R. Cone Clifford R. Cone cc: Jan F. van Eck, VanEck Digital Assets, LLC Jonathan R. Simon, VanEck Digital Assets, LLC Matthew A. Babinsky, VanEck Digital Assets, LLC Jason D. Myers, Clifford Chance US LLP Jesse Overall, Clifford Chance US LLP Tae Ho Cho, Clifford Chance US LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 January 15, 2026

Jan F. van Eck
President and Chief Executive Officer
VanEck Avalanche ETF
666 Third Avenue, 9th Floor
New York, NY 10017

 Re: VanEck Avalanche ETF
 Amendment No. 3 to Registration Statement on Form S-1
 Filed December 18, 2025
 File No. 333-285831
Dear Jan F. van Eck:

 We have reviewed your amended registration statement and have the
following
comment.

 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 December 15,
2025
letter.

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

1. We note your disclosure that "[c]urrently the Trust intends to have a
target staking
 percentage of 70% of the Trust's AVAX holdings, subject to the Staking
Policy and
 fluctuations during the ramp-up staking period." We also note your
disclosure that
 "[u]nder normal circumstances, the Sponsor will seek to stake all of the
Trust's AVAX
 except for AVAX reserved by the Sponsor in its sole discretion to
facilitate
 foreseeable redemption transactions, pay Trust expenses or otherwise
protect the Trust
 and its assets." Please revise to reconcile your disclosure regarding
the amount of
 AVAX you will stake and to clarify what you mean by "normal
circumstances."
 January 15, 2026
Page 2

 Please contact Kate Tillan at 202-551-3604 or Jason Niethamer at
202-551-3855 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: Clifford R. Cone, Esq.
</TEXT>
</DOCUMENT>

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 Document CLIFFORD CHANCE US LLP TWO MANHATTAN WEST 375 9TH AVENUE NEW YORK, NY 10001 TEL +1 212 878 8000 FAX +1 212 878 8375 www.cliffordchance.com December 18, 2025 VIA EDGAR Mr. David Gessert, Esq. Ms. Sandra Hunter Berkheimer, Esq. Office of Crypto Assets United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Re: VanEck Avalanche ETF Amendment No. 2 to Registration Statement on Form S-1 Filed November 26, 2025 File No. 333-285831 Responses to Staff comments received by letter dated December 15, 2025 Dear Mr. Gessert and Ms. Berkheimer: On behalf of our client, VanEck Avalanche ETF (the “ Trust ”), set forth below are the Trust’s responses to the comments received from the staff (the “ Staff ”) of the Securities and Exchange Commission (the “ Commission ”) by letter dated December 15, 2025 (the “ Comment Letter ”) in connection with the Trust’s Amendment No. 2 to the Registration Statement on Form S-1 (the “ Registration Statement ”), which was filed with the Commission on November 26, 2025. Concurrently with the filing of this response letter, the Trust is filing Amendment No. 3 to the Registration Statement (the “ Amended Registration Statement ”). Where noted in the responses below, the Amended Registration Statement has been updated in response to the Staff’s comments. The Trust’s responses are set out in the order in which the comments were set out in the Comment Letter and are numbered accordingly. All page references in the responses below are to the pages of the Amended Registration Statement, unless otherwise specified. Defined terms used herein but not otherwise defined have the meanings ascribed to them in the Amended Registration Statement. Amendment No. 2 to Registration Statement on Form S-1 General 1. Please revise to disclose the percentage of the Trust's AVAX to be staked and tell us, with a view towards revised disclosure, whether a current percentage of the Trust's AVAX Mr. David Gessert, Esq. Ms. Sandra Hunter Berkheimer, Esq. United States Securities and Exchange Commission December 18, 2025 Page 2 being staked will be made publicly available to investors on a regular basis, including on your website or otherwise. In response to the Staff's comment, the Trust has revised the disclosure on page 3 of the Prospectus to disclose the percentage of the Trust's AVAX to be staked and on pages 2 and 97 to disclose that a current percentage of the Trust's AVAX being staked will be made publicly available to investors on a regular basis on the Trust's website. 2. 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 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. In response to the Staff's comment, the Trust has revised the disclosure on the front cover page of the Prospectus and pages 1, 3, 6, 78, 97-98 and 162 of the Prospectus to remove the references to using or holding liquid staking tokens. Risk Factors Risks Associated with AVAX And The Avalanche Network The Trading Prices Of Many Digital Assets, Including AVAX, Have Experienced Extreme Volatility In Recent Periods..., page 17 3. We note your revised disclosure under this heading that "[t]he price of some digital assets, including AVAX, has risen..." Please expand to provide quantitative information related to the price of AVAX illustrating this trend, or revise to clarify your disclosure. In response to the Staff's comment, the Trust has revised the disclosure on page 17 of the Prospectus to remove the statement "The price of some digital assets, including AVAX, has risen following the election of Donald Trump as president of the United States." AVAX, AVAX Market, AVAX Exchanges and Regulation of AVAX Creation of New AVAX Initial Creation of AVAX, page 98 4. Please expand to describe the progressive minting process by which the AVAX supply increases. In response to the Staff's comment, the Trust has revised the disclosure on pages 95-96 of the Prospectus to describe the minting process by which AVAX supply increases. The Trust's Staking Program, page 98 Mr. David Gessert, Esq. Ms. Sandra Hunter Berkheimer, Esq. United States Securities and Exchange Commission December 18, 2025 Page 3 5. Please revise your disclosure here to explain whether and to what extent you anticipate laddering staking terms and/or utilizing your buffer to manage liquidity in light of the two week minimum validation period. In response to the Staff's comment, the Trust has revised the disclosure on page 97 of the Prospectus to explain to what extent the Trust anticipates laddering staking terms to manage liquidity in light of the two week minimum validation period. Should the Staff have any additional questions or comments regarding any of the foregoing, please do not hesitate to call me at (212) 878-3180 or Jason D. Myers at (212) 878-8324. Very truly yours, /s/ Clifford R. Cone Clifford R. Cone cc: Jan F. van Eck, VanEck Digital Assets, LLC Jonathan R. Simon, VanEck Digital Assets, LLC Matthew A. Babinsky, VanEck Digital Assets, LLC Jason D. Myers, Clifford Chance US LLP Jesse Overall, Clifford Chance US LLP Tae Ho Cho, Clifford Chance US LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 December 15, 2025

Jan F. van Eck
President and Chief Executive Officer
VanEck Avalanche ETF
666 Third Avenue, 9th Floor
New York, NY 10017

 Re: VanEck Avalanche ETF
 Amendment No. 2 to Registration Statement on Form S-1
 November 26, 2025
 File No. 333-285831
Dear Jan F. van Eck:

 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 April 10,
2025 letter.

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

1. Please revise to disclose the percentage of the Trust's AVAX to be
staked and tell us,
 with a view towards revised disclosure, whether a current percentage of
the Trust's
 AVAX being staked will be made publicly available to investors on a
regular basis,
 including on your website or otherwise.
2. 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 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.
 December 15, 2025
Page 2

Risk Factors
Risks Associated with AVAX And The Avalanche Network
The Trading Prices Of Many Digital Assets, Including AVAX, Have Experienced
Extreme
Volatility In Recent Periods..., page 17

3. We note your revised disclosure under this heading that "[t]he price of
some digital
 assets, including AVAX, has risen..." Please expand to provide
quantitative
 information related to the price of AVAX illustrating this trend, or
revise to clarify
 your disclosure.
AVAX, AVAX Market, AVAX Exchanges and Regulation of AVAX
Creation of New AVAX
Initial Creation of AVAX, page 98

4. Please expand to describe the progressive minting process by which the
AVAX
 supply increases.
The Trust's Staking Program, page 98

5. Please revise your disclosure here to explain whether and to what extent
you
 anticipate laddering staking terms and/or utilizing your buffer to
manage liquidity in
 light of the two week minimum validation period.
 Please contact Kate Tillan at 202-551-3604 or Jason Niethamer at
202-551-3855 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: Clifford R. Cone, Esq.
</TEXT>
</DOCUMENT>

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 Document CLIFFORD CHANCE US LLP TWO MANHATTAN WEST 375 9TH AVENUE NEW YORK, NY 10001 TEL +1 212 878 8000 FAX +1 212 878 8375 www.cliffordchance.com November 26, 2025 VIA EDGAR Mr. David Gessert, Esq. Ms. Sandra Hunter Berkheimer, Esq. Office of Crypto Assets United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Re: VanEck Avalanche ETF Amendment No. 2 to Registration Statement on Form S-1 File No. 333-285831 Dear Mr. Gessert and Ms. Berkheimer: On behalf of our client, VanEck Avalanche ETF (the “ Trust ”), we transmit for filing under the Securities Act of 1933, as amended, the Trust’s Amendment No. 2 to the Registration Statement on Form S-1 (the “ Amended Registration Statement ”) relating to the initial public offering of the Trust’s shares. The Trust is filing the Amended Registration Statement to provide new and updated information that supersedes the information included in the Trust’s Amendment No. 1 to the Registration Statement on Form S-1 filed on October 2, 2025 (“ Amendment No. 1 ”). We respectfully request that the Staff review the Amended Registration Statement, rather than Amendment No. 1. If you have any questions regarding the foregoing, please do not hesitate to call me at (212) 878-3180 or Jason D. Myers at (212) 878-8324. Sincerely, /s/ Clifford R. Cone Clifford R. Cone Mr. David Gessert, Esq. Ms. Sandra Hunter Berkheimer, Esq. United States Securities and Exchange Commission November 26, 2025 Page 2 cc: Jan F. van Eck, VanEck Digital Assets, LLC Jonathan R. Simon, VanEck Digital Assets, LLC Matthew A. Babinsky, VanEck Digital Assets, LLC Jason D. Myers, Clifford Chance US LLP Jesse Overall, Clifford Chance US LLP Tae Ho Cho, Clifford Chance US LLP

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Document

 CLIFFORD CHANCE US LLP

TWO MANHATTAN WEST

375 9TH AVENUE

NEW YORK, NY 10001

TEL +1 212 878 8000

FAX +1 212 878 8375

www.cliffordchance.com

October 3, 2025

VIA EDGAR

Mr. David Gessert, Esq.

Ms. Sandra Hunter Berkheimer, Esq.

Office of Crypto Assets

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: VanEck Avalanche ETF

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

 Filed March 14, 2025

 File No. 333-285831

 Responses to Staff comments made by letter dated April 10, 2025

Dear Mr. Gessert and Ms. Berkheimer:

On behalf of our client, VanEck Avalanche ETF (the “Trust”), set forth below are the Trust’s responses to the comments received from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) by letter dated April 10, 2025 (the “Comment Letter”) in connection with the Trust’s Registration Statement on Form S-1 (the “Registration Statement”), which was filed with the Commission on March 14, 2025. Concurrently with the filing of this response letter, the Trust is filing Amendment No. 1 to the Registration Statement (the “Amended Registration Statement”). Where noted in the responses below, the Amended Registration Statement has been updated in response to the Staff’s comments.

The Trust’s responses are set out in the order in which the comments were set out in the Comment Letter and are numbered accordingly. All page references in the responses below are to the pages of the Amended Registration Statement, unless otherwise specified. Defined terms used herein but not otherwise defined have the meanings ascribed to them in the Amended Registration Statement.

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.

The Trust supplementally advises the Staff that a fact sheet will be provided with a subsequent amendment to the Registration Statement.

Mr. David Gessert, Esq.

Ms. Sandra Hunter Berkheimer, Esq.

United States Securities and Exchange Commission

October 3, 2025

Page 2

2.Please tell us the status of the exchange’s plans to submit an application under Rule 19b-4, and revise your disclosure throughout the prospectus as appropriate.  Please be advised that we may have additional comments once the Rule 19b-4 application is filed.

The Trust supplementally advises the Staff that the Shares are expected to be listed and traded on The Nasdaq Stock Market LLC (the “Exchange”), pursuant to its existing generic listing standards. As a result, the Exchange does not plan to submit a separate application under Rule 19b-4. Additionally, the Trust has revised the disclosure on the inside cover page and page 1 of the Prospectus accordingly.

3.We note you include inconsistent disclosure throughout regarding the Trust’s staking plans.  For example purposes only, on pages 2 and 77 you disclose that the Trust “will employ its AVAX in Staking Activities,” on the Cover Page and page 1 you disclose that the “Sponsor may, from time to time, stake a portion of the Trust’s assets,” and on page 3 you disclose that “[t]he Trust will not employ its AVAX in Staking Activities and accordingly will not earn any form of staking rewards or income of any kind, from Staking Activities.”  Please consistently disclose whether and to what extent the Trust has plans to stake its AVAX.

In response to the Staff’s comment, the Trust has revised the disclosure on pages 2, 5, 6, 10, 101, 102, 103 and 123 of the Prospectus to clarify the Trust’s staking plans and the extent of such plans.

4.We note that you provide various facts and figures as of December 31, 2023.  For example purposes only, please refer to the information provided on pages 13, 28, 34, 70 and 71. Please revise your disclosure throughout to update.

In response to the Staff’s comment, the Trust has revised the disclosure on pages 26, 39, 45, 99 and 105 of the Prospectus to provide updated facts and figures.

Prospectus Summary

AVAX and the Avalanche Network

The AVAX Token, page 3

5.Please expand your disclosure here and under the “Creation of New AVAX” heading on page 73 to provide a materially complete description of the initial creation of AVAX, as well as current trends in the availability, circulating supply, staked supply, and the price of AVAX.  Please also discuss the market cap of AVAX relative to other crypto assets.

In response to the Staff’s comment, the Trust has revised the disclosure on page 100 of the Prospectus accordingly.

The MarketVector AVAX Benchmark Rate, page 4

Mr. David Gessert, Esq.

Ms. Sandra Hunter Berkheimer, Esq.

United States Securities and Exchange Commission

October 3, 2025

Page 3

6.We note your disclosure that the Trust will value its Shares daily based on the reported MarketVectorTM Avalanche Benchmark Rate.  As we are unable to locate an index with this name, please direct us to publicly available information about this index or please revise to correct the name of the index as applicable.

The Trust supplementally advises the Staff that publicly available information about the MarketVector™ Avalanche Benchmark Rate can be found at https://www.marketvector.com/indexes/digital-assets/marketvector-avalanche-benchmark-rate.

7.We note your disclosure throughout and under this heading that the Index’s underlying trading platforms are sourced from the “industry leading CCData Centralized Exchange Benchmark review report.”  As we are unable to locate this report, please direct us to publicly available information on this report or please revise to correct the name of the report as applicable.

The Trust supplementally advises the Staff that publicly available information about the CCData Centralized Exchange Benchmark review report can be found at https://www.ccdata.io/research/exchange-benchmark-rankings.

Custody of the Trust’s Assets

The Additional AVAX Account, page 8

8.Please provide disclosure describing the Additional AVAX Account, its purpose, and function.  Additionally, disclose whether the AVAX Custodian will also be the custodian for the Additional AVAX Account.  If there will be an Additional AVAX Custodian, identify the entity and describe their responsibilities.  In this regard we note your disclosure throughout the Risk Factors and Glossary of Defined Terms sections of your Prospectus.

In response to the Staff’s comment, the Trust has revised the disclosure on page 12 of the Prospectus to provide disclosure describing the Additional AVAX Account, its purpose, and function and on page 10 of the Prospectus to disclose the Additional AVAX Custodian and its responsibilities.

Risk Factors

Risks Associated with AVAX And The Avalanche Network

The Value Of The Shares Depends On The Development And Acceptance Of The Avalanche Network..., page 14

9.We note your disclosure in the third bullet on page 15 that bugs, defects and flaws in the source code have “disrupted normal Avalanche network, Avalanche Client, or DApp and smart contract operations or disabled related functionality for users, exposed users’ personal information and/or resulted in the theft of users’ digital assets.”  Please expand to describe all such material events or provide an illustrative example if no such events were material.

Mr. David Gessert, Esq.

Ms. Sandra Hunter Berkheimer, Esq.

United States Securities and Exchange Commission

October 3, 2025

Page 4

In response to the Staff’s comment, the Trust has revised the disclosure on pages 25 and 99 of the Prospectus to disclose the issues that disrupted block ingestion and block finalization on the Avalanche Network on each of February 1, 2024 and February 23, 2024, respectively.

The Avalanche Blockchain Could Be Vulnerable To Attacks on Transaction Finality and Consensus Processes..., page 20

10.We note your disclosure on page 72 under “Forms of Attack Against the Avalanche Network.”  Please expand to disclose the denial of service attack that disrupted the Avalanche Network on September 14, 2021.

The Trust supplementally advises the Staff that no denial of service attack disrupted the Avalanche Network on September 14, 2021. In response to the Staff’s comment, the Trust has revised the disclosure on page 98 of the Prospectus to remove the reference to a denial of service attack on the Avalanche Network on September 14, 2021.

Regulatory Risk

Digital Asset Markets In The United States Exist In A State Of Regulatory Uncertainty..., page 49

11.Please update your risk factor discussion to include recent legislative and regulatory developments.  Please make corresponding revisions to your disclosure under “Regulation of Avalanche and Government Oversight” beginning on page 74.

In response to the Staff’s comment, the Trust has revised the disclosure on page 73 of the Prospectus to include recent legislative and regulatory developments.

A Determination That AVAX Or Any Other Digital Asset Is A “Security” May Adversely Affect The Value Of AVAX..., page 51

12.We note your statements in this risk factor and on page 54 related to whether AVAX “is determined to be a security” for purposes of the federal securities laws.  Please revise these statements to add after the phrase “determined to be” the phrase “offered and sold as.”  Also, please make corresponding revisions throughout this risk factor and elsewhere in your Prospectus as appropriate.  In addition, please update your disclosure in this risk factor where applicable.

In response to the Staff’s comment, the Trust has revised the disclosure on pages 76 and 77 of the Prospectus to add the phrase “offered and sold as” after the phrase “determined to be”.

13.We note your statement that “for so long as the Sponsor believes there to be good faith grounds to conclude that the Trust’s AVAX is not a security...”  Please revise to disclose your internal policies and procedures for analyzing whether AVAX is offered and sold as a “security” within the meaning of Section 2(a)(1) of the Securities Act and disclose the risks of such internal policies and procedures, including that such policies and

Mr. David Gessert, Esq.

Ms. Sandra Hunter Berkheimer, Esq.

United States Securities and Exchange Commission

October 3, 2025

Page 5

procedures are risk-based judgments made by the Sponsor and not a legal standard or determination binding on any regulatory body or court.

In response to the Staff’s comment, the Trust has revised the disclosure on page 77 of the Prospectus to disclose the Trust’s internal policies and procedures for analyzing whether AVAX is offered and sold as a “security” within the meaning of Section 2(a)(1) of the Securities Act and to disclose the risks of such internal policies and procedures, including that such policies and procedures are risk-based judgments made by the Sponsor and not a legal standard or determination binding on any regulatory body or court.

AVAX, AVAX Market, AVAX Exchanges and Regulation of AVAX

Creation of New AVAX

Proof-of-Stake Process, page 73

14.Please expand your disclosure to identify the specific proof-of-stake consensus mechanism that Avalanche employs and describe the process.

In response to the Staff’s comment, the Trust has revised the disclosure on page 104 of the Prospectus to identify the specific proof-of-stake consensus mechanism that Avalanche employs and to describe the process.

The Trust’s Service Providers, page 92

15.Once you have entered into material agreements with the Trust’s service providers, please revise to disclose the material terms of each of these agreements, including the term of each agreement and the termination provisions of each agreement.

In response to the Staff’s comment, the Trust has revised the disclosure on pages 122 through 133 of the Prospectus to disclose the material terms of each of the material agreements with the Trust’s service providers as of the date hereof, including the term of each agreement and the termination provisions of each agreement. If the Trust enters material agreements in the future, it will disclose the material terms thereof, including the term of each such agreement and the termination provisions.

United States Federal Income Tax Consequences Taxation of the Trust, page 123

16.We note the statement here that “the remainder of this discussion assumes that the Trust is classified as a grantor trust for U.S. federal income tax purposes.”  Elsewhere in the document the tax classification of the trust is blank.  Please tell us, and revise your disclosure for consistency, whether you intend for the trust to be classified as a grantor trust for U.S. federal income tax purposes.

In response to the Staff’s comment, the Trust has revised the disclosure on page 167 and elsewhere in the Prospectus where the tax classification of the Trust was previously blank to clarify that the Trust intends to be classified as a grantor trust for U.S. federal income tax purposes.

Mr. David Gessert, Esq.

Ms. Sandra Hunter Berkheimer, Esq.

United States Securities and Exchange Commission

October 3, 2025

Page 6

Should the Staff have any additional questions or comments regarding any of the foregoing, please do not hesitate to call me at (212) 878-3180 or Jason D. Myers at (212) 878-8324.

Very truly yours,

/s/ Clifford R. Cone

Clifford R. Cone

cc: Jan F. van Eck, VanEck Digital Assets, LLC

 Jonathan R. Simon, VanEck Digital Assets, LLC

 Matthew A. Babinsky, VanEck Digital Assets, LLC

 Jason D. Myers, Clifford Chance US LLP

 Jesse Overall, Clifford Chance US LLP

 Tae Ho Cho, Clifford Chance US LLP

April 10, 2025
Jan F. van Eck
President and Chief Executive Officer
VanEck Avalanche ETF
666 Third Avenue, 9th Floor
New York, NY 10017
Re:VanEck Avalanche ETF
Registration Statement on Form S-1
Filed March 14, 2025
File No. 333-285831
Dear Jan F. van Eck:
            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.
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.
2.Please tell us the status of the exchange's plans to submit an application under Rule
19b-4, and revise your disclosure throughout the prospectus as appropriate. Please be
advised that we may have additional comments once the Rule 19b-4 application is
filed.
We note you include inconsistent disclosure throughout regarding the Trust's staking
plans. For example purposes only, on pages 2 and 77 you disclose that the Trust "will
employ its AVAX in Staking Activities," on the Cover Page and page 1 you disclose
that the "Sponsor may, from time to time, stake a portion of the Trust’s assets," and on
page 3 you disclose that "[t]he Trust will not employ its AVAX in Staking Activities
and accordingly will not earn any form of staking rewards or income of any kind, 3.

April 10, 2025
Page 2
from Staking Activities." Please consistently disclose whether and to what extent the
Trust has plans to stake its AVAX.
4.We note that you provide various facts and figures as of December 31, 2023. For
example purposes only, please refer to the information provided on pages 13, 28, 34,
70 and 71. Please revise your disclosure throughout to update.
Prospectus Summary
AVAX and the Avalanche Network
The AVAX Token, page 3
5.Please expand your disclosure here and under the “Creation of New AVAX” heading
on page 73 to provide a materially complete description of the initial creation of
AVAX, as well as current trends in the availability, circulating supply, staked supply,
and the price of AVAX. Please also discuss the market cap of AVAX relative to other
crypto assets.
The MarketVector AVAX Benchmark Rate, page 4
6.We note your disclosure that the Trust will value its Shares daily based on the
reported MarketVector TM Avalanche Benchmark Rate. As we are unable to locate an
index with this name, please direct us to publicly available information about this
index or please revise to correct the name of the index as applicable.
7.We note your disclosure throughout and under this heading that the Index's underlying
trading platforms are sourced from the "industry leading CCData Centralized
Exchange Benchmark review report." As we are unable to locate this report, please
direct us to publicly available information on this report or please revise to correct the
name of the report as applicable.
Custody of the Trust's Assets
The Additional AVAX Account, page 8
8.Please provide disclosure describing the Additional AVAX Account, its purpose, and
function. Additionally, disclose whether the AVAX Custodian will also be the
custodian for the Additional AVAX Account. If there will be an Additional AVAX
Custodian, identify the entity and describe their responsibilities. In this regard we note
your disclosure throughout the Risk Factors and Glossary of Defined Terms sections
of your Prospectus.
Risk Factors
Risks Associated with AVAX And The Avalanche Network
The Value Of The Shares Depends On The Development And Acceptance Of The Avalanche
Network..., page 14
9.We note your disclosure in the third bullet on page 15 that bugs, defects and flaws in
the source code have "disrupted normal Avalanche network, Avalanche Client, or
DApp and smart contract operations or disabled related functionality for users,
exposed users' personal information and/or resulted in the theft of users' digital
assets." Please expand to describe all such material events or provide an illustrative
example if no such events were material.

April 10, 2025
Page 3
The Avalanche Blockchain Could Be Vulnerable To Attacks on Transaction Finality and
Consensus Processes..., page 20
10.We note your disclosure on page 72 under "Forms of Attack Against the Avalanche
Network." Please expand to disclose the denial of service attack that disrupted the
Avalanche Network on September 14, 2021.
Regulatory Risk
Digital Asset Markets In The United States Exist In A State Of Regulatory Uncertainty...,
page 49
11.Please update your risk factor discussion to include recent legislative and regulatory
developments. Please make corresponding revisions to your disclosure under
"Regulation of Avalanche and Government Oversight" beginning on page 74.
A Determination That AVAX Or Any Other Digital Asset Is A "Security" May Adversely
Affect The Value Of AVAX..., page 51
12.We note your statements in this risk factor and on page 54 related to whether AVAX
"is determined to be a security" for purposes of the federal securities laws. Please
revise these statements to add after the phrase "determined to be" the phrase "offered
and sold as." Also, please make corresponding revisions throughout this risk factor
and elsewhere in your Prospectus as appropriate. In addition, please update your
disclosure in this risk factor where applicable.
13.We note your statement that "for so long as the Sponsor believes there to be good
faith grounds to conclude that the Trust's AVAX is not a security..." Please revise to
disclose your internal policies and procedures for analyzing whether AVAX is offered
and sold as a "security" within the meaning of Section 2(a)(1) of the Securities Act
and disclose the risks of such internal policies and procedures, including that such
policies and procedures are risk-based judgments made by the Sponsor and not a legal
standard or determination binding on any regulatory body or court.
AVAX, AVAX Market, AVAX Exchanges and Regulation of AVAX
Creation of New AVAX
Proof-of-Stake Process, page 73
14.Please expand your disclosure to identify the specific proof-of-stake consensus
mechanism that Avalanche employs and describe the process.
The Trust's Service Providers, page 92
15.Once you have entered into material agreements with the Trust's service providers,
please revise to disclose the material terms of each of these agreements, including the
term of each agreement and the termination provisions of each agreement.
United States Federal Income Tax Consequences
Taxation of the Trust, page 123
We note the statement here that "the remainder of this discussion assumes that the
Trust is classified as a grantor trust for U.S. federal income tax purposes." Elsewhere
in the document the tax classification of the trust is blank. Please tell us, and revise 16.

April 10, 2025
Page 4
your disclosure for consistency, whether you intend for the trust to be classified 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 Kate Tillan at 202-551-3604 or Jason Niethamer at 202-551-3855 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:Clifford R. Cone, Esq.