Risk factors

The Company advises the Staff that the disclosure on pages 61 and 62 of Amendment No. 1 has been revised to address the Staff’s comment. U.S. Securities and Exchange Commission June 1, 2026 Page 4 Our bylaws place restrictions on the forum, venue and procedures for legal actions…, page 61

The Company advises the Staff that the disclosure in this risk factor on pages 61 and 62 of the Registration Statement has been revised to define “Other Dispute” and include a summary of the mandatory arbitration provision in the Company’s bylaws. Management’s Discussion and Analysis of Financial Condition and Results of Operations Consumer and Enterprise Applications, page 82

We respectfully acknowledge the Staff’s comment and respond as follows. The Company disaggregated revenue by regulatory pathway (ANDA versus NDA) in prior periods because, historically, those categories reflected distinct economic characteristics, including differences in development risk, regulatory approval timelines, pricing, and margin profiles. However, the Company acknowledges that it paused further development of NDA products in 2021 and has not engaged in active commercial NDA-related business activities since that time. Accordingly, for the periods presented, revenue associated with NDA-related activities is zero, and the Company agrees that disaggregation by regulatory pathway no longer provides a meaningful depiction of how economic factors affect the nature, amount, timing, or uncertainty of revenue, as contemplated by ASC 606-10-50-5 and ASC 606-10-55-91. With a view toward…

The Registrant confirms that the principal risks disclosed in the Fund Summary are applicable to the Fund and related to the principal investment strategies. As disclosed in the principal investment strategies section of the Fund Summary, the Fund’s investments “may include foreign and domestic securities and other instruments, including sovereign debt (including U.S. Treasuries), mortgage-backed securities (“MBS”) and asset-backed securities, stripped securities, loans, bank instruments, municipal securities, corporate debt, other fixed-income securities and commodities-related investments.” - 4 - February 25, 2026 7.

We respectfully advise the Staff that we have revised the disclosure on page 13 to further describe how our product uses AI and automated data processing to generate pricing estimates and other outputs. We also clarified that we utilize a combination of third-party and open-source frameworks and components together with proprietary workflows and business logic, and we added related risk factor disclosure regarding reliance on third-party and open-source AI tools and the potential operational, legal, and reputational risks associated with inaccuracies, limitations, and changes in such technologies. Management’s Discussion and Analysis or Plan of Operations Plan of Operations, page 22

Each Fund will remove references to inapplicable strategies and/or risks from its risk factor disclosures, including the examples noted by the Staff.

Each Fund will revise the above-referenced section to state that the Fund expects to engage in active and frequent trading of derivatives.

As noted above in the response to Comment 3, in its principal investment strategy disclosures each Fund will specify the types of commodity-linked derivative instruments, including swaps, in which it intends to invest.

The Trust has revised the disclosure to clarify that the Fund may, as part of its principal investment strategy, invest in CLO equity and debt tranches that are rated below investment grade or the equivalent if unrated. The Trust will define "CLO Equity" in the Fund’s prospectus as “the most junior ownership tranche of a CLO structure that represents a residual claim on the cash flows generated by a diversified pool of leveraged loans, after all senior debt tranches and expenses have been paid.”

The Registrant will respond as requested. Questions on this letter or requests for additional information may be directed to me at (724) 720-8831 or Sheryl.McCall@FederatedHermes.com. Very truly yours, /s/ Sheryl L. McCall Sheryl L. McCall Senior Paralegal II Federated Hermes, Inc.

The Registrant respectfully acknowledges your comment; however, the Registrant believes that Cybersecurity and Technology Risk is not a principal risk of investing in the Fund. The Registrant believes that the placement of Cybersecurity and Technology Risk in the Item 9 Additional Information About Fund Investment Strategies and Related Risks section is currently appropriate. January 27, 2026 Page 2

In response to the Staff’s comment, the Trust notes that the risk factor entitled “Commodities” addresses the risks of investments in natural resources, including aluminum, forest products, non-ferrous metals, precious metals, petroleum and natural gas. Additionally, to supplement this risk disclosure, the Trust will add risk factors addressing the risks of investing in dividend-paying companies, and companies in the Energy and Materials sectors, as natural resource companies are generally spread across the Energy sector (e.g., oil, gas and coal) and Materials sector (e.g., metals, mining, chemicals and paper). The Trust believes that the risk disclosure, as currently presented and revised in the manner set forth above, will adequately address the risks of investing in dividend-paying companies tied to hard assets including real estate and natural resources. Furthermore, as noted in the…

The Company proposes to add the following disclosure to Footnote 2 in its future filings: Advances to Suppliers Advances to suppliers represent prepayments made to vendors for the purchase of raw materials, equipment, or services that have not yet been received as of the reporting date. These advances are generally unsecured, non-interest bearing, and are expected to be applied against future deliveries or services. Advances to suppliers are recorded at cost and classified as current or non-current assets based on the expected timing of the receipt of the related goods or services. Upon receipt of the goods or completion of services, the advances are reclassified to inventory, property and equipment, or operating expenses, as appropriate. Advances are reviewed periodically for recoverability, and any amounts deemed not recoverable are recognized as an expense in the period identified.…

The Company acknowledges the Staff’s comment and has revised the Registration Statement accordingly. Please see pages 2 through 7 of the Registration Statement for further details.

The Trust respectfully declines to include the requested risk disclosure because it is not applicable to the Fund. While IT Services Industry Risk is relevant to a leveraged long strategy, it does not accurately describe the risks of the Fund’s inverse (short) strategy. Put simply, adverse developments in the IT Services industry would generally be expected to benefit the Fund; including this disclosure could therefore be confusing to investors and could be viewed as promotional rather than risk-focused.

The Trust respectfully declines to include the requested industry risk disclosure because, as drafted for a leveraged long strategy, they are not applicable to the Funds. Each Fund seeks inverse (short) exposure, and the principal risk associated with industry-specific factors is the risk of strength in the relevant industry, not weakness. Put simply, adverse developments affecting the industry would generally be expected to benefit the Funds; accordingly, including a “long” industry risk discussion could confuse investors and may read as promotional rather than as a description of risks applicable to the Funds.

The Trust confirms that the Prospectus has been adjusted accordingly.

The Trust confirms that the Prospectus has been adjusted accordingly.

The Trust confirms that the Registration Statement includes a heading for the section entitled “Risk Factors.”

Pursuant to the Staff’s comment, the Trust will update the Registration Statement to add the term “Risk” to the end of each listed risk factor.

Pursuant to the Staff’s comment, the Trust will update the names of the above referenced risk factors to clarify that such risk factors address risks relating to the Underlying ETFs. We appreciate your prompt attention to this Registration Statement. If you have any questions or comments or would like to discuss our responses to your questions, please feel free to contact Brian D. Free at (312) 845-3017 or the undersigned at (312) 845-3721. Very truly yours, Chapman and Cutler llp By: /s/ Daniel J. Fallon Daniel J. Fallon

The Fund acknowledges that Staff’s comment and has supplemented the current Emerging Markets Risk disclosure with additional text (underlined below for emphasis): Emerging Markets Risk . The Fund may invest directly or indirectly, via ADRs, in securities issued by companies domiciled or headquartered in emerging market nations. Investments in securities traded in developing or emerging markets, or that provide exposure to such securities or markets, can involve additional risks relating to political, economic, currency, or regulatory conditions not associated with investments in U.S. securities and investments in more developed international markets. Such conditions may impact the ability of the Fund to buy, sell or otherwise transfer securities, adversely affect the trading market and price for Fund Shares and cause the Fund to decline in value. Differences in regulatory, accounting,…

The Registrant has included the requested disclosure consistent with disclosure for other series of the Trust.

The Trust has added convertible securities and rights and warrants risk language to each Fund’s Item 4 and Item 9 risk disclosures.

The Registrant has revised the disclosure in response to the Staff’s comments. 11.

The Registrant has revised the disclosure in response to the Staff’s comments. 13.

In response to the Staff’s comment, the Company respectfully undertakes to revise the relevant disclosure in its future Form 20-F filings as follows (with additions in underline showing the changes against the disclosure in the 2024 Form 20-F), subject to such updates and adjustments to be made in connection with any material developments of the subject matter being disclosed. 2 “ ITEM 3. KEY INFORMATION … The Holding Foreign Companies Accountable Act The Holding Foreign Companies Accountable Act, or the HFCAA, was enacted on December 18, 2020. Pursuant to the HFCAA and related regulations, if we have filed an audit report issued by a registered public accounting firm that the PCAOB has determined that it is unable to inspect and investigate completely, the SEC will identify us as a “Commission-Identified Issuer,” and the trading of our securities on any U.S. national securities…

While investments in inflation protected debt securities, repurchase agreements, warrants and rights are permitted within the Fund, they are not considered to be principal investments of the Fund and as a result, such risk factors have been removed from the Fund’s principal investment risk.

The Trust has made changes consistent with the Staff’s comment.

The Fund has revised the fourth paragraph of “Call Option Writing Risk” in the Fund’s “Principal Risks” section as follows: “There are special risks associated with uncovered option writing that expose the Fund to potentially significant loss. As the seller of an uncovered call option, the Fund bears unlimited risk of loss should the price of the underlying security increase above the exercise price until the Fund covers its exposure. Uncovered call options have speculative characteristics and are riskier than covered call options because there is no underlying instrument held by the Fund that can act as a partial hedge. In cases of uncovered calls being exercised, the Fund must purchase the underlying instrument to meet its call obligations and thus the necessary instruments may be unavailable for purchase. ” Should you have any questions, please feel free to contact me at (202)…

The Registrant has revised the relevant disclosure to read as follows: ● While the principals of the Adviser have the collective expertise and experience in advising investment funds with similar portfolio holdings and investment strategies, these principals do not have a track record for implementing the Fund’s investment strategy in a closed-end fund registered under the 1940 Act.

We have added language to Appendix D to clarify that the Series 12 asset is currently subject to a consignment agreement, and that the Managing Member has negotiated with the consignor to purchase the Series 12 asset at a fixed price if the fixed price auction (renamed in PQA 6 as a “Fixed Price Offering”) is successful. The consignment agreement, redacted to protect certain proprietary but immaterial terms, has been added as an exhibit to PQA 6 and additional disclosures summarizing the terms of the agreement have been added to Appendix D. Rebekah Reed/Donald Field December 3, 2025 Page 3 To that end, the only risks to the purchase price and the execution of the acquisition of the asset would be the Company’s failure to raise sufficient funds by the end of the negotiated consignment period, or a breach of contract by the consignor. We have added a risk factor to that effect. Comment 3…

Pursuant to the Staff’s comment, the prospectus will be updated to include an energy risk, industrials risk and materials risk. Furthermore, as noted in the response to Comment 1 above, if the Trust is concentrated in any other industry or group of industries, appropriate disclosure will be added to the Trust’s prospectus. Finally, the Trust has thoughtfully considered the Staff’s comment and declines to include a Power and Resources Companies risk factor. The Trust believes that, with the addition of the new risk disclosure, the Risk Factors adequately address the risks associated with an investment in Power and Resources Companies. We appreciate your prompt attention to this Registration Statement. If you have any questions or comments or would like to discuss our responses to your questions, please feel free to contact Brian D. Free at (312) 845-3017 or the undersigned at (312)…

The Company acknowledges the Staff’s comment and respectfully advises the Staff that the Company does not, and will not, have any plans to integrate cryptocurrencies into its FlexTV operations. The Company does not intend to accept digital assets as payment for FlexTV services, or otherwise incorporate cryptocurrency into its streaming business model. ARIZONA ● CALIFORNIA ● COLORADO ● CONNECTICUT ● DELAWARE ● FLORIDA ● GEORGIA ● ILLINOIS ● INDIANA ● KANSAS ● KENTUCKY ● LOUISIANA MARYLAND ● MASSACHUSETTS ● MINNESOTA ● MISSISSIPPI ● MISSOURI ● NEVADA ● NEW JERSEY ● NEW MEXICO ● NEW YORK ● NORTH CAROLINA OHIO ● OREGON ● PENNSYLVANIA ● RHODE ISLAND ● TENNESSEE ● TEXAS ● UTAH ● VIRGINIA ● WASHINGTON ● WASHINGTON D.C. ● WEST VIRGINIA November 25, 2025 Page 2

In response to the Staff’s comments, the disclosure on page 21 has been revised.

In response to the Staff’s comment, the Company respectfully undertakes to revise the relevant disclosure in its future Form 20-F filings as follows (with additions in underline showing the changes against the disclosure in the 2024 Form 20-F), subject to such updates and adjustments to be made in connection with any material developments of the subject matter being disclosed. 2 “ D. Risk Factors … Risks Related to Doing Business in China … The ADSs may be prohibited from being traded over the counter in the United States under the HFCAA if the SEC subsequently determines our audit work is performed by auditors that the PCAOB is unable to inspect or investigate completely. The prohibition from trading of the ADSs, or the threat of their being prohibited from being traded, may materially and adversely affect the value of your investment. The HFCAA was enacted on December 18, 2020. The…

The Registration Statement has been further revised to add the disclosure responsive to this comment in the section of the Registration Statement cited in the comment. U.S. Federal Income Tax Consequences, page 132 4.

The Fund confirms that it has revised the aforementioned disclosure in the Amendment in response to the Staff’s comment. 13.

In response to the Staff’s comment, the Company revised the relevant disclosures under the heading “Risks Related to Our Cryptocurrency Strategy and Holdings” starting on page 53 of the Revised F-3 to provided tailored risk factors specific to HYPE, SOL, and SUI and their respective blockchains, and removing references to risks related to bitcoin where relevant. HYPE, SOL, and SUI are highly volatile assets, and fluctuations in the price of HYPE, SOL, and SUI have in the past..., page S-48

In response to the Staff’s comment, the Company revised the relevant disclosures on page 57 of the Revised F-3 to provide quantitative information demonstrating the volatility of HYPE, SOL and SUI. Part II – Information Not Required in Prospectus Item

The above-referenced risk factors, in addition to “Prepayment Risk”, have been removed in accordance with the Staff’s comment.

The Registrant has considered the Staff’s comment and respectfully declines to make any changes. The Registrant believes that the disclosure, as currently presented, is appropriate for investor comprehension.

The Company respectfully acknowledges the comment. The Company has revised and updated the disclosure on page 58 in “Management’s Discussion and Analysis of Financial Condition and Results of Operations—Debt and Financing Arrangements—Convertible Note Financing” to quantify the potential share issuance upon conversion of all outstanding convertible notes if such notes were to be converted in connection with this Offering. Additionally, the Company has revised and updated the disclosure on page 58 in “Management’s Discussion and Analysis of Financial Condition and Results of Operations—Equity Offerings” to include a disclosure relating to the Company’s Regulation CF offering from August 2023 where the Company issued and sold 604,546 shares of common stock at a price of $4.9624 per share for gross proceeds of approximately $3.0 million. Such Regulation CF offering was closed on August 31,…

The disclosure will be revised accordingly on a going forward basis.

The Trust has revised the disclosure to address the comment. The Adviser has confirmed that the Fund may purchase and sell shares of Bullish in US dollars. * * * Please contact me at (913) 660-0778 regarding the responses contained in this letter. Sincerely, /s/ John H. Lively John H. Lively 2

The Company respectfully advises the Staff that the Notes were redeemed and are no longer outstanding, as disclosed in the Company’s Current Report on Form 8-K filed with the SEC on October 6, 2025. In addition, the Company has expanded this risk factor, to address potential dilution from the reset provision that could adjust upward the number of common shares underlying the Investor Warrants. The risk factor discloses the maximum number of shares that may be issuable upon exercise of the Investor Warrants. Plan of Distribution, page 67

The Company respectfully advises the Staff that owing to the Company’s October 16, 2025 termination of the EPFA, as disclosed in the Company’s Current Report on Form 8-K filed with the SEC on October 17, 2025, the Company is no longer registering for resale any additional shares of common stock pursuant to the EPFA, but is reverting to registering for resale only 5,218,690 shares on behalf of other Selling Shareholders. The Company further advises the Staff that on October 16, 2025, the Company filed with the SEC a request to withdraw the proxy statement on Schedule 14A because the Company has decided not to proceed with the transactions described in the proxy statement at this time. Accordingly, the Company believes the Staff’s comment is no longer appliable to the Registration Statement.

Recently, we have relied on one customer which has represented approximately 97% of our net sales as of June 30, 2025. We have begun to diversify our customer base to include some additional national grocery chains to diversify our customer base over the next year. We have added disclosure on pages 3 of Prospectus Summary section, 42 of MD&A section and 49 of Business section to disclose our customer dependence. We have also added a risk factor titled “We have depended on a single customer for a substantial portion of our net sales, and the loss of this customer or a reduction in their purchases could materially and adversely affect our business, results of operations, and financial condition.” Our third-party retailers are the same as our customers and we address the customer concentration as indicated above. Risk Factors Risks Relating to This Offering, page 28

We have added a risk factor titled “We have depended on a single customer for a substantial portion of our net sales, and the loss of this customer or a reduction in their purchases could materially and adversely affect our business, results of operations, and financial condition” and updated the section titled “Customer Concentration and Diversification Progress” on page 49 and added that section in the prospectus summary section as well on page 3. Liquidity and Capital Resources, page 40

We have added a supplier section on page 53 to describe the names of principal suppliers and to discuss the percentage of total product purchases and dependence on any one supplier. We have also added a risk factor called “We depend on a limited number of suppliers for our products, and the loss of one or more of these suppliers could disrupt our operations, increase our costs, or otherwise adversely affect our business” to that effect on page 13. Executive and Director Compensation, page 62

In response to the Staff’s comments, the Company has revised its disclosure on pages 36, 78-80, 179 and 186 of Amendment No. 1. The Company hereby provides assurance that when the matter of enforceability of jury trial waivers for “internal entity claims” in federal securities law is finally adjudicated, it will make future investors aware of such final adjudication and its scope for “internal entity claims” by including such disclosure in its future Exchange Act reports. The Organizational Documents Proposals

We confirm, on behalf of the Company, that the Company has revised the disclosure in the risk factor section and elsewhere to eliminate disclosure about the Company having a limited operating history as the subsidiaries of the Company have a long operating history prior to the incorporation of the Company in September 2022. Commission Comment : Property, page 50

Please refer to the last sentence of the revised text in Response 2. KAREN A. ASPINALL ● PARTNER 11300 Tomahawk Creek Pkwy, Suite 310 ● Leawood, KS 66211 ● p: 949.629.3928 Practus, LLP ● Karen.Aspinall@Practus.com ● Practus.com 4.

The Registrant has updated its Unsponsored Depositary Receipt Risk in Item 4 as provided in Response 7. 13.

The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 1, 26 and 27 of Amendment No. 1 to clarify that the Company’s current policy does not set a specific target with respect to the amount of digital assets held and to provide additional disclosure on the Company’s approach to accumulate and hold digital assets, focusing on SOL, for the long-term. The Company respectfully advises the Staff that it does not have a policy regarding monetization of its crypto assets given the current focus on accumulating and holding such assets. The Company has updated the disclosure on pages 2 and 27 of Amendment No. 1 to clarify that the Company does not currently hedge its exposure to SOL price fluctuations, but may do so in the future. In light of the current policies and procedures, the Company believes that the material and applicable risk factors are…

The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 1, 13 and 14 of Amendment No. 1 to clarify that the Company’s current policy does not set a specific target with respect to the amount of digital assets held and to provide additional disclosure on the Company’s approach to accumulate and hold digital assets, focusing on SOL, for the long-term. The Company respectfully advises the Staff that it does not have a policy regarding monetization of its crypto assets given the current focus on accumulating and holding such assets. The Company has updated the disclosure on pages 2 and 14 of Amendment No. 1 to clarify that the Company does not currently hedge its exposure to SOL price fluctuations, but may do so in the future. In light of the current policies and procedures, the Company believes that the material and applicable risk factors are…

Pursuant to the Staff’s comment, the referenced risk factor has been revised to include the following disclosure. XRP began trading in 2012 and in the United States in 2013, with a temporary suspension on many exchanges from late 2020 to mid-2023.

Pursuant to the Staff’s comment, the referenced risk factor has been revised to include the following disclosure: It is widely believed, though unconfirmed, that early founders of Ripple Labs, including Chris Larsen and Jed McCaleb, still hold significant amounts of XRP. This concentration of ownership could give them disproportionate influence over the system’s governance. In addition, any perceived selling activity from wallets purportedly linked to these individuals or other early XRP stakeholders could have a negative impact on the price of XRP. October 10, 2025 Page 3

Pursuant to the Staff’s comment, the referenced risk factor has been revised to include the following disclosure: In April 2025, a malware attack was discovered in a widely used open-source JavaScript library associated with the XRP Ledger. The malicious code was inserted through a supply chain vulnerability and had the potential to compromise applications built using the affected library. While the core XRP Ledger protocol and validator infrastructure were not directly compromised, some third-party applications that integrated the compromised library may have been exposed to risks, including unauthorized access to user data and disruption of application functionality. The vulnerability was identified and remediated by the developer community shortly after discovery, and no material exploitation of the malware has been publicly confirmed. However, the incident highlights the XRP…

The Trust has determined to use the services of Gemini Trust Company, LLC and BitGo Trust Company, Inc. as the custodians for the Trust. Both of these service providers utilize segregated wallets, not omnibus accounts, as part of their custodial solutions. Accordingly, the Registration Statement has been revised to remove references to omnibus XRP accounts where appropriate.