United States securities and exchange commission logo





                               December 13, 2023

       Guillermo Trias
       Chief Executive Officer/President of the Sponsor
       Tidal Commodities Trust I
       c/o Toroso Investments, LLC
       234 West Florida Street, Suite 203
       Milwaukee, WI 53204

                                                        Re: Tidal Commodities
Trust I
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted November
14, 2023
                                                            CIK No. 0001985840

       Dear Guillermo Trias:

            We have reviewed your amended draft registration statement and have
the following
       comments.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to this
letter and your amended
       draft registration statement or filed registration statement, we may
have additional comments.

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

       General

   1.                                                   Please revise to
describe the AML and KYC procedures conducted by the Fund and any
                                                        applicable service
providers.
   2.                                                   To the extent that you
intend to use an updated fact sheet, please provide a copy for our
                                                        review.
   3.                                                   Please provide us with
an update on the status of any review being conducted by the NFA
                                                        and provide us with
copies of any comments issued and your responses to those
                                                        comments. Please also
tell us whether there are any limitations, conditions or other
                                                        restrictions on your
activities as a commodity pool as it relates to your intentions to hold a
                                                        mix of bitcoin and
bitcoin futures.
 Guillermo Trias
FirstName LastNameGuillermo Trias
Tidal Commodities  Trust I
Comapany13,
December  NameTidal
              2023 Commodities Trust I
December
Page 2    13, 2023 Page 2
FirstName LastName
Prospectus Summary, page 1

4.       Please revise to disclose here whether the Fund is a passive or active
investment vehicle.
         Please also disclose, if true, that the Fund, the Sponsor and the
service providers will not
         loan or pledge the Fund's assets, nor will the Fund's assets serve as
collateral for any loan
         or similar arrangement.
5.       Please revise your disclosure here to provide quantitative information
that demonstrates
         the volatility of the price of bitcoin and Bitcoin Futures Contracts.
6.       Please revise your disclosure here to address the risks associated
with the competition you
         will face in launching and sustaining your product, including the risk
that your timing in
         reaching the market and your fee structure relative to other
bitcoin-related ETPs could
         have a detrimental effect on the scale and sustainability of your
product.
7.       Please revise to disclose here to provide quantitative information
that summarizes the
         historical range between the NAV per share and price of Shares in the
secondary market.
         Similarly, please revise to provide quantitative information that
summarizes the historical
         range between the Benchmark and the NAV of the Fund.
The Benchmark Methodology, page 2

8.       We note your disclosure on page 2 that the CIOC approves any material
changes to the
         methodology and reviews the Benchmark methodology at least on an
annual basis. Please
         revise to disclose whether Shareholders will be notified of any
material changes to the
         Benchmark, and, if so, how. In addition, please identify the Core
Exchanges of the
         Benchmark here. In this regard, we note that you identify the
Constituent Exchanges of
         the CF Bitcoin Reference Rate on page 4 but do not identify the
Benchmark Core
         Exchanges.
Bitcoin Future Contracts, page 3

9.       We note your disclosure on page 3 that you will invest in bitcoin, BTC
Contracts and
         MBT Contracts "to the extent necessary" to achieve exposure to the
bitcoin futures
         market. Please clarify here what you mean by "to the extent
necessary." In addition,
         please clarify what you mean by your statement that there is a
December CME Bitcoin
         Futures Contract "if there is only one contract expiring in December
at that point in time."
The Fund's Investment Strategies, page 4

10.      Please revise to disclose the number of BTC Contracts, MBT Contracts,
bitcoin, cash and
         cash equivalents that you hold as of the most recent practicable date,
and revise to
         describe your policies regarding (i) how you determine the percentage
of Bitcoin Futures
         Contracts and the percentage of bitcoin held by the Fund, (ii) the
amount of cash and cash
         equivalents held by the Fund and (iii) how often you engage in
transactions to rebalance
         the percentage of Bitcoin Futures Contracts and bitcoin held.
 Guillermo Trias
FirstName LastNameGuillermo Trias
Tidal Commodities  Trust I
Comapany13,
December  NameTidal
              2023 Commodities Trust I
December
Page 3    13, 2023 Page 3
FirstName LastName
11.      Please revise to disclose the CME dynamic price fluctuation limits for
Bitcoin Future
         Contracts, and discuss how frequently such limits have historically
been imposed. In
         addition, we note your disclosure on page 6 that "[i]f the CME halted
trading in Bitcoin
         Futures Contracts for other reasons, including if trading were halted
for an entire trading
         day or several trading days, the Fund would value its Bitcoin Futures
Contracts by using
         the settlement price that the CME publishes." Please describe the
price that the CME
         would publish if the trading of Bitcoin Futures Contracts is halted.
The Fund's Investments in Bitcoin, page 7

12.      Please revise to describe the "Investment Restrictions on Spot
Bitcoin" and disclose your
         Spot Bitcoin Limits, including quantification in dollars of those
limits in recent periods in
         order to provide context around how those limits may impact the
composition of your
         assets. In addition, please revise to summarize here and describe in
greater detail on page
         53 the mechanics of how you purchase and sell bitcoin and Bitcoin
Futures Contracts
         in EFP transactions, including (i) whether you sell and purchase first
to expire or second
         to expire BTC Contracts and/or MBT Contracts, (ii) whether you use the
CME's daily
         settlement prices from the prior day as the reference price for the
Bitcoin Futures
         Contracts sold or purchased in the EFP transactions, and, if not, how
and when you
         calculate the reference price of the Bitcoin Futures Contracts, (iii)
how and when you
         calculate the reference price of the bitcoin sold or purchased in the
EFP transactions, (iv)
         whether you use the Direct Request for Quote available in the CME
Direct, (v) the
         mechanics of how the bitcoin is transferred in connection with the EFP
transactions and
         (vi) how the CME ensures that the EFP transactions are executed at
"commercially
         reasonable prices," including a description of what is deemed to be a
commercially
         reasonable price. In this regard, we note your disclosure that you use
the FBSP as the
         reference price for the bitcoin and the settlement price as the
reference for the Futures
         Contracts and that all purchases or sales of bitcoin are settled
on-chain.
13.      Please describe how the Investment Restrictions on Spot Bitcoin
mitigate the risk of
         manipulation of the Shares of the Fund and the bitcoin spot market,
and clarify how a
         change of the SEC's view of the CME Bitcoin Futures market as a
regulated market of
         significant size, the NAV of the Fund and the prevailing trading
conditions on the Core
         Exchanges of the Benchmark impact the Investment Restrictions on Spot
Bitcoin.
14.      We note your reference here to executing bitcoin transactions in a
"regulated
         environment." Please revise to clarify, if true, that these
transactions do not take place on
         a regulated exchange, and balance your disclosure by describing the
relevant risks
         involved.
The Offering, page 12

15.      Your disclosure on page 13 that "[t]he Sponsor determines the value of
the spot
         bitcoin held by the Fund based on a methodology that is entirely
derived from the
         settlement prices of Bitcoin Futures Contracts on the CME and that
[the Sponsor]
 Guillermo Trias
Tidal Commodities Trust I
December 13, 2023
Page 4
         considers all available facts and all available information on the
valuation date" is
         inconsistent with your disclosure regarding the Benchmark methodology.
Please revise
         for clarity here so that investors understand how the spot bitcoin
holdings and Bitcoin
         Futures Holdings of the Fund are calculated for the purpose of
determining the NAV and
         the NAV per Share of the Fund in connection with creations and
redemptions.
16.      Please revise to disclose whether any of the expenses paid by the
Sponsor are capped. In
         addition, your disclosure on page 13 that the "[g]eneral expenses of
the Trust will be
         allocated among the Fund and any future series of the Trust as
determined by the Sponsor
         in its discretion" and your disclosure on page 37 that the Sponsor has
the authority to
         "allocate expenses to and between the funds of the Trust" is
inconsistent with your
         disclosure on page 12 that "[t]he Trust has been formed and will be
operated with the goal
         that the Fund and any other series of the Trust will be liable only
for obligations of such
         series, and a series will not be responsible for or affected by any
liabilities or losses of or
         claims against any other series." Please revise for clarity and
consistency.
17.      Please expand your summary of the Bitcoin Custodian to disclose the
proportion of
         private keys that will be held in hot or cold storage, whether the
assets stored by the
         Bitcoin Custodian will be commingled with assets of other customers
and whether and to
         what extent the Custodian carries insurance for any losses of the
Fund's custodied bitcoin.
What are the Risk Factors Involved with an Investment in the Fund
Risks Related to Bitcoin and the Bitcoin Network, page 15

18.      Please add risk factors addressing front-running and wash trading in
the spot bitcoin
         markets.
"Forks" in the Bitcoin Network could have adverse effects, page 16

19.      Please revise to disclose the Fund's policies related to forks and air
drops, the terms of the
         Bitcoin Custodian's agreement that address forks and airdrops and
whether the Sponsor
         has provided any instructions to the Bitcoin Custodian regarding forks
and air drops.
Rewards for mining bitcoin are designed to decline over time, page 17

20.      Please expand this risk factor to describe the halving of bitcoin
mining rewards, including
         the timing of the halving events and quantitative information related
to the historical,
         current and future size of the bitcoin mining rewards.
Environmental risks from Bitcoin mining, page 21

21.    Please expand this risk factor to address the reasons why bitcoin mining
may implicate
FirstName LastNameGuillermo Trias
       different risks than other crypto asset mining such as the differences
in proof-of-work and
Comapany    NameTidaland
       proof-of-stake,   Commodities
                            discuss theTrust I
                                        regulations that U.S. states and
foreign jurisdictions have
       passed
December   13, or are Page
               2023   currently
                           4 considering that impact crypto asset mining.
FirstName LastName
 Guillermo Trias
FirstName LastNameGuillermo Trias
Tidal Commodities  Trust I
Comapany13,
December  NameTidal
              2023 Commodities Trust I
December
Page 5    13, 2023 Page 5
FirstName LastName
Risks Related to Lack of Liquidity
Authorized Purchasers' buying and selling activity, page 25

22.      Your disclosure that Authorized Purchasers will purchase bitcoin in
connection with
         creation orders and sell bitcoin in connection with redemption orders
is inconsistent with
         your disclosure on page 32 and throughout that purchases and
redemptions will be
         transacted in cash rather than in-kind. Similarly, in the second to
last risk factor on page
         32 you reference the Authorized Purchasers' ability to purchase and
sell bitcoin in an
         efficient manner to effectuate creation and redemption orders and in
the last risk factor on
         page 32 you state that Shares surrendered by Authorized Purchasers are
redeemable in
         exchange for the underlying amount of bitcoin. Please revise as
necessary.
Arbitrage transactions intended to keep the price of Shares, page 26

23.      Please expand this risk factor to provide examples of "unanticipated
difficulties" in
         creations and redemptions.
Regulatory Risk, page 27

24.      Please add risk factors and expand the risk factors in this subsection
to identify and
         discuss material legislation or regulation, including pending
legislation or regulation,
         related to bitcoin, the bitcoin market, crypto assets and the crypto
asset markets in the U.S.
         and in foreign jurisdictions.
There are technical and fundamental risks inherent in the trading system, page
30

25.      Please revise to clarify the risks that this risk factor is addressing
by explaining what you
         mean by "other investment fund complex" and why the Sponsor's
discontinuation in
         activities related to "other investment fund complex" could adversely
affect the Fund,
         clarify what you mean by the quantitative models upon which the
Sponsor's trading
         systems are based and clarify the types of trading decisions you are
addressing in this risk
         factor.
The Fund could terminate at any time and cause liquidation, page 31

26.      We note your disclosure on page 31 that "[i]f the Sponsor and the Fund
are unable to raise
         sufficient funds so that the expenses are reasonable in relation to
the Fund's NAV, the
         Fund may be forced to terminate, and investors may lose all or part of
their investment."
         Please revise to quantify or otherwise describe what "reasonable in
relation to the Fund's
         NAV" means. In addition, we note your disclosure on page 36 that "[t]o
the extent that
         the Fund does not grow to or maintain a viable size, it may be
liquidated, and the
         expenses, timing and tax consequences of such liquidation may not be
favorable to some
         Shareholders." Please revise to quantify or otherwise describe what a
"viable size" means.
 Guillermo Trias
FirstName LastNameGuillermo Trias
Tidal Commodities  Trust I
Comapany13,
December  NameTidal
              2023 Commodities Trust I
December
Page 6    13, 2023 Page 6
FirstName LastName
Fund assets may be depleted if investment performance does not exceed fees,
page 32

27.      We note your disclosure on page 32 that "[i]n addition to certain fees
paid to the Fund   s
         service providers, the Fund pays the Sponsor a fee of 0.94% of assets
under management
         per annum, regardless of Fund performance." Please identify the fees
paid to the Fund's
         service providers that are not paid by the Sponsor out of the
Management Fee.
If a minimum number of Shares is outstanding, market makers may be less
willing, page 33

28.      Please revise this risk factor to disclose whether you have in the
past halted redemptions
         due to the number of Shares outstanding. In this regard, we note that,
according to your
         website, on November 15, 2023, you had 50,000 Shares outstanding.
Potential Conflicts of Interest
The Sponsor's principals, officers or employees may trade bitcoin, page 37

29.      Please expand this risk factor to include affiliates of the Sponsor,
and disclose here that
         the Administrator is an affiliate of the Sponsor.
Operation of the Fund, page 49

30.      Please revise to reconcile your disclosure here that the Fund expects
that the Fund   s assets
         will be used to invest in Bitcoin Futures Contracts and cash and cash
equivalents with the
         disclosure throughout the prospectus that the Fund also intends to use
its assets to invest in
         bitcoin.
The Offering
The Fund's Investments in Spot Bitcoin
Custody of Bitcoin, page 54

31.      Please revise to describe the material terms of the Fund's agreement
with the
         Bitcoin Custodian, including the term and a detailed description of
the termination
         provisions that includes quantitative information regarding the
"applicable notice" to the
         Fund and to the Sponsor in connection with the Bitcoin Custodian's
decision to terminate
         the BitGo Agreement for cause, the "applicable notice" to the Bitcoin
Custodian should
         the Sponsor choose to terminate the agreement and the termination fee
that the Sponsor
         must pay in connection with terminating the agreement prior to its
term. In addition,
         please disclose (i) the percentage of the Trust's private keys held in
cold storage, (ii) the
         geographic location of where the Fund's assets will be stored, (iii)
the degree to which the
         insurance policy protects the Fund's assets held by the Bitcoin
Custodian so that investors
         understand both whether the insurance only covers the theft of assets
directly related to
         the Bitcoin Custodian's custody of the private keys and how the
coverage would be
         distributed among impacted Bitcoin Custodian clients, (iv) the Bitcoin
Custodian's
         policies related to Incidental Rights, (iv) whether the Sponsor has
provided instructions to
         the Bitcoin Custodian regarding airdrops or forks, (v) whether the
counterparties in the
 Guillermo Trias
FirstName LastNameGuillermo Trias
Tidal Commodities  Trust I
Comapany13,
December  NameTidal
              2023 Commodities Trust I
December
Page 7    13, 2023 Page 7
FirstName LastName
         EFP transactions transfer the bitcoin to the Bitcoin Custodian and
(vi) whether the Bitcoin
         Custodian in the EFP transactions transfers the bitcoin to the
counterparties. Also, we
         note your disclosure that clients may purchase additional insurance
coverage in their own
         name through the BitGo underwriter. Please revise to disclose whether
the Fund has done
         so, and, if so, the amount of coverage this provides.
32.      Please add a section that describes the agreement and material terms
of the custody
         agreement with the Custodian.
Other Trading Policies of the Fund
Exchange for Related Position, page 58

33.      Please expand this section to describe the Fund's policies related to
when it would engage
         in EFRP transactions in connection with the creation and redemption of
Shares.
The Fund's Investments in Cash and Cash Equivalents, page 58

34.      You state that most of the Fund   s investments are in cash and cash
equivalents that
         support the Fund   s positions in bitcoin and Bitcoin Futures
Contracts. Please revise to
         clarify how the Fund's investments in cash and cash equivalents
support the Fund's
         positions in spot bitcoin.
The Benchmark
Benchmark Calculation, page 59

35.      Please revise your disclosure to discuss the CIOC, including a brief
discussion of how and
         when the methodology is reviewed for purposes of considering whether
to modify the
         methodology or the list of Core Exchanges. Also include a brief
description of each Core
         Exchange, including where it is located and how it is licensed and
regulated. In addition,
         please revise to disclose the minimum trading volume necessary to
qualify as a Core
         Exchange. Further, please revise to include a discussion of the
Benchmark's contingency
         measures in the event of the absence of or insufficient inputs.
36.      Please revise to disclose how the real-time NQBTC is calculated and
where it is
         published. Similarly, please disclose when and where the NQBTCS is
published.
The Fund's Service Providers
Support Agreement, page 64

37.      Please revise to disclose the term and termination provisions of the
Support Agreement,
         and please revise to disclose the Prior Sponsor's obligations pursuant
to the Support
         Agreement.
Contractual Fees and Compensation Arrangements with the Sponsor and Third-Party
Service
Providers, page 67

38.      Please revise this table to include the fees and compensation
arrangements with all of the
 Guillermo Trias
FirstName LastNameGuillermo Trias
Tidal Commodities  Trust I
Comapany13,
December  NameTidal
              2023 Commodities Trust I
December
Page 8    13, 2023 Page 8
FirstName LastName
         Service Providers or include footnotes to the table to indicate which
Service Provider fees
         are not included in the table.
Other Non-Contractual Payments by the Fund, page 67

39.      Please revise this section to disclose whether the Sponsor pays any
expenses related to the
         EFP transactions for the sale and purchase of spot bitcoin, including
any bitcoin
         transaction fees for on-chain transfers of bitcoin. In addition, we
note that the Authorized
         Purchasers pay a $300 fee for each creation and redemption order.
Please revise to
         disclose whether these fees may be used by the Fund to cover expenses
related to the
         creations and redemptions.
Calculating NAV, page 70

40.      We acknowledge your response to prior comment 7 and the related
changes to your
         disclosure. Please note we are continuing to evaluate your response.
In the interim,
         please address the following with respect to your valuation of bitcoin
for financial
         statement purposes:
             Provide us with your revised financial statement accounting policy
for determining
              the fair value of bitcoin in accordance with ASC Topic 820;
             Tell us, and revise your disclosure to clearly state, whether you
believe the
              methodology used to calculate the Fund's bitcoin holdings is
consistent with U.S.
              GAAP;
             As the trust is expected to primarily transact with the bitcoin
markets through the
              Authorized Participant, confirm for us that your determination of
the principal market
              will be from the perspective of the Authorized Participant;
             Tell us if you and/or your Authorized Participant plan to transact
in multiple
              markets. If so, please ensure that your accounting policy
reflects that fact and
              describes the types of markets in which you and/or your
Authorized Participant
              expect to transact. In that regard, we note that ASC
820-10-35-36A includes
              definitions of four types of markets (e.g. brokered market,
dealer market, exchange
              market, and principal to principal market);
             Confirm for us that your principal market will be one which you
and/or your
              Authorized Participant will be able to access and clarify whether
you anticipate your
              principal market to be one in which you and/or your Authorized
Participant will
              normally transact. Refer to ASC Topics 820-10-35-6A and
820-10-35-5A,
              respectively; and
             Tell us how the third-party vendor will be involved in determining
the fair value of
              bitcoin for financial statement purposes, including the
determination of the principal
              market. In that regard, we note your disclosure that you will
engage a third-party
              vendor to obtain a price from "a" principal market for bitcoin.
Please confirm for us
              that you expect the third-party vendor to determine the principal
market for the
              reporting entity, and not a principal market for bitcoin in
general (as suggested by
              your disclosure). Reference is made to ASC Topic 820-10-35-6A
which indicates the
 Guillermo Trias
FirstName LastNameGuillermo Trias
Tidal Commodities  Trust I
Comapany13,
December  NameTidal
              2023 Commodities Trust I
December
Page 9    13, 2023 Page 9
FirstName LastName
              principal market shall be considered from the perspective of the
reporting entity.
41.      We note your disclosure on page 52 states that the BRR is published at
4:00 p.m. London
         time but, on page 70, you disclose that the Sub-Administrator uses the
settlement price
         reported by the CME between 14:59 and 15:00 CT and that the NAV for a
particular day
         is released after 4:15 p.m. ET. Please revise here to disclose how the
BRR calculated by
         the CME is used to calculate the value of the Bitcoin Futures and the
spot bitcoin held by
         the fund in order to determine the NAV and the NAV per Share for the
purposes of
         creations and redemptions. In addition, please revise to disclose the
calculation used by
         the BRR, including how the data from the Constituent Exchanges is used
and include a
         brief description of each Constituent Exchange, including how they are
selected as a
         Constituent Exchange, the volume of each, the market share of each,
the location of each
         and how each is licensed and regulated. In addition, please provide a
brief description of
         the contingency provisions of the BRR methodology.
42.      Please revise to disclose the methodology used to calculate the NAV of
the Fund for
         purposes of creations and redemptions if the BRR is not published. In
addition, please
         disclose how ICE Data Indices, LLC calculates the indicative fund
value.
Creation and Redemption of Shares
Determination of Required Deposits, page 74

43.      We note your disclosure on page 74 that "[t]he Sponsor determines,
directly in its sole
         discretion or in consultation with the Custodian and the
Sub-Administrator, the
         requirements for cash and/or cash equivalents, including the remaining
maturities of the
         cash equivalents, which may be included in deposits to create
baskets." Please revise to
         disclose the criteria that the Sponsor considers in regards to whether
cash equivalents will
         be accepted as payment for Shares, including the maximum maturities of
cash equivalents
         that the Sponsor will accept. Similarly, please disclose the criteria
the Sponsor considers
         in regards to whether cash equivalents will be used in connection with
redemptions. In
         addition, we note your disclosure that "[i]f cash equivalents are to
be included in a
         Creation Basket Deposit for orders placed on a given business day, the
Sub-Administrator
         will publish an estimate of the Creation Basket Deposit requirements
at the beginning of
         such day." Please tell us why the Sub-Administrator only provides an
estimate of the
         Creation Basket Deposit if the Sponsor has determined that it will
accept cash equivalents
         as payment for Shares.
44.      Please disclose the policies related to purchasing Bitcoin Futures
Contracts after receiving
         cash or cash equivalents in connection with creations, including
whether the amounts due
         to the Sponsor for the Management Fee and other Fund expenses are
taken into
         consideration when determining the number of Bitcoin Future Contracts
that may be
         purchased after receiving cash or cash equivalents for creations.
Similarly, disclose the
         policies related to selling Bitcoin Futures Contracts or bitcoin in
connection
         with redemptions.
 Guillermo Trias
Tidal Commodities Trust I
December 13, 2023
Page 10
45.      Please revise to add disclosure clarifying whether the Authorized
Participants bear the risk
         of price movements of the underlying assets of the Shares with respect
to cash creations
         and redemptions.
46.      Please revise to disclose the impact of the use of cash creations and
redemptions on the
         efficiency of the arbitrage mechanism and how this compares to the use
of in-kind
         creations and redemptions.
Suspension and Rejection of Purchase Orders, page 74

47.      Please revise to provide a description of what is deemed to be an
emergency affecting the
         handling of cash equivalents such that the Sponsor may choose to
suspend the purchase
         order to delay its settlement, and please disclose what is deemed to
be an emergency such
         that the delivery, disposal or evaluation of cash equivalents in not
reasonably practicable
         in connection with redemption orders. In addition, revise to disclose
whether and how
         you will notify Shareholders if the Trust has suspended creations and
redemptions, and
         describe the potential impact of suspending creations and redemptions.
Use of Proceeds, page 77

48.      Please revise to provide a materially complete description of the
mechanics of purchasing
         and selling spot bitcoin for the Fund. Please describe, for example,
which party will enter
         into EFP transactions on behalf of the Fund, whether the Fund has
identified any private
         counterparties with which it intends to trade, whether there is a risk
that the Fund will be
         able to negotiate transactions in sufficient quantities to meet its
investment objective and
         whether the Fund expects to enter into EFP transactions whenever there
is a creation or
         redemption order. Please also explain what you mean by the statement
that the physical
         leg of the transaction will be settled bilaterally, including a
description of how the bitcoin
         will be transferred from the EFP counterparty to the Bitcoin
Custodian, and vice versa.
The Sponsor Has Conflicts of Interest, page 80

49.      Please revise to disclose whether there is a code of conduct or other
requirements for pre-
         clearance of bitcoin-related transactions that apply to the Sponsor's
affiliates.
Information You Should Know, page 100

50.    Please revise to include the following for the Hashdex Bitcoin Futures
ETF, a series of the
       Teucrium Commodity Trust, or tell us why you are not required to provide
the
       information:
           Management's discussion and analysis of financial condition and
results of operations
FirstName LastNameGuillermo
           (refer to Item 303 of Trias
                                 Regulation S-K); and
Comapany   NameTidal Commodities
           Quantitative                  Trust
                         and qualitative     I
                                         disclosures about market risk (refer
to Item 305 of
           Regulation
December 13,   2023 PageS-K).
                           10
FirstName LastName
 Guillermo Trias
FirstName LastNameGuillermo Trias
Tidal Commodities Trust I
Comapany13,
December  NameTidal
              2023 Commodities Trust I
December
Page 11 13, 2023 Page 11
FirstName LastName
Hashdex Bitcoin Futures ETF, a series of the Tidal Commodities Trust I
Financial Statements, page F-1

51.      We note that you have provided an audited balance sheet for Hashdex
Bitcoin Futures
         ETF, a series of Tidal Commodities Trust I, the sole fund as of
October 24, 2023. Please
         note that audited financial statements must also be provided for the
registrant, Tidal
         Commodities Trust I. Refer to Question 104.01 of the Compliance and
Disclosure
         Interpretations for Securities Act Sections.
52.      We note that you included placeholders in the filing for the audit
reports of Hashdex
         Bitcoin Futures ETF, a series of the Tidal Commodities Trust I, and
Hashdex Bitcoin
         Futures ETF, a series of the Teucrium Commodity Trust. In your next
amendment, please
         include those audit reports if they are available.
Note 1. Organization and Significant Accounting Policies, page F-3

53.      Please include accounting policies for creations and redemptions and
calculating the net
         asset value.
Hashdex Bitcoin Futures ETF, a series of the Teucrium Commodity Trust
Financial Statements, page F-6

54.      On pages F-7 through F-12 you refer to the Predecessor Fund. Please
revise to include the
         name of the entity.
       Please contact Kate Tillan at 202-551-3604 or Michelle Miller at
202-551-3368 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Sonia Bednarowski at 202-551-3666 or Justin Dobbie at 202-551-3469 with
any other
questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Crypto
Assets