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                             October 7, 2022

       Michael Sonnenshein
       Chief Executive Officer
       Grayscale Zcash Trust (ZEC)
       290 Harbor Drive, 4th Floor
       Stamford, CT 06902

                                                        Re: Grayscale Zcash
Trust (ZEC)
                                                            Amendment No. 3 to
                                                            Registration
Statement on Form 10
                                                            Filed September 23,
2022
                                                            File No. 000-56433

       Dear Michael Sonnenshein:

              We have reviewed your filing and have the following comments. In
some of our
       comments, we may ask you to provide us with information so we may better
understand your
       disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Exhibit 99.1

       General

   1.                                                   Refer to your responses
to comment 2 in our June 13, 2022 letter and related comments.
                                                        While we do not have
any further comments at this time regarding your responses, please
                                                        confirm your
understanding that our decision not to issue additional comments should not
                                                        be interpreted to mean
that we either agree or disagree with your responses, including any
                                                        conclusions you have
made, positions you have taken and practices you have engaged in
                                                        with respect to this
matter.
 Michael Sonnenshein
FirstName  LastNameMichael
Grayscale Zcash Trust (ZEC) Sonnenshein
Comapany
October    NameGrayscale Zcash Trust (ZEC)
        7, 2022
October
Page 2 7, 2022 Page 2
FirstName LastName
        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.

        You may contact Ben Phippen at 202-551-3697 or Amit Pande, Accounting
Branch
Chief, at 202-551-3423 if you have questions regarding comments on the
financial statements
and related matters. Please contact Christopher Wall at 202-551-4162 or Sonia
Bednarowski at
202-551-3666 with any other questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Finance