VanEck Bitcoin Trust
c/o VanEck Digital Assets, LLC
666 Third Avenue, 9th Floor
New York, New York 10017

    VIA EDGAR   Ms. Sandra Hunter Berkheimer, Esq.
Ms. Lulu Cheng, Esq.
Office of Crypto Assets
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549   January 9, 2024

Re: Request for Acceleration of Effectiveness
VanEck Bitcoin Trust
Registration Statement on Form S-1

File No. 333-251808

Dear Mses. Berkheimer and Cheng

In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Securities Act”), VanEck Bitcoin Trust (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 5:00 p.m., New York City time, on January 10, 2024, 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 Clifford R. Cone at (212) 878-3180 or Jason D. Myers at (212) 878-8324.

Sincerely,

VanEck Digital Assets, LLC

Sponsor of VanEck Bitcoin Trust

By:      /s/ Jonathan R. Simon

Name: Jonathan R. Simon

Title: Senior Vice President, General Counsel and Secretary

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
	Clifford R. Cone, 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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