Hashdex Commodities Trust 10-K

Item 1B. Unresolved Staff Comments There are no unresolved staff comments. Item 1C. Cybersecurity Because the Trust has no directors, principal officers or employees, the Sponsor is responsible for managing cybersecurity risks to the Fund. The Sponsor has an information security program and policy in place, as mandated by new Regulation S-K Item 106. This program is designed to assess, identify, and manage material risks from cybersecurity threats. Regular reviews of cybersecurity and information technology plans are conducted for key service providers, as part of the Sponsor’s disaster recovery and business continuity planning process. Additionally, the Sponsor evaluates whether any cybersecurity threats, including those resulting from previous incidents, have materially affected or are reasonably likely to materially affect the Trust and the Fund. The Sponsor’s Vice President of IT & Cybersecurity , Mr. Tiago DeMesquita, is responsible for identifying, assessing and managing the Sponsor’s risks from cybersecurity threats. Mr. DeMesquita has over 5 years of experience in technology and cybersecurity. Mr. DeMesquita heads the Cybersecurity Committee of the Sponsor which meets regularly to evaluate strategies, governance, risk management, compliance, engineering and development, security operations, and incident management. In addition, the Sponsor maintains a cybersecurity insurance policy. 39 Item 2. Properties The principal offices of the Sponsor, the Trust and the Fund are leased and are located at 234 West Florida Street, Suite 203, Milwaukee, Wisconsin 53204. Item 3. Legal Proceedings Neither the Trust, Fund or Sponsor are currently subject to any material legal proceedings, nor, to our knowledge, are any material legal proceedings threatened against Trust, Fund or Sponsor. Item 4. Mine Safety Disclosures Not applicable. PART II