Invesco CurrencyShares Canadian Dollar Trust (FXC) S-1/A IPO registration (amended)

                         Rydex Specialized Products LLC
                         9601 Blackwell Road, Suite 500
                               Rockville, MD 20850




                                  June 13, 2006




Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Mail Stop 4569
Washington, DC 20549-4561
Attention: Christian N. Windsor, Esq.
           Michael Clampitt, Esq.


           Re:   CurrencyShares Canadian Dollar Trust -
                 Registration Statement on Form S-1
                 Amendment No. 2 (Registration No. 333-132363)


Gentlemen:

         Pursuant to Rule 461 under the Securities Act of 1933, as amended, the
undersigned, the Chief Executive Officer of Rydex Specialized Products LLC, the
sponsor (the "Sponsor") of the CurrencyShares Canadian Dollar Trust (the
"Trust"), on behalf of the Trust hereby requests that the above-referenced
Registration Statement be declared effective by the Securities and Exchange
Commission (the "Commission") on Thursday, June 14, 2006, at 11:30 a.m. Eastern
Daylight Saving Time, or as soon as practicable thereafter.

         We hereby acknowledge that:

         o    should the Commission or the staff, acting pursuant to delegated
              authority, declare the filing effective, it does not foreclose
              the Commission from taking any action with respect to the filing;

         o    the action of the Commission or the staff, acting pursuant to
              delegated authority, in declaring the Registration Statement
              effective, does not relieve the Sponsor on behalf of the Trust
              from its full responsibility for the adequacy and accuracy of the
              disclosure in the filing; and

         o    the Sponsor and the Trust may not assert the declaration of
              effectiveness as a defense in any proceeding initiated by the
              Commission or any person under the federal securities laws of the
              United States.





Securities and Exchange Commission
June 13, 2006
Page 2




         Please contact counsel for the Trust, Patrick Daugherty at (313)
234-7103 or Yvette M. VanRiper at (313) 234-7107, should you have any questions
or comments regarding this request.


                                               RYDEX SPECIALIZED PRODUCTS LLC

                                               By: /s/ Michael Byrum
                                                   Michael Byrum
                                                   Secretary
cc:   Mr. Timothy Meyer
      Mr. J. Stuart Thomas
      Mr. George Simon
      Mr. Patrick Daugherty
      Ms. Yvette M. VanRiper