February 5, 2018
United States Securities and Exchange Commission
100 F Street N.E.
Washington, D.C. 20549
Attn: Tom Kluck
| Division of Corporation Finance |
| Re: | Pre-Effective Amendment No. 1 to Registration Statement on FormS-3 |
| (ProShares Trust II; Filed February 1, 2018; File No. 333-220688) |
Dear Mr. Kluck:
We hereby request that the effective date for the above-captioned Registration Statement be accelerated so that it will be declared effective under the Securities Act of 1933, as amended, on or about 4:00 p.m., Eastern Time, on Tuesday, February 6, 2018, or as soon thereafter as reasonably practicable.
If the Staff has any questions regarding this request, please contact Robert J. Borzone, Jr. at (240)497-6578 or me at(240) 497-6579.
Thank you for your time and attention to this matter.
| Very truly yours, | ||
| By: | /s/ Richard F. Morris | |
Richard F. Morris General Counsel | ||