March 27, 2018
United States Securities and Exchange Commission
100 F Street N.E.
Washington, D.C. 20549
Attn: Kim McManus
Senior Attorney
Office of Real Estate and Commodities
| Re: | Pre-Effective Amendment No. 2 to Registration Statement on Form S-1 for ProShares Trust II |
(ProShares Trust II File No. 333-223012)
Dear Ms. McManus:
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, as of 4:00 p.m. on March 29, 2018, or as soon thereafter as reasonably practicable.
If the Staff has any further comments or questions regarding this filing, please contact me at (240) 497-6400. Thank you for your time and attention to this matter.
Very truly yours,
By: /s/ Richard F. Morris
Richard F. Morris
General Counsel