ProShare Capital Management LLC
7501 Wisconsin Avenue
Suite 1000E
Bethesda, MD 20814-6527
Phone: 240.497.6400
Fax: 240.497.6530
www.ProShares.com
December 20, 2018
VIA EDGAR CORRESPONDENCE
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Attn: Mr. Joshua Lobert
Re: | Pre-Effective Amendment No. 1 to Registration Statement on Form S-1 for ProShares Trust II (File No. 333-228620) |
Dear Mr. Lobert:
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 December 20, 2018, or as soon thereafter as reasonably practicable.
If the Staff has any further comments or questions regarding this filing, please contact the undersigned or Omar Bardouil at (240) 497-6400. Thank you for your time and attention to this filing.
Very truly yours,
By: /s/ Richard F. Morris
ProShare Capital Management LLC
General Counsel