ProShare Capital Management LLC
7501 Wisconsin Avenue
Suite 1000E
Bethesda, MD 20814-6527
Phone: 240.497.6400
Fax: 240.497.6530
www.ProShares.com
September 4, 2020
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attn: | Mr. John D. Brown, Attorney Advisor | |
Division of Corporation Finance | ||
Office of Finance |
Re: Registration Statement on Form S-3 for ProShares Trust II (File No. 333-244420)
Dear Mr. Brown:
On behalf of ProShares Trust II, 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 5:00 p.m. on September 9, 2020, 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, | ||
ProShare Capital Management LLC | ||
By: | /s/ Richard F. Morris | |
Richard F. Morris | ||
General Counsel |