 | Sullivan & Worcesterllp 1666 K Street, NW Washington, DC 20006 | T 202 775 1200 F 202 293 2275 www.sandw.com |
| March 6, 2018 |
VIA EDGAR
EDGAR Operations Branch
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
ETF Managers Group Commodity Trust I
Registration Statement on Form S-1
CIK - 0001610940
Ladies and Gentlemen:
Enclosed for filing electronically is Pre-Effective Amendment No. 3 to the Registration Statement on Form S-1 for ETF Managers Group Commodity Trust I (the “Trust”). This filing is being made to register shares of the Breakwave Dry Bulk Shipping ETF, a new series of the Trust, and incorporates changes made in response to SEC and NFA comments.
Any questions or comments with respect to this filing may be directed to the undersigned at (202) 775-1232.
| Very truly yours, | |
| /s/ Eric Simanek | |
| Enclosures | |
| cc: David C. Mahaffey, Esq. |
BOSTON NEW YORK WASHINGTON, DC