May 10, 2022
VIA EDGAR
David Lin
Division of Corporation Finance
Securities and Exchange Commission
100 F. Street N.E.
Washington, D.C. 20549
| Re: | ConvexityShare Trust |
| Pre-Amendment No. 2 to the Draft Registration Statement on Form S-1 | |
| CIK No. 0001817218 |
Dear Mr. Lin,
This letter sets forth a response to the comment received by telephone on May 9, 2022, pertaining to the above referenced amended Registration Statement on Form S-1 (the “Registration Statement”) submitted by ConvexityShares Trust (the “Registrant”) on April 29, 2022 for the purpose of registering the shares of the ConvexityShares Daily 1.5x SPIKES Futures ETF and ConvexityShares 1x SPIKES Futures ETF (the “Funds”). Unless otherwise noted, capitalized terms have the same meanings as used in the Registration Statement.
Set forth below is the comment and the Registrant’s response thereto.
| 1. | Comment: It appears that the conformed signature was inadvertently omitted from the “REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM.” |
Response: The conformed signature has been added to the Report of the Independent Registered Public Accounting Firm.
Best regards,
| /s/ Eric Simanek | |
| Eric Simanek | |
| 202-775-1232 | |
| esimanek@sullivanlaw.com |