April 28, 2023
Anu Dubey
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Re: SmartTrust 613 (the “Fund”)
(CIK# 1936080)
Ms. Dubey:
Transmitted herewith on behalf of Hennion & Walsh, Inc. (the “Sponsor”), sponsor, depositor and principal underwriter of the Fund, is a correspondence filing in response to comment 8 from the letter dated April 24, 2023 from Anu Dubey of the staff of the U.S. Securities and Exchange Commission (the “Commission”) regarding the Fund. We have separately addressed the staff’s other comments from that letter in Amendment No. 1 to the Registration Statement on Form S-6 for the Fund filed on April 28, 2023.
Below is the anticipated portfolio for the Technology Revolution Trust II along with the corresponding “segment” associated with each issuer as defined and determined by Syntax LLC for purposes of the Syntax North America Technology Revolution Index. The portfolio is subject to change and the final portfolio for the trust will be determined at the time of deposit. The final trust portfolio will be reflected in the final Registration Statement for the Fund filed on the trust’s date of deposit.
| Name of Issuer | Ticker Symbol | Syntax Business Segment |
| Opera Ltd | OPRA | High Performance Compute/Artificial Intelligence |
| Fair Isaac Corp | FICO | Banking, Insurance, & Investment Technology |
| Belden Inc | BDC | Robotics |
| Digi International Inc | DGII | Internet of Things |
| ATS Corp | ATS.CT | Robotics |
| Thermon Group Holdings Inc | THR | Internet of Things |
| International Money Express Inc | IMXI | Banking, Insurance, & Investment Technology |
| Interactive Brokers Group Inc | IBKR | Banking, Insurance, & Investment Technology |
| Dexcom Inc | DXCM | Internet of Things |
| Enova International Inc | ENVA | Banking, Insurance, & Investment Technology |
| Plexus Corp | PLXS | Robotics |
| WEX Inc | WEX | Banking, Insurance, & Investment Technology |
| TMX Group Ltd | X.CT | Banking, Insurance, & Investment Technology |
| CACI International Inc | CACI | Cybersecurity |
| Fortinet Inc | FTNT | Cybersecurity |
| Nasdaq Inc | NDAQ | Banking, Insurance, & Investment Technology |
| Nice Ltd | NICE | High Performance Compute/Artificial Intelligence |
| Johnson Controls International | JCI | Internet of Things |
| Equifax Inc | EFX | Banking, Insurance, & Investment Technology |
| Check Point Software Technology | CHKP | Cybersecurity |
| Tradeweb Markets Inc | TW | Banking, Insurance, & Investment Technology |
| ACI Worldwide Inc | ACIW | Banking, Insurance, & Investment Technology |
| Leidos Holdings Inc | LDOS | Cybersecurity |
| EVERTEC Inc | EVTC | Banking, Insurance, & Investment Technology |
| Arlo Technologies Inc | ARLO | Internet of Things |
| SK Telecom Co Ltd | SKM | 5G Technology & Services |
| Clear Secure Inc | YOU | Cybersecurity |
| Alarm.com Holdings Inc | ALRM | Cybersecurity |
| CyberArk Software Ltd | CYBR | Cybersecurity |
| Marathon Digital Holdings Inc | MARA | Cryptocurrency & Blockchain |
If you have any questions, please do not hesitate to contact Scott R. Anderson at (312) 845-3834 or Matthew T. Wirig at (312) 845-3432.
Very truly yours,
/s/ CHAPMAN AND CUTLER LLP
Chapman and Cutler LLP
