April 3, 2020

Rosanne Luth
Chief Executive Officer
SavvyShares LLC
1365 Fourth Avenue
San Diego, CA 92101

       Re: SavvyShares LLC
           Amendment No. 1 to Draft Offering Statement on Form 1-A
           Submitted March 23, 2020
           CIK No. 0001801255

Dear Ms. Luth:

       We have reviewed your amended draft offering statement and have the
following
comment. In our comment, we may ask you to provide us with information so we
may better
understand your disclosure.

        Please respond to this letter by providing the requested information
and either submitting
an amended draft offering statement or publicly filing your offering statement
on EDGAR. If
you do not believe our comment applies to your facts and circumstances or do
not believe an
amendment is appropriate, please tell us why in your response. After reviewing
any amendment
to your draft offering statement or filed offering statement and the
information you provide in
response to this comment, we may have additional comments.

Amendment No. 1 to Draft Offering Statement on Form 1-A

Description of Business
Competition, page 26

1.     You disclose that you believe your single-source digital tracking
technology will provide
       you with a competitive advantage. In this regard, we note from your
website that Luth
       Research, your founder and competitor, has comparable tracking
technology
       ("SavvyConnect") that it launched in 2009. If true, please identify Luth
Research as a
       competitor in digital tracking and address the risks and challenges that
you may face as a
       result of such competition.
 Rosanne Luth
SavvyShares LLC
April 3, 2020
Page 2

        You may contact Eiko Yaoita Pyles, Staff Accountant, at (202) 551-3587
or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions
regarding comments
on the financial statements and related matters. Please contact Bernard Nolan,
Attorney-Adviser,
(202) 551-6515 or, in his absence, Jan Woo, Legal Branch Chief, at (202)
551-3453 with any
other questions.



                                                           Sincerely,
FirstName LastNameRosanne Luth
                                                           Division of
Corporation Finance
Comapany NameSavvyShares LLC
                                                           Office of Technology
April 3, 2020 Page 2
cc:       John Tishler, Esq.
FirstName LastName