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                   March 29, 2021

       Samuel Masucci, III
       ETF Managers Capital LLC
       ETF Managers Group Commodity Trust I
       30 Maple Street
       Suite 2
       Summit, NJ 07901

                                                        Re: ETF Managers Group
Commodity Trust I
                                                            Registration
Statement on Form S-1
                                                            Filed March 23,
2021
                                                            File No. 333-254634

       Dear Mr. Masucci:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. We remind you
       that the company and its management are responsible for the accuracy and
adequacy of their
       disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

             Please contact Sonia Bednarowski at 202-551-3666 or Sandra Hunter
Berkheimer, Legal
       Branch Chief, at 202-551-3758 with any questions.




                   Sincerely,


                   Division of Corporation Finance

                   Office of Finance