United States securities and exchange commission logo 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