United States securities and exchange commission logo October 17, 2022 Steven Dunn Chief Executive Officer abrdn Precious Metals Basket ETF Trust c/o abrdn ETFs Sponsor LLC 1900 Market Street, Suite 200 Philadelphia, PA 19103 Re: abrdn Precious Metals Basket ETF Trust Registration Statement on Form S-3 Filed October 14, 2022 File No. 333-267880 Dear Steven Dunn: 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 with any questions. Sincerely, Division of Corporation Finance Office of Finance