CHAPMAN AND CUTLER LLP
                             111 WEST MONROE STREET
                                CHICAGO, IL 60603


                                  July 24, 2009


Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C.  20549


             Re: Claymore Securities Defined Portfolios, Series 610
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Ladies and Gentlemen:

   Enclosed please find a copy of the Registration Statement on Form S-6 for the
registration under the Securities Act of 1933 of Units representing the
ownership of interests in the subject Fund. This Registration Statement is filed
on July 24, 2009, on behalf of Claymore Securities, Inc. (the "Sponsor").

   Inasmuch as the Fund is not yet operative, no filings have been required
under any of the acts administered by the Commission. Therefore, for purposes of
Securities Act Release No. 5196 there are no delinquencies to be reported or
other references to be made to filings under the 1934 Act.

   No notification of registration or Registration Statement under the
Investment Company Act of 1940 is currently being submitted to the Commission,
as the filings under the 1940 Act (File No. 811-03763) are intended to apply not
only to that series of the Fund, but to all "subsequent series" as well.

   The Fund is expected to be comprised of the following unit investment trust:
Guggenheim ETF 60/20/20 Asset Allocation Portfolio, Series 1 (the "Trust"). The
Trust will invest in a portfolio of shares of exchange-traded funds ("ETFs") and
exchange-traded notes ("ETNs"). As the ETFs in which the Trust will invest are
structured as open-end management companies or unit investment trusts, the Trust
is not eligible to go automatically effective in reliance on Rule 487 under the
Securities Act of 1933. The Trust may not rely on Rule 487 because paragraph
(b)(1) of Rule 487 requires that reliance upon the rule is conditioned upon the
registrant not engaging in the business of investing in open-end funds. Absent
paragraph (b)(1) of Rule 487, it would be our opinion that the Registration
Statement would not contain disclosures which would render it ineligible to
become effective pursuant to Rule 487.

   Based upon the foregoing, as specified in Securities Act Release No. 6510, we
respectfully request limited review of the inclusion in the Trust of shares of
the ETF by the staff of the Commission.

   We are advised that the Sponsor proposes to deposit securities and to
activate the subject Fund as soon as practicable after the effective date of the
Registration Statement.

   In the event that you may have any questions with regard hereto or if there
is any way which we can be of assistance, please do not hesitate to telephone
Eric F. Fess collect at (312) 845-3781 or Morrison C. Warren (312) 845-3484.

                                                               Very truly yours,


                                                      /s/ Chapman and Cutler LLP
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                                                          CHAPMAN AND CUTLER LLP