September 24, 2009


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

             Re: Claymore Securities Defined Portfolios, Series 609

        Guggenheim 40/40/20 Asset Allocation Portfolio of ETFs, Series 1

                               File No. 333-160779

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Ladies and Gentlemen:

   On behalf of Claymore Securities, Inc., depositor, sponsor and underwriter of
the Claymore Securities Defined Portfolios, Series 609, consisting of the
above-captioned trust (the "Trust"), there is enclosed Amendment No. 2 to the
Registration Statement on Form S-6 relating to securities of Claymore Securities
Defined Portfolios, Series 609 (the "Fund").

   The Reference Trust Agreement was entered into by Claymore Securities, Inc.,
as Depositor, and The Bank of New York Mellon, as Trustee, on the date hereof,
and Securities (or delivery statements relating to contracts for the purchase
thereof) in the aggregate amount of the portfolio(s) have been deposited with
the Trustee. In connection therewith the Trustee is prepared to establish book
entry positions which are being retained by the Trustee for delivery after the
effectiveness of the Registration Statement.

   In addition to Amendment No. 2, the exhibits listed therein are submitted
herewith.

   Except as indicated in the Memorandum of Changes, the changes in the
Prospectus represent primarily the completion of various statements regarding
the Securities deposited in the Trust and the dates of record, deposit,
distribution, termination and evaluation, together with a list of the Securities
which will comprise the portfolio of the Trust, the Statement of Financial
Condition of the Trust and the Report of Independent Registered Public
Accounting Firm.

   We have appreciated the courtesy and cooperation of the members of the Staff
and if there are any questions on which we may be of assistance, please do not
hesitate to call either Eric F. Fess (312-845-3781) or Morrison C. Warren
(312-845-3484) collect.

                                                               Very truly yours,

                                                      /s/ Chapman and Cutler LLP
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                                                          CHAPMAN AND CUTLER LLP