October 14, 2009

Mr. Christian T. Sandoe
Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549

Re:       Claymore Exchange-Traded Fund Trust 2 (File Nos. 333-135105 &
          811-21910)

Dear Mr. Sandoe:

Thank you for your telephonic comments concerning Post-Effective Amendment No.
50 to the registration statement for Claymore Exchange-Traded Fund Trust 2 (the
"Trust") filed on Form N-1A on July 31, 2009, concerning the following new
series of the Trust: Claymore/AlphaShares China All-Cap ETF (the "Fund"). Below,
we describe the changes made to the registration statement in response to the
staff's comments and provide any responses to or any supplemental explanations
of such comments, as requested. These changes will be reflected in
Post-Effective Amendment No. 56 (the "Amendment") to the Fund's registration
statement on Form N-1A, which will be filed via EDGAR on or about the date
hereof.

GENERAL:

         Comment 1. Please confirm that the offering of the Fund will comply
with all aspects of the Trust's current exemptive relief allowing the Trust to
offer exchange-traded funds.

                  Response 1. To the best of our knowledge, the offering of the
Fund will comply with all aspects of the Trust's current exemptive relief.

PROSPECTUS:

         Comment 2. Index Methodology (page 2)

         The second sentence in this section states that the Index consists of
companies "based in mainland China." Please clarify the criteria used to
determine whether a company is "based in mainland China."

                  Response 2. For purposes of the Index, companies are
considered to be based in mainland China if they are so classified under the
Standard & Poor's BMI Country Code classification system. This system determines
a company's country of domicile by considering a number of criteria, including:
(a) the headquarters of a country, (b) its registration or incorporation, (c)
primary stock listing, (d) geographic source of revenues, (d) location of fixed
assets, (f) operations and (g) the residence of senior officers. The disclosure
in item 1 under "Index Construction" has been revised to clarify the foregoing.



         Comment 3. Index Construction (page 3)

         Are all securities that meet the criteria set forth in this section
included in the Index, or may the Index Provider exclude securities that meet
the criteria based on its discretion or other factors? If so, please revise the
disclosure to clarify whether and how the Index Provider may exclude securities
that otherwise clarify for inclusion.

                  Response 3. The Index Provider does not use discretion to
exclude securities from the Index that otherwise meet the criteria set forth
under "Index Construction." Disclosure has been added immediately preceding item
1 in that section to clarify the foregoing.

STATEMENT OF ADDITIONAL INFORMATION:

         Comment 4. Creation and Redemption of Creation Unit Aggregations -
Procedures for Creation of Creation Unit Aggregations (page 22)

         Please confirm that custom orders placed as a result of the Trust
requiring the substitution of cash for a Deposit Security may be placed until
4:00 P.M. (Eastern time) rather than 3:00 P.M..

                  Response 4. The disclosure currently provides that the 3:00
         deadline only applies to custom orders placed as a result of the Trust
         permitting the substitution of cash for a Deposit Security, but not to
         custom orders placed as a result of the Trust requiring such a
         substitution. Custom orders placed under the latter circumstance may be
         placed until 4:00.

         As you have requested and consistent with SEC Release 2004-89, the
Trust hereby acknowledges that:

                  the Trust is responsible for the adequacy and accuracy of the
         disclosure in the filings;

                  the Staff's comments or changes to disclosure in response to
         Staff comments in the filings reviewed by the Staff do not foreclose
         the Commission from taking any action with respect to the filings; and

                  the Trust may not assert Staff comments as a defense in any
         proceeding initiated by the Commission or any person under the federal
         securities laws of the United States.

         If you would like to discuss any of these responses in further detail
or if you have any questions, please feel free to contact me at (212) 641-5669,
or Stuart Strauss at (212) 698-3529. Thank you.

                                   Sincerely,

                                   /s/ Jeremy Senderowicz