CHAPMAN AND CUTLER LLP 111 WEST MONROE STREET CHICAGO, ILLINOIS 60603 July 24, 2009 Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: First Trust Strategic High Income Fund III the "Fund") To the Commission: On behalf of the above Fund, electronically transmitted herewith pursuant to Rule 14a-6 under the Securities Exchange Act of 1934 are the preliminary proxy statement, form of proxy and other soliciting materials for the Fund. It is intended that the proxy materials will be mailed to shareholders of the Fund on or about August 4, 2009. Please call the undersigned at (312) 845-3446 (fax (312) 701-2361) with any questions or comments regarding this filing. Very truly yours, CHAPMAN AND CUTLER LLP By /s/ Suzanne M. Russell ------------------------------ Suzanne M. Russell