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


                                  May 9, 2013


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


     Re: Guggenheim Defined Portfolios, Series 1039 (the "Fund")
         --------------------------------------------------------

Ladies and Gentlemen:

     Enclosed please find a copy of Amendment No. 1 to 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
Amendment No. 1 to the Registration Statement is filed on May 9, 2013, on behalf
of Guggenheim Funds Distributors, LLC (the "Sponsor").

     Inasmuch as the Fund is not yet operative, no filings have been required
under any of the acts administered by the Securities and Exchange Commission
(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: Floating Rate & Dividend Growth Portfolio, Series 1 (the "Trust"). The
Trust will invest in a portfolio of equity securities, common shares of
closed-end investment companies and shares of exchange-traded funds ("ETFs"). 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.

     We are advised that the Sponsor proposes to deposit securities and to
activate the subject Fund on May 10, 2013.

     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
                                                          CHAPMAN AND CUTLER LLP