Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
June 28, 2013
Mr. Edward P. Bartz
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Guggenheim Defined Portfolios, Series 1051
Global Commodity Producers Portfolio, Series 1
File Nos. 333-188251 and 811-03763
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Dear Mr. Bartz:
This letter is in response to your comments given in your letter dated May
29, 2013 regarding the registration statement on Form S-6 for Guggenheim Defined
Portfolios, Series 1051, filed on April 30, 2013 with the Securities and
Exchange Commission (the "Commission"). The registration statement offers the
Global Commodity Producers Portfolio, Series 1 (the "Trust").
PROSPECTUS
Investment Summary -- Principal Investment Strategy
1. This section states that the Trust will invest at least 80% of its
assets in companies that derive at least 50% of their revenues from commodity
production and exploration. Since the Trust s name includes the term OproducersO
and does not include the term Oexploration,O please revise the Trust s 80%
policy to eliminate the term Oexploration.O See Rule 35d-1(a)(2)(i) under the
Investment Company Act of 1940. Also, since the Trust s name includes the term
Oglobal,O please expressly describe how the Trust will Oinvest [its] assets in
investments that are tied economically to a number of countries throughout the
world.O See Investment Company Names, Investment Company Act Release No. 24828,
at n.42 (Jan. 17, 2001). For example, the Trust could include a policy that it
will invest significantly (i.e., at least 40% of its assets) in companies
organized or located outside the U.S. or doing a substantial amount of business
outside the U.S.
Response: The disclosure has been revised as requested.
Investment Summary -- Security Selection
2. This section describes the selection criteria for the securities in
which the Trust will invest. Please also identify the types of securities (i.e.,
common stocks, preferred stocks, debt securities, etc.) in which the Trust will
invest.
Response: The first sentence of the second paragraph has been revised to
state: "Begin with a global universe of common stock and American Depository
Receipts ("ADRs") of companies that produce or mine commodities in one of three
sleeves: Energy, Agriculture and Metals/Mining." In addition, we revised the
risks to include disclosures pertaining to ADRs.
3. The first sentence of the fourth paragraph in this section states that
the final portfolio will contain 30 to 40 "names." Please revise this sentence
to state that the final portfolio will contain 30 to 40 securities.
Response: The disclosure has been revised as requested.
We appreciate your prompt attention to this registration statement. If you
have any questions or comments or would like to discuss our responses to your
questions please feel free to contact the undersigned at (312) 845-3484.
Very truly yours,
CHAPMAN AND CUTLER LLP
By /s/ Morrison C. Warren
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Morrison C. Warren