Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
October 1, 2014
Mr. Edward Bartz
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Guggenheim Defined Portfolios, Series 1237
Zacks Rank Strong Buy 50 Strategy Portfolio, Series 1 File
Nos. 333-198607 and 811-03763
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Dear Mr. Bartz:
This letter is in response to your comments given during a telephone
conversation with our office regarding amendment no. 1 to the registration
statement on Form S-6 for Guggenheim Defined Portfolios, Series 1237, filed on
September 26, 2014 with the Securities and Exchange Commission (the
"Commission"). The registration statement offers the Zacks Rank Strong Buy 50
Strategy Portfolio, Series 1 (the "Trust").
PROSPECTUS
Investment Summary -- Principal Risks
1. Please explain to us whether the Trust will invest in foreign securities
and securities of emerging market countries and, if so, provide corresponding
disclosures in the discussions of the Trust s principal investment strategies
and principal risks.
Response: The Trust's portfolio includes foreign securities, including
securities of issuers in emerging market countries. As a result, we have revised
the disclosure in response to your comments.
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