Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
December 12, 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 1259
Total Income Portfolio, Series 4
File Nos. 333-199554 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 the registration statement on Form S-6
for Guggenheim Defined Portfolios, Series 1259, filed on October 22, 2014 with
the Securities and Exchange Commission (the "Commission"). The registration
statement offers the Total Income Portfolio, Series 4 (the "trust").
PROSPECTUS
Investment Summary -- Principal Investment Strategy
1. The "Principal Investment Strategy" states that the trust will invest in
business development companies ("BDCs"), master limited partnerships ("MLPs")
and real estate investment trusts ("REITs"). Because the trust's principal
investment objective is to provide current income, please confirm that the BDCs,
MLPs and REITs purchased for the trust will each have a primary investment
objective of providing current income.
Response: When selecting securities of BDCs, MLPs or REITs for the trust,
the sponsor evaluates whether a particular security is generating current
income. If it is, then it may be chosen for the trust's portfolio because the
sponsor believes that selecting such securities furthers the trust's investment
objective, regardless of the underlying investment objectives of the BDCs, MLPs
and REITs.
Investment Summary -- Principal Risks
2. The "Principal Investment Strategy" section states that the trust may
invest in exchange-traded funds that invest in emerging market debt. Please add
disclosure about the risks of investing in emerging markets in the "Principal
Risks" section.
Response: Even though the trust may invest in exchange-traded funds that
invest in emerging market debt, we include risks based upon the final portfolio.
Because the last series of this strategy included a small percentage of
exchange-traded funds that invest substantially all of their assets in emerging
market debt, the relevant risk disclosure was included under "Investment Risks."
If such securities are selected for the portfolio of this trust, we will add the
appropriate risk disclosures.
3. The duration example in the eighth bullet uses a duration of three
years. Please confirm that the average weighted duration of the securities
underlying the BDCs and exchange-traded funds is approximately three years or
less. If not, please revise this example to reflect the average weighted
duration of the underlying securities.
Response: We confirm that the average weighted duration of the underlying
securities is approximately three years or less and, therefore, the example does
not need to be revised.
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