Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
August 14, 2015
Mr. Edward Bartz
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Guggenheim Defined Portfolios, Series 1349
Zacks Income Advantage Strategy Portfolio, Series 31
Zacks Income Advantage Strategy Portfolio (2-year), Series 13
File Nos. 333-205423 and 811-03763
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Dear Mr. Bartz:
This letter is in response to your comment 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 1349, filed on
August 13, 2015 with the Securities and Exchange Commission (the "Commission").
The registration statement proposes to offer the Zacks Income Advantage Strategy
Portfolio, Series 31 and Zacks Income Advantage Strategy Portfolio (2-year),
Series 13 (each, a "Trust").
PROSPECTUS
Zacks Income Advantage Strategy Portfolio (2-year), Series 13
Investment Summary -- Security Selection
1. Please conform the disclosure in this Trust to the disclosure in Zacks
Income Advantage Strategy Portfolio, Series 31.
Response: The "Security Selection" section will be revised to have the same
disclosures as the Zacks Income Advantage Strategy Portfolio, Series 31.
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