Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
January 13, 2016
Mr. Edward Bartz
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Guggenheim Defined Portfolios, Series 1413
Global Balanced Income Builder Portfolio, Series 7
Guggenheim Balanced Income Builder Portfolio, Series 14
File Nos. 333-208271 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 1413, filed on November 30, 2015, with
the Securities and Exchange Commission (the "Commission"). The registration
statement proposes to offer the Global Balanced Income Builder Portfolio, Series
7 and Guggenheim Balanced Income Builder Portfolio, Series 14 (individually, a
"Trust;" and collectively, the "Trusts").
PROSPECTUS
GLOBAL BALANCED INCOME BUILDER PORTFOLIO, SERIES 7
Investment Summary -- Principal Investment Strategy
1. Disclose in the "Principal Investment Strategy" section that the Trust
holds exchange-traded funds that invest in municipal bonds.
Response: The disclosure has been revised in response to your comment.
GUGGENHEIM BALANCED INCOME BUILDER PORTFOLIO, SERIES 14
Investment Summary -- Principal Risks
2. Revise the "Principal Risks" section to include disclosure regarding
real estate investment trusts.
Response: The disclosure has been revised in response to your comment.
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