Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
February 18, 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 1424
Total Income Portfolio, Series 7
File Nos. 333-208853 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 1424, filed on January 4, 2016, with
the Securities and Exchange Commission (the "Commission"). The registration
statement proposes to offer the Total Income Portfolio, Series 7 (the "Trust").
PROSPECTUS
Investment Summary -- Principal Investment Strategy
1. The "Principal Investment Strategy" section states that the Trust
invests in exchange-traded funds that may invest in preferred securities. Please
add relevant risk disclosure related to investment in preferred securities.
Response: The disclosure has been revised in response to your comment.
Investment Summary -- Principal Risks
2. The duration example in the eighth bullet uses a duration of three
years. Please confirm that the average weighted duration of the underlying
securities 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