Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
March 4, 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 1428
Income & Treasury Limited Duration Portfolio of Funds, Series 47
File Nos. 333-209192 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 1428, filed on January 29, 2016, with
the Securities and Exchange Commission (the "Commission"). The registration
statement proposes to offer the Income & Treasury Limited Duration Portfolio of
Funds, Series 47 (the "Trust").
PROSPECTUS
INVESTMENT SUMMARY -- PRINCIPAL RISKS
1. The duration example in the seventh bullet uses a duration of five
years. Please confirm that the average weighted duration of the underlying
securities is approximately five 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 five 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