Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
April 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 1440
Equity Best Ideas 2016-1
File Nos. 333-210026 and 811-03763
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Dear Mr. Bartz:
This letter is in response to your comment letter dated April 5, 2016
regarding the registration statement on Form S-6 for Guggenheim Defined
Portfolios, Series 1444, filed on March 9, 2016, with the Securities and
Exchange Commission (the "Commission"). The registration statement proposes to
offer the Equity Best Ideas 2016-1 (the "Trust").
PROSPECTUS
Investment Summary -- Investment Objective
1. This section states that the Trust's investment objective is "total
return." Please define "total return" in this section.
Response: The investment objective has been revised to state "[t]he trust
seeks to provide total return through capital appreciation and dividend income."
Investment Summary -- Principal Investment Strategy
2. Please disclose in this section the significance of the phrase "Best
Ideas" in the Trust's name. In addition, the fourth sentence of this section
states that the "recommendations . . . takes into consideration industry sector
weightings." Please clarify in this section whether it is Baird's
recommendations or the Trust's security selections, or both, that take into
consideration industry sector weightings. Please also describe in this section
how the industry sector weightings are taken into consideration, e.g., the Trust
may not invest more than 15% of its assets in any industry sector.
Response: The disclosure has been revised in response to your comment.
Investment Summary -- Principal Risks
3. The second bullet point in this section states that the Trust invests in
U.S.-listed foreign securities and American Depositary Receipts ("ADRs"). Please
disclose the Trust's strategy regarding its investments in U.S.-listed foreign
securities and ADRs in the summary of principal investment strategies. Please
also explain to us whether the Trust will invest in securities of emerging
market issuers and, if so, provide appropriate disclosures in the summaries of
the Trust's principal investment strategies and principal risks.
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