Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
April 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 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 comments regarding amendment no. 1 to
the registration statement on Form S-6 for Guggenheim Defined Portfolios, Series
1444, filed on April 13, 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 -- Principal Investment Strategy
1. Please clarify in this section whether Baird's recommendations takes
into consideration industry sector weightings.
Response: The fifth sentence of this section has been removed.
Additional Revisions
The third sentence of the "Principal Investment Strategy" section has been
revised. The Trust invests significantly in the consumer products sector and
invests in a single real estate investment trust. As such, the "Principal
Investment Strategy" section and the risks sections have been revised, as
appropriate. Additionally, the foreign securities disclosures have been deleted
from the "Principal Risks" section because it is not a principal risk of the
Trust. Finally, risk disclosures relating to investments in small-capitalization
companies and emerging market companies have been deleted because the Trust does
not invest in these securities.
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