Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
April 24, 2018
Mr. Edward Bartz
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Guggenheim Defined Portfolios, Series 1754
Floating Rate & Dividend Growth Portfolio, Series 17
File Nos. 333-223329 and 811-03763
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Dear Mr. Bartz:
This letter responds to your comment made during a telephone conversation
with our office regarding the registration statement on Form S-6 for Guggenheim
Defined Portfolios, Series 1754, filed on March 1, 2018 with the Securities and
Exchange Commission (the "Commission"). The registration statement proposes to
offer the Floating Rate & Dividend Growth Portfolio, Series 17 (the "Trust").
PROSPECTUS
Investment Summary -- Principal Risks
1. The duration example in the seventh 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