Subject: File No. S7-24-15
From: James Dunn

March 11, 2020

I have invested in Pro-Share funds only once or twice in the past and found their description of how the funds operate to be totally inadequate. They accentuate the positive, without equally accentuating the negative. Twice, that I recall, they have "reverse split" funds that I own with the explanation that it was necessary to do so to give them better marketability. Have yet
to understand their explanation and have seen absolutely no positives associated with these reverse splits. I endorse the SEC's new regulations on this matter.