April 10, 2008

Mr. Christian T. Sandoe Securities and Exchange Commission Division of
Investment Management
100 F Street, NE
Washington, D.C.  20549
Re: Claymore Exchange-Traded Fund Trust 2 (File Nos. 333-135105 & 811-21910)

Dear Mr. Sandoe:

Thank you for your telephonic comments concerning Post-Effective Amendment No.
28 to the registration statement for Claymore Exchange-Traded Fund Trust 2 (the
"Trust") filed on Form N-1A on February 14, 2008 ("Amendment No. 28"),
concerning the following new series of the Trust: Claymore/MAC Global Solar
Energy Index ETF (the "Fund"). Below, we describe the changes made to the
registration statement in response to the staff's comments and provide any
responses to or any supplemental explanations of such comments, as requested.
These changes will be reflected in Post-Effective Amendment No. 30 (the
"Amendment") to the Fund's registration statement on Form N-1A, which will be
filed via EDGAR on or about the date hereof.

PROSPECTUS:

         COMMENT 1. PLEASE CONFIRM THAT THERE ARE NO AFFILIATIONS BETWEEN THE
INDEX PROVIDER AND CLAYMORE OTHER THAN THE LICENSE ARRANGEMENTS BETWEEN THE
FUND'S INVESTMENT ADVISER AND THE INDEX PROVIDER.

                  Response 1. Other than the license arrangements, there are no
         affiliations between the index provider and Claymore.

         COMMENT 2. THE PROSPECTUS CURRENTLY STATES THAT THE FUND WILL NORMALLY
INVEST AT LEAST 80% OF ITS ASSETS IN SECURITIES THAT COMPRISE THE MAC GLOBAL
SOLAR ENERGY INDEX (THE "INDEX"). AS SET FORTH IN INVESTMENT COMPANY ACT RELEASE
NO. 24828 (JANUARY 17, 2001), PLEASE NOTE THAT INDEX FUNDS WHOSE NAMES CONTAIN
THE WORD "INDEX" WOULD GENERALLY BE EXPECTED TO INVEST MORE THAN 80% OF THEIR
ASSETS IN THE UNDERLYING INDEX IN ORDER TO COMPLY WITH THE REQUIREMENTS OF RULE
35D-1 UNDER THE INVESTMENT COMPANY ACT OF 1940, AS AMENDED.

                  Response 2. The disclosure has been revised to clarify that
         the Fund will normally invest at least 90% of its assets in securities
         that comprise the Index.

         COMMENT 3. INDEX METHODOLOGY (PAGE 2)

         PLEASE CLARIFY THAT "COMPANIES THAT ARE INVOLVED IN SOLAR POWER....
FINANCE" MUST HAVE SUCH FINANCING ACTIVITIES AS A MAJOR COMPONENT OF THEIR
BUSINESS IN ORDER TO BE CONSIDERED AS INDEX CONSTITUENTS.

                  Response 3. The disclosure has been revised to clarify that
         companies must derive a significant portion of their business (as
         measured by the methodology set forth in the prospectus) from such
         solar power-related activities in order to be eligible for inclusion in
         the Index.

         COMMENT 4. PLEASE DISCLOSE THE AVERAGE MARKET CAPITALIZATION OF THE
         INDEX CONSTITUENTS.

                  Response 4. The disclosure has been added.



CHRISTIAN SANDOE, ESQ.
APRIL 10, 2008
PAGE 2

STATEMENT OF ADDITIONAL INFORMATION:

         COMMENT 5. INVESTMENT RESTRICTIONS AND POLICIES - INVESTMENT
RESTRICTIONS (PAGE 3)

         PLEASE REVISE THE DISCLOSURE IN FUNDAMENTAL INVESTMENT RESTRICTION
NUMBER 1 TO CLARIFY THAT THE FUND WILL INVEST MORE OR LESS THAN 25% OF ITS
ASSETS IN THE SECURITIES OF ANY ONE INDUSTRY OR GROUP OF INDUSTRIES TO THE
EXTENT ITS UNDERLYING INDEX EXCEEDS OR FALLS SHORT OF SUCH THRESHHOLD.

                  Response 5. The fundamental investment limitation in question
         has been approved by the Board of Trustees of the Trust with respect to
         the Fund. As such, we do not believe that the wording of the policy can
         be altered without the affirmative vote of the Fund's shareholders.
         However, we hereby represent that pursuant to the current disclosure
         regarding such limitation, the Fund will invest more than 25% of its
         assets in the securities of any one industry or group of industries if
         the Index exceeds such threshhold, and will invest less than that
         amount if the Index falls short of such threshhold. Accordingly, we
         respectfully submit that the current disclosure is sufficient.

         COMMENT 6. MANAGEMENT - PORTFOLIO MANAGER - OTHER ACCOUNTS MANAGED BY
THE PORTFOLIO MANAGER

         THE CURRENT DISCLOSURE REFERS TO MR. CRAIG'S MANAGEMENT OF TWO
REGISTERED INVESTMENT COMPANIES. TO THE EXTENT SUCH INVESTMENT COMPANIES CONSIST
OF MULTIPLE PORTFOLIOS, PLEASE ALSO DISCLOSE THE TOTAL NUMBER OF PORTFOLIOS
CONTAINED IN THE INVESTMENT COMPANIES MANAGED BY MR. CRAIG.

                  Response 6. The disclosure has been added.

         As you have requested and consistent with SEC Release 2004-89, the
Trust hereby acknowledges that:

                  the Trust is responsible for the adequacy and accuracy of the
         disclosure in the filings;

                  the Staff's comments or changes to disclosure in response to
         Staff comments in the filings reviewed by the Staff do not foreclose
         the Commission from taking any action with respect to the filings; and

                  the Trust may not assert Staff comments as a defense in any
         proceeding initiated by the Commission or any person under the federal
         securities laws of the United States.

         If you would like to discuss any of these responses in further detail
or if you have any questions, please feel free to contact me at (212) 818-3412,
or Stuart Strauss at (212) 878-4931. Thank you.

                                                     Sincerely,


                                                    /s/ Jeremy Senderowicz