June 5, 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.
29 to the registration statement for Claymore Exchange-Traded Fund Trust 2 (the
"Trust") filed on Form N-1A on April 1, 2008 ("Amendment No. 28"), concerning
the following new series of the Trust: Claymore/BNY Frontier Select DR 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. 31 (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. ON PAGE 2, THE HEADING USES THE WORD "SELECTOR" IN THE NAME
OF THE FUND. PLEASE CONFORM THE HEADING TO THE OTHER USES OF THE FUND'S NAME,
WHICH CONTAIN THE WORD "SELECT." ALSO, PLEASE CONFIRM THAT THE "DR" IN THE
FUND'S NAME IS AN ACRONYM FOR "DEPOSITORY RECEIPTS."

                  Response 1. The Fund's name has been changed to the
         "Claymore/BNY Mellon Frontier Markets ETF," and the heading has been
         conformed accordingly. The acronym "DR" in the Fund's initial name (as
         well as the name of the Index) does refer to depository receipts.

         COMMENT 2. PRIMARY INVESTMENT STRATEGIES (PAGE 2)

         IN THE THIRD PARAGRAPH, PLEASE CHANGE THE REFERENCES TO "STOCKS" TO
"SECURITIES" TO REFLECT THE FACT THAT THE FUND WILL BE INVESTING IN DEPOSITORY
RECEIPTS.

         THE PROSPECTUS CURRENTLY STATES THAT THE FUND WILL NORMALLY INVEST AT
LEAST 80% OF ITS ASSETS IN SECURITIES THAT COMPRISE 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 accordingly.

         COMMENT 3. PRIMARY INVESTMENT STRATEGIES (PAGE 2)

         PLEASE CLARIFY THAT THE DEPOSITORY RECEIPTS IN WHICH THE FUND INVESTS
ARE BASED UPON UNDERLYING STOCKS RATHER THAN BONDS.

                  Response 3. The disclosure has been revised accordingly. We
         also note that the Fund may invest, in certain limited circumstances,
         directly in one or more underlying stocks of the depository receipts
         that comprise the Index. Disclosure has been added to the prospectus to



CHRISTIAN SANDOE, ESQ.
JUNE 5, 2008
PAGE 2


         clarify the foregoing, including the circumstances under which the Fund
         may invest directly in underlying stocks.

         COMMENT 4. INDEX CONSTRUCTION (PAGE 3)

         ITEM 1 IN THIS SECTION SEEMINGLY INDICATES THAT DEPOSITORY RECEIPTS
MEETING THE CRITERIA SET FORTH THEREIN ARE AUTOMATICALLY INCLUDED TO THE INDEX,
BUT ITEM 2 SEEMS TO INDICATE THAT THE INDEX PROVIDER HAS DISCRETION OVER WHETHER
OR NOT TO INCLUDE OTHERWISE-QUALIFYING SECURITIES IN THE INDEX. PLEASE RECONCILE
THE TWO ITEMS.

                  Response 4. Item 2 has been revised to clarify that the
         discussion refers to a quarterly review of the Index methodology,
         rather than whether to include qualifying securities in the Index at
         any given time.

         COMMENT 5. INDEX CONSTRUCTION (PAGE 3)

         THE FINAL BULLET UNDER ITEM 1 STATES THAT "PASSIVE FOREIGN INVESTMENT
COMPANIES ARE EXCLUDED BASED ON THE BEST INFORMATION AVAILABLE." PLEASE CLARIFY
WHY PASSIVE FOREIGN INVESTMENT COMPANIES ARE EXCLUDED FROM THE INDEX AND WHAT
THE "BEST INFORMATION AVAILABLE" ENTAILS.

                  Response 5. Disclosure has been added accordingly.

         COMMENT 6. INDEX CONSTRUCTION (PAGE 4)

         PLEASE CLARIFY WHAT ITEM 4 MEANS WHEN IT SAYS THAT THE INDEX "MAY BE"
ADJUSTED FOR CHANGES IN SHARES AND FLOAT.

                  Response 6. The disclosure has been revised to clarify that
         such adjustments will take place on a quarterly basis.

         COMMENT 7. PRIMARY INVESTMENT RISKS (PAGE 4)

         AS THE FUND WILL INVEST IN DEPOSITORY RECEIPTS, PLEASE REVISE THE
DISCLOSURE IN "EQUITY RISK" TO REMOVE REFERENCES TO COMMON STOCKS.

                  Response 7. As set forth in Response 3 above, the Fund may
         invest directly in underlying stocks in certain circumstances.
         Accordingly, the references to common stocks have not been removed from
         the disclosure.



CHRISTIAN SANDOE, ESQ.
JUNE 5, 2008
PAGE 3


         COMMENT 8. SECONDARY INVESTMENT STRATEGIES (PAGE 8)

         (A) THE PROSPECTUS CURRENTLY STATES THAT THE FUND WILL NORMALLY INVEST
AT LEAST 80% OF ITS ASSETS IN SECURITIES THAT COMPRISE 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.

         (B) IN ADDITION, PLEASE CLARIFY HOW THE FUND EXPECTS TO TRACK THE INDEX
AND MINIMIZE TRACKING ERROR IF IT WILL NORMALLY INVEST 80% OF ITS ASSETS IN
COMPONENT SECURITIES OF THE INDEX. DOES THE FUND, FOR EXAMPLE, EXPECT TO HOLD
THE REMAINING 20% OF ITS ASSETS IN CASH?

                  Response 8. (a) As set forth in Response 1, the name of the
         Fund has been changed and no longer includes the word "Index."
         Pursuant to Rule 35d-1, disclosure also has been added to clarify that
         the Fund will normally invest at least 80% of its total assets in
         securities of issuers from "Frontier Market" countries (whether
         directly or through depositary receipts), as defined by the Index
         Provider from time to time in the manner set forth in the prospectus.

                              (b) The Fund expects that any of its assets
         invested in assets other than the component securities of the Index
         generally would either be in derivatives or other investments made to
         assist the Fund in tracking the Index (or, on a temporary basis, in
         cash or similarly liquid assets for cash management purposes). The Fund
         does not expect to hold close to 20% of its assets in investments other
         than the component securities of the Index for a substantial length of
         time.

                              In addition, as set forth in Response 3, the
         Fund may, in certain limited circumstances, invest directly in one or
         more underlying stocks of the depository receipts that comprise the
         Index. Disclosure has been added to the prospectus to clarify that the
         Fund's requirement to invest 80% of its assets in securities that
         comprise the Index includes investments in such underlying stocks. We
         note that the Fund's exemptive relief currently allows the Fund to
         invest 80% of its assets in component securities of the Index "and
         investments that have economic characteristics that are substantially
         identical to the economic characteristics" of the Index's component
         securities. We believe that the underlying stocks in respect of the
         depository receipts that comprise the Index qualify as "investments
         that have economic characteristics that are substantially identical to
         the economic characteristics" of the Index's depository receipts.

STATEMENT OF ADDITIONAL INFORMATION:

         COMMENT 9. INVESTMENT RESTRICTIONS AND POLICIES - INVESTMENT
RESTRICTIONS (PAGE 3)

         PLEASE 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 9. 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.



CHRISTIAN SANDOE, ESQ.
JUNE 5, 2008
PAGE 4


         COMMENT 10. MANAGEMENT - TRUSTEES AND OFFICERS (PAGE 12)

                  PLEASE CLARIFY THE CURRENT OCCUPATIONS OF RANDALL C. BARNES
         AND RONALD E. TOUPIN, JR.

                  Response 10. Additional disclosure has been added accordingly.

         COMMENT 11. CREATION AND REDEMPTION OF CREATION UNIT AGGREGATIONS
(PAGE 29)

         AS THE FUND WILL BE INVESTING IN DEPOSITORY RECEIPTS RATHER THAN STOCKS
DIRECTLY, PLEASE CONSIDER WHETHER THE LIST OF COUNTRIES AND HOLIDAYS SHOULD ONLY
REFER TO THOSE COUNTRIES IN WHICH THE INDEX'S DEPOSITORY RECEIPTS ARE TRADED.

                  Response 11. As set forth in Response 3, the Fund may invest
         directly in underlying stocks in certain circumstances. Accordingly, we
         believe that it would be appropriate to retain an extended list of
         countries and holidays. The list has been modified to reflect the
         countries represented in the Index.

         COMMENT 12. CREATION AND REDEMPTION OF CREATION UNIT AGGREGATIONS
(PAGE 33)

         PLEASE CONFIRM WHETHER THERE IS A MISSING FOOTNOTE ENTRY FOR RUSSIA ON
THE LIST OF DELAYED SETTLEMENT TIMES FOR THE YEAR 2008.

                  Response 12. The list has been revised to reflect the
         countries represented in the Index and no longer contains Russia.

         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