K&L GATES LLP   1601 K STREET, N.W.   WASHINGTON, DC 20006   T +1 202 778 9000 F +1 202 778 9100 klgates.com

February 24, 2023

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Re: Direxion Shares ETF Trust

File Nos. 333-150525; 811-22201

Post-Effective Amendment No. 387

Ladies and Gentlemen:

We have acted as counsel to Direxion Shares ETF Trust (the “Trust”) in connection with the preparation of Post-Effective Amendment No. 387 to the Trust’s Registration Statement on Form N-1A (the “Amendment”), and we have reviewed a copy of the Amendment being filed with the U.S. Securities and Exchange Commission.

Pursuant to paragraph (b)(4) of Rule 485 under the Securities Act of 1933, we represent that, based on our review and our assessment of the disclosure changes being effected by the Amendment, the Amendment does not contain disclosures that would render it ineligible to become effective pursuant to paragraph (b) of Rule 485.

Very truly yours,

/s/ K&L Gates LLP