0001213900-23-033122.txt : 20230526 0001213900-23-033122.hdr.sgml : 20230526 20230427130509 ACCESSION NUMBER: 0001213900-23-033122 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20230427 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ETF Managers Group Commodity Trust I CENTRAL INDEX KEY: 0001610940 STANDARD INDUSTRIAL CLASSIFICATION: [6221] IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 30 MAPLE STREET STREET 2: SUITE 2 CITY: SUMMIT STATE: NJ ZIP: 07901 BUSINESS PHONE: 908-897-0513 MAIL ADDRESS: STREET 1: 30 MAPLE STREET STREET 2: SUITE 2 CITY: SUMMIT STATE: NJ ZIP: 07901 CORRESP 1 filename1.htm

April 27, 2023

VIA EDGAR

Eric Envall

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

	RE:	ETF Managers Group Commodity Trust I
		Breakwave Tanker Shipping ETF
		Registration Statement on Form S-1 (File No. 333-266945) (the “Registration Statement”)

Dear Mr. Envall:

In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, ETF Managers Group Commodity Trust I (the “Trust”) hereby respectfully requests that the Registration Statement be declared effective on Friday, April 28, 2023, at 3:00 p.m. ET, or as soon thereafter as practicable.

In connection with the submission of the Trust’s request for accelerated effectiveness of the Registration Statement, the Trust hereby acknowledges that:

should the Securities and Exchange Commission (the “Commission”) or the staff thereof (the “Staff”), acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Trust from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

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

Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Eversheds Sutherland (US), LLP, by calling Eric Simanek at (202) 220-8412.

	ETF Managers Group Commodity Trust I

	By: ETF Managers Capital, LLC,
	its Sponsor

	By:	/s/ Samuel Masucci III
		Samuel Masucci III Chief Executive Officer