Rydex Specialized Products LLC
9601 Blackwell Road, Suite 500
Rockville, MD 20850

February 7, 2007

Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Mail Stop 3720
Washington, DC 20549
Attention:    Larry Spirgel, Esq.
                    Paul Fischer, Esq.

Re: CurrencyShares Japanese Yen Trust –
  Registration Statement on Form S-1
  Amendment No. 2 (Registration No. 333-138881)

Gentlemen:

        Pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned, the Secretary of Rydex Specialized Products LLC, the sponsor (the “Sponsor”) of the CurrencyShares Japanese Yen Trust (the “Trust”), on behalf of the Trust hereby requests that the above-referenced Registration Statement be declared effective by the Securities and Exchange Commission (the “Commission”) on Wednesday, February 7, 2007, at 4:00 p.m. Eastern Time, or as soon as practicable thereafter.

        We hereby acknowledge that:

• should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

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

• the Sponsor and the Trust may not assert 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.

Securities and Exchange Commission
February 7, 2007
Page 2

        Please contact counsel for the Trust, Patrick Daugherty at (313) 234-7103 or David V. Gubbini at (313) 234-7144, should you have any questions or comments regarding this request.

RYDEX SPECIALIZED PRODUCTS LLC

By: /s/ Michael Byrum

      Michael Byrum

      Secretary

cc:	Mr. Timothy Meyer
	Mr. J. Stuart Thomas
	Mr. George Simon
	Mr. Patrick Daugherty
	Ms. Yvette M. VanRiper