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                               June 1, 2023

       Steven Dunn
       President and Chief Executive Officer
       abrdn Palladium ETF Trust
       1900 Market Street, Suite 200
       Philadelphia, PA 19103

                                                        Re: abrdn Palladium ETF
Trust
                                                            Registration
Statement on Form S-3
                                                            Filed May 18, 2023
                                                            File No. 333-272037

       Dear Steven Dunn:

              We have limited our review of your registration statement to
those issues we have
       addressed in our comments. In some of our comments, we may ask you to
provide us with
       information so we may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Form S-3 filed May 18, 2023

       Risks Related to Palladium, page 6

   1.                                                   Please revise this
section to add a new risk factor that specifically addresses, qualitatively
                                                        and quantitatively, the
changes in palladium's price over the last year.
 Steven Dunn
FirstName  LastNameSteven
abrdn Palladium ETF Trust Dunn
Comapany
June 1, 2023Nameabrdn Palladium ETF Trust
June 1,
Page 2 2023 Page 2
FirstName LastName
General Risks, page 12

2.       Please revise the risk factors in this section to include revised
disclosure that;
             discusses how the 2022 London Platinum and Palladium Market's
suspension of
             Russian palladium refiners' accreditation has actually impacted
the palladium market;
             explains whether and how Russia's production levels have impacted
palladium prices
             subsequent to the suspension; and
             better explains how the inclusion of disclosure related to gold
and silver, for example
             on page 13, is relevant to the risks to the palladium markets.
Platinum Group Metals, page 14

3.       Please update the discussion and table on this page to include
information and figures
         through 2022 and into 2023.
Historical Chart of the Price of Palladium, page 16

4.       We note your chart that shows the price per ounce of palladium through
2022 and the
         discussion in your final paragraph regarding palladium's price changes
in 2022. Please
         revise this section to add additional, more timely disclosure about
palladium's prices in
         2023 and how they compare to your discussion of pricing in previous
years. Include
         quantitative and qualitative disclosures that address the more recent
price declines and the
         reasons for the declines.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Eric Envall at (202) 551-3234 or John Dana Brown at (202)
551-3859 with
any questions.



                                                               Sincerely,

                                                               Division of
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                                                               Office of Crypto
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