March 25, 2020

John Love
Chief Executive Officer
United States Commodity Index Funds Trust
1850 Mt. Diablo Boulevard, Suite 640
Walnut Creek, California 94596

       Re: United States Commodity Index Funds Trust
           Registration Statement on Form S-1
           Filed March 13, 2020
           File No. 333-237184

Dear Mr. Love:

       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-1 filed March 13, 2020

Risk Factors
The Trust Agreement Limits the Forum in Which Claims may be brought, page 17

1.     We note that your forum selection provision in your Trust Agreement
identifies the Court
       of Chancery of the State of Delaware (or, if such court does not have
subject matter
       jurisdiction thereof, any other court in the State of Delaware with
subject matter
       jurisdiction) as the exclusive forum for certain litigation. Please
disclose whether this
       provision applies to actions arising under the Securities Act or
Exchange Act. If so, please
       also state that there is uncertainty as to whether a court would enforce
such provision. If
       the provision applies to Securities Act claims, please also state that
investors cannot waive
       compliance with the federal securities laws and the rules and
regulations thereunder. In
       that regard, we note that Section 22 of the Securities Act creates
concurrent jurisdiction
 John Love
United States Commodity Index Funds Trust
March 25, 2020
Page 2
         for federal and state courts over all suits brought to enforce any
duty or liability created by
         the Securities Act or the rules and regulations thereunder.

        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 Susan Block at 202-551-3210 or Dietrich King at
202-551-8071 with any
questions.



FirstName LastNameJohn Love                         Sincerely,
Comapany NameUnited States Commodity Index Funds Trust
                                                    Division of Corporation
Finance
March 25, 2020 Page 2                               Office of Finance
FirstName LastName