February 17, 2011 |
Re:
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FactorShares 2X: S&P500 Bull/USD Bear (the “Company”)
Registration Statement on Form S-1 (File No. 333-164757)
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1.
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should the Securities and Exchange Commission (the “Commission”), or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare this filing effective, it does not foreclose the Commission from taking any action with regard to the filing;
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2.
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the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its responsibility for the adequacy and accuracy of the disclosure in this filing; and
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3.
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the Company 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.
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Very truly yours, |
FACTORSHARES 2X: S&P500 BULL/USD BEAR
By: Factor Capital Management, LLC,
its Managing Owner
By: /s/ Stuart Rosenthal
Name: Stuart Rosenthal
Title: Chief Executive Officer
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TIMBER HILL LLC
By: /s/ Bradford Jacobowitz
Name: Bradford Jacobowitz
Title: Chief Compliance Officer
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