cmdt20180425_corresp.htm

0001437749-18-007677.txt : 20180530 0001437749-18-007677.hdr.sgml : 20180530 20180425145519 ACCESSION NUMBER: 0001437749-18-007677 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20180425 FILER: COMPANY DATA: COMPANY CONFORMED NAME: iSHARES COMMODITY OPTIMIZED TRUST CENTRAL INDEX KEY: 0001535365 STANDARD INDUSTRIAL CLASSIFICATION: [6221] IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 400 HOWARD STREET CITY: SAN FRANCISCO STATE: CA ZIP: 94105 BUSINESS PHONE: 415-670-2000 MAIL ADDRESS: STREET 1: 400 HOWARD STREET CITY: SAN FRANCISCO STATE: CA ZIP: 94105 FORMER COMPANY: FORMER CONFORMED NAME: iShares Dow Jones-UBS Roll Select Commodity Index Trust DATE OF NAME CHANGE: 20111121 CORRESP 1 filename1.htm cmdt20180425_corresp.htm

iShares^® Delaware Trust Sponsor LLC

400 Howard Street

San Francisco, California 94105

April 25, 2018

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attention: Tom Kluck

	Re:	iShares^® Commodity Optimized Trust
		Registration Statement on Form S-1
		File No. 333-224285.

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), iShares^® Delaware Trust Sponsor LLC (the “Sponsor”), as sponsor on behalf of the registrant, iShares^® Commodity Optimized Trust (the “Trust”), hereby requests that the effective date of the above-referenced Registration Statement be accelerated by the Securities and Exchange Commission (the “Commission”) so that the Registration Statement will become effective under the Securities Act on April 27, 2018 or as soon thereafter as practicable.

The Sponsor and the Trust 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 filing effective, does not relieve the registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

●

the registrant 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.

We request that we be notified of such effectiveness by a telephone call to Andrew Faulkner of Skadden, Arps, Slate, Meagher & Flom LLP at (212) 735-2853 and that such effectiveness also be confirmed in writing.

	Very truly yours,

	iShares^® Commodity Optimized Trust

	By:	iShares^®Delaware Trust Sponsor LLC, its sponsor


	/s/ Paul Lohrey
	By: Paul Lohrey
	Title: Chief Executive Officer, Principal Executive Officer, President


	/s/ Jack Gee By: Jack Gee
	Title: Chief Financial Officer, Principal Accounting Officer

cc:

Andrew M. Faulkner, esq.

Skadden, Arps, Slate, Meagher & Flom LLP

Four Times Square

New York, New York 10036