ROPES & GRAY LLP

PRUDENTIAL TOWER

800 BOYLSTON STREET

BOSTON, MASSACHUSETTS 02199

April 16, 2021 James M. Forbes T +1 617 235 4765 James.Forbes@ropesgray.com

BY EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: GMO Trust (the “Trust”) (File Nos. 002-98772 and 811-04347)

Dear Ladies and Gentlemen:

Transmitted herewith for filing by means of electronic submission on behalf of the Trust pursuant to (1) the Securities Act of 1933, as amended (the “Securities Act”), and Rule 485(a)(2) thereunder, (2) the Investment Company Act of 1940, as amended (the “1940 Act”), (3) Form N-1A and (4) Regulation S-T, is Post-Effective Amendment No. 218 to the Trust’s Registration Statement under the Securities Act and Amendment No. 266 to the Trust’s Registration Statement under the 1940 Act on Form N-1A (“Amendment No. 218/266”), including (i) a GMO Trust Prospectus relating to GMO Emerging Markets ex-China Fund (the “Fund”), a series of the Trust, (ii) a Statement of Additional Information for the Fund; and (iii) other information, the signature page, and exhibits. The other series of the Trust are offered through separate prospectuses and statements of additional information, and no information contained herein is intended to amend or supersede any prior filing relating to any other series of the Trust.

This Amendment No. 218/266 is being filed in connection with the Trust’s registration of the Fund under the Securities Act. Pursuant to the provisions of Rule 485(a)(2) under the Securities Act, it is intended that this Amendment No. 218/266 become effective on June 30, 2021.

If you have any questions or need any clarification concerning the foregoing or this transmission, please call the undersigned at (617) 235-4765.

Very truly yours,

/s/ James M. Forbes

James M. Forbes

Enclosures

cc: Jonathan Feigelson, Esq., Grantham, Mayo, Van Otterloo & Co. LLC

Douglas Y. Charton, Esq., Grantham, Mayo, Van Otterloo & Co. LLC

Thomas R. Hiller, Esq.
Sarah S. Clinton, Esq.