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DWS Investment Management Americas, Inc.

100 Summer Street

Boston, MA 02110

December 9, 2024

VIA EDGAR

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: David Mathews

    Re:
    Post-Effective Amendment No. 169 to the Registration Statement on Form N-1A of DWS RREEF Completion Fund I (the “Fund”), a series of Deutsche DWS Market Trust (the “Registrant”) (Reg. Nos. 002-21789; 811-01236)

Dear Mr. Mathews,

This letter is submitted on behalf of the Fund
in response to comments of the Staff of the Securities and Exchange Commission (“SEC”) regarding the above-referenced Post-Effective
Amendment (“Amendment”), which comments were received via telephone on November 20, 2024. The Amendment was filed on behalf
of the Fund on October 4, 2024, with an effective date of December 18, 2024.

The Staff’s comments are restated below, followed
by the Fund’s responses.

General
Comments

1.
Comment: Please file the Fund’s responses to the Staff’s comments on EDGAR at least five business days prior to
the filing of the amendment to the Fund’s Registration Statement pursuant to Rule 485(b). Please reflect any disclosure changes
in the correspondence or email changed pages. Please be advised that comments provided on any one section of the Fund’s Registration
Statement apply to similar disclosure throughout the Registration Statement.

Response: The Fund confirms it
will file its responses to the Staff’s comments on EDGAR as requested. We agree to either reflect all disclosure changes in the
correspondence or email changed pages separately. In addition, the Fund confirms that it will apply the Staff’s comments on any
one section of the Registration Statement to similar disclosure throughout.

 2. Comment: Provide a completed fee and expense table in the response letter and confirm in the correspondence
that the cap will be for the duration of at least one year.

Response: A copy of the Fund’s
completed fee table and expense example are included in this letter as Attachment A. We confirm the expense cap will be in effect
for a period of at least one year from the date of the Fund’s prospectus and this disclosure is included in Attachment A.

Prospectus
Comments

 3. Comments to clarify disclosure in the fee and expense table regarding the Fund’s fees:

 a. Comment: In narrative disclosure in the fee and expense table, state that the Fund’s subadvisor
will be compensated directly or indirectly by wrap program sponsors, such as through wrap fees and explain how participants in the wrap
program can obtain information about the fee.

Response: The fee and expense table
in the Fund’s Prospectus included in the Amendment includes the following footnote: “Shareholders should be aware, however,
that the fund is part of separately managed account investment programs, and the fund’s subadvisor will be compensated directly
or indirectly by wrap program sponsors or wrap account clients for separately managed account advisory services.” The Fund proposes
to add the following disclosure to this footnote: “For additional information on these compensation arrangements, please contact
the wrap program sponsor or your financial representative.”

 b. Comment: Since the Advisor charges no management fee, please revise the discussion of waivers and
reimbursements to explain that the waiver only provides for fund expenses.

Response: The Fund’s Prospectus
has been revised to address the Staff’s comment by deleting the reference to “fees” in the footnote to the fee and expense
table that describes the waiver and reimbursement arrangements.

 c. Comment: At or prior to the performance section, note that fees are assessed at the wrap program
level, not at the fund level, which will result in higher performance being represented than if the fees were assessed at the fund level.

Response: The Fund’s Prospectus
has been revised to address the Staff’s comment. See Attachment B.

 4. Comment: Clarify whether the Fund intends to invest directly in real assets or in companies that
invest in real assets.

Response: The Fund intends to invest
in securities of companies in real assets sectors and does not intend to invest directly in real assets. Consistent with this investment
approach, the Fund’s Prospectus has been revised to address the Staff’s comment. See Attachment B.

 2

 5. Comment: Clarify in the disclosure what metrics or factors are used to determine whether a company
owns or derives a “significant portion” of their value from real assets or the production thereof, so as to be included in
the Fund’s portfolio.

Response: The Fund’s subadvisor
will generally consider securities for investment that are included in various indices that are real assets-related such as the FTSE EPRA
NAREIT Global Real Estate Index, the Dow Jones Brookfield Infrastructure Index, or the S&P Global Natural Resources Index, industry
classifications, or companies that the Fund’s subadvisor otherwise determines own or derive a significant portion of their value
from real assets or the production thereof. The Fund’s Prospectus has been revised to address the Staff’s comment. See
Attachment B.

 6. Comment: Clarify in the disclosure which entity, the Advisor or subadvisor, is primarily responsible
for making investment decisions for the Fund.

Response: RREEF America L.L.C. (“RREEF”)
is the subadvisor to the Fund and is primarily responsible for making investment decisions for the Fund, subject to the oversight of the
Advisor. The Prospectus included in the Amendment already states that “RREEF makes the investment decisions, buys and sells securities
for the fund and conducts research that leads to these purchase and sale decisions.” Consistent with this statement, the Fund will
change several references in the Prospectus from the Advisor to the Fund’s subadvisor. See Attachment B.

 7. Comment: With respect to fixed income securities, clarify whether all or particular types of fixed
income securities are deemed to be real assets by the Fund. Explain how the Fund classifies fixed income securities as real assets and
the role fixed income securities will play in achieving the Fund’s overall investment objective. Additionally, to aid investors
to understand the strategy, consider adding a brief description of master limited partnerships.

Response: For fixed income securities,
the Fund generally intends to utilize an equivalent process to that used to determine whether an equity investment is considered a real
assets investment, as described under the caption “Management process” in the Prospectus. Fixed income securities are not
expected to play a material role in implementing the Fund’s investment objective and strategy. The Fund’s Prospectus has been
revised to address the Staff’s comments. See Attachment B.

 8. Comment: The “Other Investment Strategies” section discloses that the Fund may invest
in exchange-traded funds. Please confirm in correspondence that acquired fund fees are expected to represent less than 0.1% of Fund expenses
in the first year of operation or amend the expense table accordingly.

Response: The Fund confirms that
expenses relating to the Fund’s investment in acquired funds are expected to be less than 0.1% of the Fund’s total expenses,
and therefore acquired fund fees and expenses do not need to be reflected in the expense table.

3

Statement
of Additional Information Comments

 9. Comment: With regards to the concentration policy, confirm in correspondence that the Fund considers
the investment of any underlying DWS Fund, or other underlying investment company, when determining fund compliance with its concentration
policy.

Response: The Fund does not expect
to invest materially in any underlying DWS Fund or other underlying investment company. In determining compliance with its concentration
policies, the Fund considers the concentration policies of underlying funds, though it does not look through to all securities held in
underlying funds. The Registrant is not aware that the Staff has issued formal guidance on the application of the concentration policy
to funds of funds. To the extent the Fund determines its investment in an underlying fund exposes the Fund to a material risk, including
significant exposure to a particular industry or group of industries, the Fund will take steps to ensure that it has appropriate risk
disclosure relating to that exposure.

Any comments or questions on this
filing should be directed to the undersigned at (617) 295-2564 (email: Peter.Fariel@dws.com).

Very truly yours,

/s/Peter Fariel

Peter Fariel

Vice President and Senior Legal Counsel

DWS Investment Management Americas, Inc.

cc: 	John Marten, Vedder Price P.C.

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Attachment A

DWS RREEF Completion Fund I

ANNUAL FUND OPERATING EXPENSES

(expenses that you pay each year as a % of the value of your
investment)

    Management fee1
    0.00%

    Distribution/service (12b-1) fees
    None

    Other expenses2
    0.35%

    Total annual fund operating expenses
    0.35%

    Fee waiver/expense reimbursement
    0.35%

    Total annual fund operating expenses after fee waiver/expense reimbursement
    0.00%

1 The Advisor does not charge a management fee to
the fund. Shareholders should be aware, however, that the fund is part of separately managed account investment programs, and the fund's
subadvisor will be compensated directly or indirectly by wrap program sponsors or wrap account clients for separately managed account
advisory services. For additional information on these compensation arrangements, please contact the wrap program sponsor or your
financial representative.”

2 “Other expenses” are based on estimated
amounts for the current fiscal year.

The Advisor has contractually agreed through December 17, 2027
to reimburse fund expenses to the extent necessary to maintain the fund’s total annual operating expenses (excluding certain expenses
such as extraordinary expenses, taxes, brokerage, interest expense and acquired fund fees and expenses) at a ratio no higher than 0.00%.
The agreement may only be terminated with the consent of the fund’s Board.

EXAMPLE

This Example is intended to help you compare the cost of investing
in the fund with the cost of investing in other mutual funds. The Example assumes that you invest $10,000 in the fund for the time periods
indicated and then redeem all of your shares at the end of those periods. The Example also assumes that your investment has a 5% return
each year and that the fund's operating expenses (including three years of capped expenses) remain the same. Although your actual costs
may be higher or lower, based on these assumptions your costs would be:

    1 Year
    3 Years

    $0
    $0

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Attachment B

DWS RREEF Completion Fund I

Revised Prospectus

                      

                  Prospectus

                     December 18, 2024

                   

                                 DWS RREEF Completion Fund I

                                 TICKER: RASFX

                     As with all mutual funds, the Securities and Exchange Commission (SEC) and the Commodity
                           Futures Trading Commission (CFTC) do not approve or disapprove these shares or determine whether the
                           information in this prospectus is truthful or complete. It is a criminal offense for anyone to inform
                           you otherwise.

                      

                  Table of Contents

                   

                                 DWS RREEF Completion Fund I

                                 Investment Objective

                                 1

                                 Fees and Expenses

                                 1

                                 Principal Investment Strategies

                                 1

                                 Main Risks

                                 2

                                 Past Performance

                                 6

                                 Management

                                 6

                                 Purchase and Sale of Fund Shares

                                 6

                                 Tax Information

                                 6

                                 Payments to Broker-Dealers and

                                 Other Financial Intermediaries

                                 6

                                 Fund Details

                                 Additional Information About Fund Strategies and

                                 Risks

                                 7

                                 Other Policies and Risks

                                 13

                                 Who Manages and Oversees the Fund

                                 13

                                 Management

                                 14

                                 Investing in the Fund

                                 Buying, Exchanging and Selling Shares

                                 16

                                 How to Buy Shares

                                 16

                                 How to Sell Shares

                                 16

                                 Policies You Should Know About

                                 16

                                 Policies About Transactions

                                 16

                                 How the Fund Calculates Share Price

                                 18

                                 Other Rights We Reserve

                                 18

                                 Financial Intermediary Support Payments

                                 19

                                 Understanding Distributions and Taxes

                                 20

                                 Financial Highlights

                                 23

                                 Appendix A

                                 24

                                 Hypothetical Expense Summary

                                 24

                        Your investment in the fund is not a bank deposit and is not insured or guaranteed
                              by the Federal Deposit Insurance Corporation or any other government agency, entity or person.

                      

                   

 

                  DWS RREEF Completion Fund I

                   

                                 Ticker: RASFX

                  Investment Objective

                     The fund seeks total return.

                     Fees and Expenses

                     These are the fees and expenses you may pay when you buy, hold and sell shares. You may pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the tables and examples below.

                     SHAREHOLDER FEES 

                                 (paid directly from your investment)

                                    None

                     ANNUAL FUND OPERATING EXPENSES

(expenses that you pay each year as a % of the value of your investment) 

                                 Management fee1

                                    0.00

                                 Distribution/service (12b-1) fees

                                    None

                                 Other expenses2

                                    0.35

                                 Total annual fund operating expenses

                                    0.35

                                 Fee waiver/expense reimbursement

                                    0.35

                                 Total annual fund operating expenses after fee waiver/