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SPDR SERIES TRUST

 Beau Yanoshik

 Partner

 +1.202.373.6133

 beau.yanoshik@morganlewis.com

via EDGAR Correspondence

 October 24, 2023

 Mr. Mark Cowan

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

 Washington,
D.C. 20549 

Re:
 SPDR Series Trust (the “Registrant”); SEC File Nos. 333-57793
and 811-08839; Post-Effective Amendment No. 309 to the Registrant’s Registration Statement on Form N-1A (“Amendment No. 309”)

 Dear Mr. Cowan:

 This letter
responds to comments you provided in a telephonic conversation with me on October 10, 2023, with respect to Amendment No. 309. Amendment No. 309 was filed on August 23, 2023, and included disclosure with respect to the SPDR MSCI
USA Gender Diversity ETF and SPDR S&P Dividend ETF (each, a “Fund” and collectively, the “Funds”), each a series of the Registrant, as set forth in the Prospectuses and Statements of Additional Information filed as part of
Amendment No. 309.

 Summaries of the comments with respect to the Funds, and responses thereto on behalf of the Registrant, are provided below. All
page references refer to the pages in Amendment No. 309. Capitalized terms not defined herein should be given the meaning provided in Amendment No. 309.

Prospectuses:

1.
 Comment: Please confirm whether the SPDR MSCI USA Gender Diversity ETF gave 60 days’ notice to
shareholders prior to changing its index.

 Response: The SPDR MSCI USA Gender Diversity ETF gave shareholders 50
days’ notice prior to the change in the Index.

Morgan, Lewis & Bockius LLP

1111 Pennsylvania Avenue, NW Washington, DC 20004

 +1.202.739.3000

United States

 +1.202.739.3001

2.
 Comment: Please file on EDGAR a completed draft of each Fund’s fee table and example information
prior to effectiveness.

 Response: The completed fee and example tables for each Fund are included in Appendix A
to this correspondence.

3.
 Comment: With respect to the SPDR MSCI USA Gender Diversity ETF, because the name of the Fund includes a
portion of the name of the Fund’s underlying index, please include a Rule 35d-1 policy to invest at least 80% of the Fund’s assets in securities included in the Index. In addition, please include a
Rule 35d-1 policy with respect to the term “gender diversity.” Please disclose these policies, along with the Fund’s Rule 35d-1 policy to invest in
securities of United States companies which is currently disclosed in the SAI, in “The Fund’s Principal Investment Strategy” section, along with disclosure stating that the policies may be changed upon 60 days’ written notice to
shareholders. In addition, please include in either Item 4 or 9 a definition of what the Fund considers a United States company.

Response: The Registrant is aware of the recently adopted amendments to Rule 35d-1 and the
December 10, 2025, compliance date. The Registrant intends to assess and address the amendments with respect to the Registrant’s series, as necessary, prior to the compliance date. The Registrant does not believe, however, under current
Rule 35d-1, that the Fund is required to adopt a Rule 35d-1 policy with respect to securities included in the Index or with respect to the term “gender
diversity.”

 The comment first requests that the Fund include a Rule 35d-1 policy to invest at
least 80% of the Fund’s assets in securities included in the Index because a portion of the Index’s name is included in the name of the Fund. The Registrant notes that Footnote 42 in the 2001 Rule
35d-1 Adopting Release specifies that the term “index” suggests a focus on a particular type of investment and investment companies including this term in their name are therefore subject to Rule 35d-1. The Fund does not include the term “index” in its name and, as a result, the Registrant has not included a Rule 35d-1 policy. Although the Fund has not
included a Rule 35d-1 policy related to the Index in the prospectus and SAI, the Registrant notes that, as stated in the Fund’s principal investment strategy, the Fund, under normal market conditions,
generally invests substantially all, but at least 80%, of its total assets in the securities comprising the Index.

 The comment also
requests that the Fund include a Rule 35d-1 policy with respect to the term “gender diversity.” The Registrant does not believe the term “gender diversity” implicates current Rule 35d-1(a)(2). Current Rule 35d-1(a)(2) requires that a fund with a “name suggesting that the [f]und focuses its investments in a particular type of investment or
investments, or in investments in a particular industry or group of industries,” adopt a policy to invest, under normal circumstances, at least 80% of the value of the fund’s net assets plus borrowings for investment purposes in the types
of investments or industries suggested by the fund’s name. The Registrant respectfully submits that the term “gender diversity” does not suggest investment in any type of investment or industry.

 The comment next requests that the Registrant disclose the Fund’s Rule 35d-1 policy to invest in securities of United States companies which is currently disclosed in the SAI, in “The Fund’s Principal Investment Strategy” section. The Registrant notes that the
“Principal Strategies” discussion within the “Additional Strategies Information” section in Item 9 includes the following disclosure:

As described in the SAI, the Fund has adopted a non-fundamental investment policy to invest at least
80% of its net assets, plus the amount of borrowings for investment purposes, in investments suggested by its name, measured at the time of investment. The Fund will provide shareholders with at least 60 days’ notice prior to any change in this
non-fundamental 80% investment policy. 

 The Registrant believes the current disclosure is
appropriate. In addition to the non-fundamental Rule 35d-1 policy in the SAI and the disclosure noted above in the “Additional Strategies Information” section,
the Fund also has a policy disclosed in “The Fund’s Principal Investment Strategy” section to invest at least 80% of its assets in securities comprising the Index. “The Fund’s Principal Investment Strategy” section
notes that the selection universe for the Index is a parent index designed to measure the performance of the large- and mid-cap segments of the U.S. market. As a result, the Registrant believes the current
disclosure in its totality is clear that the Fund will invest at least 80% of its respective net assets in securities of United States companies.

In response to the request to add a definition of what the Fund considers a United States company, the Registrant has added the following
sentence to the third paragraph in “The Fund’s Principal Investment Strategy” section:

 The MSCI USA Gender Diversity
Select Index (the “Index”) is designed to represent the performance of companies that exhibit a commitment towards promoting and maintaining a high level of gender diversity across the different levels within their organization, including
their corporate board, executive and senior management, and workforce. The selection universe for the Index includes all constituents in the MSCI USA Index (the “Parent Index”), which is designed to measure the performance of the large-
and mid-cap segments of the U.S. market. The Parent Index includes companies classified as United States companies by the Index Provider generally based on the company’s country of incorporation and
the primary listing of its securities.

4.
 Comment: With respect to the following sentence included in “The Fund’s Principal Investment
Strategy” section for each Fund, please include disclosure in both Items 4 and 9 explaining how the investments identified in this sentence help the Fund track the Index.

In addition, in seeking to track the Index, the Fund may invest in equity securities that are not included in the Index, cash and cash
equivalents or money market instruments, such as repurchase agreements and money market funds (including money market funds advised by the Adviser).

Response: Each Fund may invest in the securities identified in the sentence above in a number of circumstances. For example, a Fund may
invest in securities that are not yet represented in the Index in anticipation of their addition to the Index. When a Fund receives cash as part of a creation transaction or due to the sale of a Fund holding, but cannot immediately invest the cash,
the Fund may temporarily hold the cash or invest it in cash equivalents or money market instruments. These investments are consistent with each Fund’s sampling strategy. The Registrant notes the paragraph below, currently included in the
“Principal Strategies” discussion within the “Additional Strategies Information” section in Item 9, explaining the Funds’ sampling strategies.

 The Adviser will utilize a sampling strategy in managing the Fund. Sampling means that the
Adviser uses quantitative analysis to select securities, including securities in the Index, outside of the Index and derivatives that have a similar investment profile as the Index in terms of key risk factors, performance attributes and other
economic characteristics. These include industry weightings, market capitalization, and other financial characteristics of securities. The quantity of holdings in the Fund will be based on a number of factors, including asset size of the Fund. In
addition, from time to time, securities are added to or removed from the Index. The Adviser may sell securities that are represented in the Index, or purchase securities that are not yet represented in the Index, in anticipation of their removal
from or addition to the Index. Further, the Adviser may choose to overweight securities in the Index, purchase or sell securities not in the Index, or utilize various combinations of other available techniques, in seeking to track the Index.

5.
 Comment: Please revise the sentence below, included in “The Fund’s Principal Investment
Strategy” section for each Fund, as noted.

 In seeking to track the Index, the Fund’s assets may
will be concentrated in an industry or group of industries, but only to the extent that the Index concentrates in a particular industry or group of industries.

Response: The Registrant believes the disclosure included in the 485(a) filing is correct and appropriate. In particular, due to the
fact that each Fund employs a sampling strategy, there may be instances when the Index is concentrated in an industry or group of industries, but the Fund is not.

6.
 Comment: Please disclose in “The Fund’s Principal Investment Strategy” section of each
Fund if the Index is concentrated in an industry or group of industries and include corresponding principal risk disclosure in Items 4 and 9 discussing the risks associated with concentration and the risks associated with any industry or group of
industries, as applicable.

 Response: The Registrant has added disclosure to the principal strategies and
principal risks sections related to the sectors which represented a significant portion of the respective Fund as of August 31, 2023.

7.
 Comment: The Staff notes the reference to the “Diversity Management Score” in the SPDR MSCI
USA Gender Diversity ETF’s “The Fund’s Principal Investment Strategy” section. Please disclose the required Diversity Management Score for eligibility for inclusion in the Index.

Response: The Registrant confirms there is no minimum Diversity Management Score necessary for inclusion in the Index. The
Diversity Management Score is not used as a screen, but rather is one of two components for determining a security’s MSCI Gender Diversity Score, as discussed in “The Fund’s Principal Investment Strategy” section.

8.
 Comment: Please provide a plain English explanation of the following sentence included in the SPDR MSCI
USA Gender Diversity ETF’s “The Fund’s Principal Investment Strategy” section.

 For each GICS
(Global Industry Classification Standard) sector, companies are selected for inclusion in the Index primarily in decreasing order of MSCI Gender Diversity Score until 50% of the free float adjusted market capitalization of the sector is reached.

 Response: The Registrant has revised the disclosure as follows:

For each GICS (Global Industry Classification Standard) sector, companies are selected for inclusion in the Index primarily in decreasing
order of MSCI Gender Diversity Score until 50% of the free float adjusted market capitalization (calculated by multiplying the number of shares readily available in the market by the price of such shares) of the sector is
reached.

9.
 Comment: With respect to the following sentence included in the SPDR MSCI USA Gender Diversity
ETF’s “The Fund’s Principal Investment Strategy” section, please confirm if the 4.5% limit applies to a GICS industry/group of industries, or if it applies to individual securities.

To mitigate concentration risk, each security’s weight in the Index is capped at 4.5%, and any weight exceeding this limit will be
redistributed on a pro-rata basis to securities of issuers that do not exceed the 4.5% limit.

Response: The Registrant confirms the 4.5% limit applies to individual securities.

10.
 Comment: For each Fund, please include a Concentration Risk discussion in the “Principal Risks of
Investing in the Fund” section if the Fund will be concentrated.

 Response: The Registrant believes the
current placement of the “Concentration Risk” discussion in the “Non-Principal Risks” section is appropriate. Because each Fund’s strategy is to track its Index, the Fund’s
investments may be concentrated in a particular industry or group of industries to the extent that its Index is concentrated in a particular industry or group of industries. As a result, a Fund may or may not be concentrated at any given time.
The Registrant notes that, to the extent a Fund invests significantly in a sector as of a certain date, disclosure will be included in the Fund’s corresponding “Principal Risks of Investing in the Fund” section.

11.
 Comment: For each Fund, in the “Principal Risks of Investing in the Fund” section, please
revise the “Fluctuation of Net Asset Value, Share Premiums and Discounts Risk” discussion to address the risk of widening bid-ask spreads. For the SPDR MSCI USA Gender Diversity ETF, please add
similar disclosure with regards to the “Valuation Risk” discussion.

 Response: The Registrant believes
the disclosure below, which is currently included in the “Costs of Buying and Selling Shares” discussion, addresses the risks of widening bid-ask spreads and, as a result, the Registrant has not
revised the “Fluctuation of Net Asset Value, Share Premiums and Discounts Risk” and “Valuation Risk” discussions as requested.

 In addition, secondary market investors will also incur the cost of the difference between the
price that an investor is willing to pay for Fund Shares (the “bid” price) and the price at which an investor is willing to sell Fund Shares (the “ask” price). This difference in bid and ask prices is often referred to as the
“spread” or “bid/ask spread.” The bid/ask spread varies over time for Fund Shares based on trading volume and market liquidity, and is generally lower if Fund Shares have more trading volume and market liquidity and higher if
Fund Shares have little trading volume and market liquidity. Further, increased market volatility may cause increased bid/ask spreads. Due to the costs of buying or selling Fund Shares, including bid/ask spreads, frequent trading of Fund Shares may
significantly reduce investment results and an investment in Fund Shares may not be advisable for investors who anticipate regularly making small investments.

12.
 Comment: The Staff notes the inclusion of “Valuation Risk” as a principal risk of the SPDR
MSCI USA Gender Diversity ETF. Given the nature of the Fund’s investments, please explain why potentially a large portion of the Fund’s portfolio may be valued o