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SPDR SERIES TRUST

 Beau Yanoshik

 Partner

 +1.202.373.6133

 beau.yanoshik@morganlewis.com

via EDGAR Correspondence

 August 29, 2024

 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. 316 to the Registrant’s Registration Statement on Form N-1A (“Amendment No. 316”)

 Dear Mr. Cowan:

 This letter
responds to comments you provided in a telephonic conversation with me on July 30, 2024, with respect to Amendment No. 316. Amendment No. 316 was filed on June 21, 2024, and included disclosure with respect to the SPDR Bloomberg
Enhanced Roll Yield Commodity Strategy No K-1 ETF (the “Fund”), a series of the Registrant, as set forth in the Prospectus and Statement of Additional Information filed as part of Amendment
No. 316.

 Summaries of the comments with respect to the Fund, and responses thereto on behalf of the Registrant, are provided below. All page
references refer to the pages in Amendment No. 316. Capitalized terms not defined herein should be given the meaning provided in Amendment No. 316.

Prospectus:

1.
 Comment: Please consider revising the Fund’s investment objective to include the name of the index
the Fund seeks to track.

 Response: The Registrant believes the current investment objective provides an accurate
description of the Index, which the Registrant believes may be more helpful to investors than including the name of the Index. As a result, the Registrant respectfully declines to revise the investment objective as suggested.

Morgan, Lewis & Bockius LLP

 1111 Pennsylvania Avenue, NW

 Washington, DC
20004

 United States

 +1.202.739.3000

+1.202.739.3001

2.
 Comment: Please file on EDGAR a completed draft of the Fund’s fee table and example information and
ensure the Fund’s ticker symbol and series and class IDs have been completed on EDGAR prior to effectiveness.

Response: The completed fee and example tables are included in Appendix A to this correspondence. The Registrant confirms the
Fund’s ticker symbol and series and class IDs will be updated on EDGAR prior to effectiveness.

3.
 Comment: The Staff notes the Fund intends to invest in a wholly owned subsidiary organized in the Cayman
Islands (the “Subsidiary”). Please confirm the Subsidiary’s management fee, including any performance fee, will be included in the “Management fees” line item in the “Annual Fund Operating Expenses” table or,
alternatively, if the Subsidiary’s management fee will be offset.

 Response: SSGA Funds Management, Inc.
(“SSGA FM”), investment adviser to the Subsidiary, will not charge a management fee to the Subsidiary.

4.
 Comment: Please confirm in correspondence that the Subsidiary’s other expenses will be included in
the “Other expenses” line item in the “Annual Fund Operating Expenses” table.

 Response: SSGA
FM will pay all fees and expenses of the Subsidiary, except for brokerage expenses, taxes, interest, fees and expenses of the Cayman Subsidiary’s board, litigation expenses and other extraordinary expenses (the “excluded expenses”).
Any excluded expenses will be included in the Fund’s “Other expenses” line item in the “Annual Fund Operating Expenses” table. The excluded expenses are currently not expected to exceed one basis point of the Fund’s
average net assets.

5.
 Comment: Please revise the Fund’s Rule 35d-1 80% policy to
identify the Index by name.

 Response: The Registrant believes the Fund’s current Rule 35d-1 80% policy is appropriate. The Registrant notes the Fund will operate as an index fund, in that the Fund generally seeks to track the performance of a third-party index. However, because the Fund tracks a
third-party index, the Registrant has no control over changes to the index, changes to the name of the index, or even the continued availability of the index. The Registrant does, however, have control over what instruments are included in the Fund.
Consequently, the Registrant believes it is more appropriate, and consistent with the requirements of Rule 35d-1, to have a policy to invest at least 80% of its assets in the instruments comprising the index
the Fund seeks to track. Despite not including the Index’s name in its Rule 35d-1 80% policy, to the extent the name of the index, or even the index itself, is changed in the future, the Registrant will
endeavor to provide shareholders sufficient notice prior to such change.

6.
 Comment: Please consider reorganizing “The Fund’s Principal Investment Strategy” section.
For example, rather that beginning with the Fund’s 80% policy, consider noting that the Fund seeks to track the Index.

Response: The Registrant has made the requested change.

7.
 Comment: The Staff notes “The Fund’s Principal Investment Strategy” includes information
about when the Index rebalances and reconstitutes. Please disclose in the strategy whether the Fund will reposition its portfolio on the same schedule as the Index.

 Response: The Registrant notes that “The Fund’s Principal Investment Strategy”
states the Fund seeks to track the performance of the Index, which the Registrant believes sufficiently implies that the Fund generally will rebalance and reconstitute on the same schedule as the Index. However, there may be instances where the Fund
may dispose of investments or instruments providing exposure to investments comprising the Index, or purchase investments or instruments providing exposure to investments that are not yet represented in the Index, in anticipation of their removal
from or addition to the Index. In such instances, the Fund will not rebalance its portfolio at the exact same time as the Index rebalance. The Registrant has added the following disclosure to the “Principal Strategies” discussion in the
“Additional Strategies Information” section of the Prospectus:

 The Adviser seeks to track the performance of the
Fund’s Index as closely as possible (i.e., obtain a high degree of correlation with the Index). A number of factors may affect the Fund’s ability to achieve a high degree of correlation with its Index, and there can be no guarantee that
the Fund will achieve a high degree of correlation. For example, the Fund may not be able to achieve a high degree of correlation with its Index when there are practical difficulties or substantial costs involved in compiling a portfolio of
securities and/or instruments to follow the Index, when a security and/or instrument in the Index becomes temporarily illiquid, unavailable or less liquid, or legal restrictions exist that prohibit the Fund from investing in a security and/or
instrument in the Index. In addition, from time to time, investments are added to or removed from the Index. The Adviser may sell investments or instruments providing exposure to investments that are represented in the Index, or purchase
investments or instruments providing exposure to investments 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 exposure to investments in the
Index, purchase or sell investments or instruments providing exposure to investments not in the Index, or utilize various combinations of other available techniques, in seeking to track the Index.

8.
 Comment: As the Fund will invest in a wholly owned subsidiary organized in the Cayman Islands, the Fund
should provide the following disclosure:

a.
 Disclose that the Fund complies with the provisions of the Investment Company Act of 1940 (“1940
Act”) governing investment policies (Section 8) on an aggregate basis with the Subsidiary.

 Response: The
Registrant confirms that the Fund complies with such provisions on an aggregate basis with the Subsidiary.

b.
 Disclose that the Fund complies with the provisions of the 1940 Act governing capital structure and leverage
(Section 18) on an aggregate basis with the Subsidiary so that the Fund treats the Subsidiary’s debt as its own for purposes of Section 18.

Response: The Registrant confirms that the Fund complies with such provisions on an aggregate basis with the Subsidiary.

c.
 Disclose that any investment adviser to the Subsidiary complies with provisions of the Investment Company Act
relating to investment advisory contracts (Section 15) as if it were an investment adviser to the Fund under Section 2(a)(20) of the Investment Company Act. Any investment advisory agreement between the Subsidiary and its investment adviser is
a material contract that should be included as an exhibit to the registration statement. If the same person is the adviser to both the Fund and the Subsidiary, then, for purposes of complying with Section 15(c), the reviews of the Fund’s
and the Subsidiary’s investment advisory agreements may be combined.

 Response: The Registrant respectfully
submits that the Subsidiary is not a registered investment company under the 1940 Act and is therefore not required to comply with the requirements of Section 15 of the 1940 Act. In addition, the Registrant does not believe that the
Subsidiary’s advisory agreement is a material contract of the Fund requiring its inclusion as an exhibit to the registration statement. Notwithstanding, many of the material terms of the Subsidiary’s advisory agreement are similar to those
of the advisory agreement for the Fund.

d.
 Disclose that the Subsidiary complies with provisions relating to affiliated transactions and custody (Section
17). Identify the custodian of the Subsidiary, if any.

 Response: The Registrant confirms that, with respect to
the Fund, the Subsidiary will comply with the provisions relating to affiliated transactions under Section 17 and the rules thereunder. The Registrant also confirms that the Subsidiary’s custodial arrangements will comply with the
requirements of Section 17(f) of the 1940 Act. The registration statement has been revised to note that State Street Bank and Trust Company, the Fund’s custodian, also serves as the custodian to the Subsidiary.

e.
 Explain in correspondence whether the financial statements of the Subsidiary will be consolidated with those of
the Fund. If not, please explain why not.

 Response: The Registrant confirms that the Subsidiary’s financial
statements will be reported on a consolidated basis with those of the Fund.

f.
 Confirm in correspondence that the Subsidiary and its board of directors will agree to inspection by the Staff
of the Subsidiary’s books and records, which will be maintained in accordance with Section 31 of the Investment Company Act and the rules thereunder.

Response: The Registrant so confirms.

g.
 Confirm in correspondence that the Subsidiary and its board of directors will agree to designate an agent for
service of process in the United States.

 Response: The Registrant so confirms.

h.
 Disclose that the Fund does not currently intend to create or acquire primary control of any entity which
primarily engages in investment activities in securities or other assets, other than entities wholly-owned or majority-owned by the Fund.

 Response: The Registrant has added the following disclosure to the “Use of a Cayman
Islands Organized Subsidiary” discussion in the “Investment Policies” section of the SAI:

 The Fund does not
currently intend to create or acquire primary control of any entity which primarily engages in investment activities in securities or other assets, other than entities wholly-owned or majority-owned by the Fund.

9.
 Comment: Please consider adding disclosure to “The Fund’s Principal Investment Strategy”
section disclosing that in seeking to track the Index, the Fund’s assets will be concentrated to the same extent as the Index. In addition, please disclose in the principal investment strategy 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 the following sentence to “The Fund’s Principal Investment Strategy” section.

In seeking to track the Index, the Fund’s assets may 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.

 In addition, the Registrant has added the sentence below to
“The Fund’s Principal Investment Strategy” section and a discussion of risks relating to metals commodities, agricultural commodities, and energy commodities to the “Principal Risks of Investing in the Fund” section.

As of June 30, 2024, the Index had significant exposure to metals commodities, agricultural commodities, and energy commodities.

10.
 Comment: “The Fund’s Principal Investment Strategy” section states the Fund and the
Subsidiary may invest in money market funds. Please add a line item for “Acquired Fund Fees and Expenses” to the “Annual Fund Operating Expenses” table to the extent such investments equal or exceed one basis point.

 Response: Pursuant to the investment advisory agreement between the Adviser and the Registrant, on behalf of the
Fund, the Fund’s management fee is reduced by the amount of any acquired fund fees and expenses attributable to the Fund’s investments in other investment companies (except acquired fund fees and expenses associated with holdings of
acquired funds for cash management purposes). The acquired fund fees and expenses associated with holdings of acquired funds for cash management purposes are not currently expected to exceed one basis point. As a result, the Registrant does not
believe a separate line item for acquired fund fees and expenses is necessary. The Registration Statement has been updated to reflect that the Fund’s management fee is reduced by the amount of any acquired fund fees and expenses attributable to
the Fund’s investments in other investment companies (except acquired fund fees and expenses associated with holdings of acquired funds for cash management purposes).

11.
 Comment: If the Fund will derive its returns principally from swaps, please include a footnote to the
“Annual Fund Operating Expenses” table disclosing the cost of investing in swaps (e.g., the footnote should explain that the embedded cost of the swap(s) and the operating expenses of the reference assets are indirect expenses of the fund
that are not included in either the Fee Table or the Expense Example.) The Fund should also provide an estimate of such costs (as a percentage of Fund assets) for the current fiscal year.

Response: The Registrant has reviewed the requirements of Form N-1A and respectfully declines to
make the requested change. The Registrant notes that General Instruction C(3)(b) to Form N-1A does not permit the inclusion in Items 2 through 8 of information that is not required by those items, and that the
requested footnote is not required by those items.

12.
 Comment: Please confirm the inclusion of “Debt Securities Risk” in the “Principal Risks
of Investing in the Fund” section.

 Response: The Registrant has removed the “Debt Securities Risk”
discussion from the “Principal Risks of Investing in the Fund” section. The Registrant has added the “U.S. Treasury Obligations Risk” discussion below.

U.S. Treasury Obligations Risk: U.S. Treasury obligations may differ from other fixed income securities in their interest rates,
maturities, times of issuance and other characteristics. Similar to other issuers, changes to the financial condition or credit rating of the U.S. government may cause the value of the Fund’s U.S. Treasury obligations to decline.

In addition, the Registrant has revised the last sentence of the first paragraph of “The Fund’s Principal Investment Strategy”
as noted below.

 The Subsidiary and the Fund may also inv