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SEC Company Response from GUGGENHEIM STRATEGIC OPPORTUNITIES FUND (GOF) (CIK 0001380936) (GOF) — Jul 24, 2007

GUGGENHEIM STRATEGIC OPPORTUNITIES FUND (GOF) (CIK 0001380936)
Date: July 24, 2007 · CIK: 0001380936 · Accession: 0001104659-07-055592

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File numbers found in text: 333-138686, 811-21982

Date
July 24, 2007
Author
WACHOVIA CAPITAL MARKETS, LLC
Form
CORRESP
Company
GUGGENHEIM STRATEGIC OPPORTUNITIES FUND (GOF) (CIK 0001380936)

Letter

Securities and Exchange Commission Division of Investment Management Washington, D.C. 20549 Re: Claymore/Guggenheim Strategic Opportunities Fund—Registration Statement on Form N-2 (File Nos. 333-138686 and 811-21982)

Dear Mr. Sandoe:

In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Claymore/Guggenheim Strategic Opportunities Fund hereby requests acceleration of the effective date of the above-captioned Registration Statement so that it may become effective at 12:00 p.m., Eastern time, on July 26, 2007 or as soon as practical thereafter.

Sincerely,

CLAYMORE/GUGGENHEIM STRATEGIC

OPPORTUNITIES FUND

By:

/s/ Nicholas Dalmaso

Nicholas Dalmaso

Chief Legal and Executive Officer

[WACHOVIA LOGO]

July 24, 2007

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-4720

Attention: Mr. Christian T. Sandoe

Re:

Claymore/Guggenheim Strategic Opportunities Fund

Common Shares of Beneficial Interest

Registration Nos.

333-138686

811-21982

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned, as the representative of the prospective Underwriters of the above captioned securities, hereby joins in the request of the Claymore/Guggenheim Strategic Opportunities Fund that the effectiveness of the Registration Statement relating to such securities be accelerated so that the Registration Statement will become effective by 12:00 p.m., Eastern Time, on July 26, 2007, or as soon thereafter as practicable.

Very truly yours,
WACHOVIA CAPITAL MARKETS, LLC

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CORRESP
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Claymore/Guggenheim
Strategic Opportunities Fund

2455 Corporate West Drive

Lisle, Illinois
60532

July 24, 2007

Mr. Christian T. Sandoe

Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, D.C. 20549

  Re:

  Claymore/Guggenheim Strategic Opportunities
  Fund—Registration

  Statement on Form N-2 (File Nos. 333-138686 and
  811-21982)

Dear Mr. Sandoe:

In accordance with
Rule 461 of the General Rules and Regulations under the Securities Act of 1933,
as amended, Claymore/Guggenheim Strategic Opportunities Fund hereby requests
acceleration of the effective date of the above-captioned Registration
Statement so that it may become effective at 12:00 p.m., Eastern time, on July
26, 2007 or as soon as practical thereafter.

  Sincerely,

  CLAYMORE/GUGGENHEIM STRATEGIC

  OPPORTUNITIES FUND

  By:

  /s/  Nicholas Dalmaso

  Nicholas Dalmaso

  Chief Legal and Executive Officer

[WACHOVIA LOGO]

July 24, 2007

Securities and Exchange
Commission

100 F Street, N.E.

Washington, D.C.  20549-4720

Attention: Mr. Christian T. Sandoe

  Re:

  Claymore/Guggenheim Strategic Opportunities Fund

  Common Shares of Beneficial Interest

  Registration Nos.

  333-138686

  811-21982

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, the
undersigned, as the representative of the prospective Underwriters of the above
captioned securities, hereby joins in the request of the Claymore/Guggenheim
Strategic Opportunities Fund that the effectiveness of the Registration
Statement relating to such securities be accelerated so that the Registration
Statement will become effective by 12:00 p.m., Eastern Time, on July 26, 2007,
or as soon thereafter as practicable.

  Very truly yours,

  WACHOVIA CAPITAL MARKETS, LLC

  By:

  /s/ Lear Beyer

  Lear Beyer

  Managing Director