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    Eversheds
                                         Sutherland (US) LLP

        700 Sixth Street,
        NW, Suite 700

        Washington, DC 20001-3980

        D: (202) 383.0180

        F: (202) 637.3593

        JamesCain@eversheds-sutherland.com

June
3, 2020

Via EDGAR

Sonia Bednarowski

Dietrich King

United States
Securities and Exchange Commission

Division of
Corporation Finance

100 F Street,
NE

Washington,
DC 20549-4561

 Re: United
                                         States 12 Month Oil Fund, LP

Registration
Statement on Form S-1

Filed
May 15, 2020

File
No. 333-238283

Dear
Ms. Bednarowski and Mr. King:

On behalf of the United States 12 Month Oil Fund, LP (the “Fund”),
set forth below are the Fund’s responses to the comments provided by the staff of the Division of Corporation Finance (the
“Staff”) of the Securities and Exchange Commission (the “Commission) in that certain
letter dated May 29, 2020, relating to the above referenced Registration Statement (the “Registration Statement”).
Each of the Staff’s comments is set forth below in italics followed by the Fund’s response. We are concurrently submitting
via EDGAR this letter and an amendment to the Registration Statement (“Amendment No. 1”). For the Staff’s
reference, we have included both a clean copy of Amendment No. 1 and a copy marked to show all changes from the version filed on
May 15, 2020.

Registration
Statement on Form S-1

Risk Factors
Involved With An Investment in USL, page 4

 1. Please add a new risk factor that addresses the risks to investors
with using the fund as a proxy for investing oil. Specifically address the risks to non-professional investors who are not experienced
in investing oil futures and may not have ready access to the types of information that professional investors may have. In this
regard, we note your disclosure on page 4 that investment in USL is not a proxy for investing in the oil markets.

Response:
We have revised the existing risk factor “An investment
in USL is not a proxy for investing in the crude oil markets, and the daily percentage changes in the price of the Benchmark Oil
Futures Contract, or the NAV of USL, may not correlate with daily percentage changes in the spot price of crude oil”
and made other revisions in the prospectus to address this comment.

    Eversheds Sutherland (US)
    LLP is part of a global legal practice, operating through various separate and distinct legal entities, under Eversheds
    Sutherland. For     a full description of the structure and a list of offices, please visit
    www.eversheds-sutherland.com.

        June 3, 2020

        Page 2

Correlation Risk

Accountability levels, position limits, and daily price fluctuation
limits, page 8

 2. Please update your disclosure in the risk factor on page 8 to disclose
the position limits set forth in the April 23, 2020 CME letter, which supersedes the April 16, 2020 letter. In this regard, we
note your disclosure on page 16 of your Form 10-Q for the quarter ended March 31, 2020.

Response:
We have revised the prospectus to address this comment.

Other Risks

USL and
USCF may have additional conflicts of interests, page 14

 3. We note that you are holding and may continue to invest in the same
type of oil futures contracts that other USCF funds currently hold and purchase pursuant to their investment strategy. For example,
it appears there is overlap between the investments currently held by you and the United States Oil Fund, LP. It also appears that
the limits imposed in the CME Letters apply to both of these oil funds. Please address here and throughout whether your investment
strategy creates additional actual or potential conflicts of interest with USCF’s other oil funds, describing the conflicts
and the material risks they represent to investors.

Response:	While there is some overlap between the investments held by the
Fund and those held by the United States Oil Fund, LP (“USO”), we believe that the current risk factors address the
relevant risks to investors. These risk factors include, among others, Accountability levels, position limits, and daily
price fluctuation limits set by the exchanges have the potential to cause tracking error, by limiting USL’s investments,
including its ability to fully invest in the Benchmark Oil Futures Contract, which could cause the price of shares to substantially
vary from the price of the Benchmark Oil Futures Contract, and USL and USCF may have conflicts of interest, which
may permit them to favor their own interests to the detriment of shareholders.

We
note that we have revised the conflict of interest risk factor to address potential conflicts of the sort described in your
comment and have included a cross reference to the section of the prospectus that addresses in greater detail conflicts of
interest, including this risk.  See “Conflicts of Interest” at page 37. As noted in the risk factor, United
States Commodity Funds, LLC (“USCF”), and the Fund have no formal policies to resolve conflicts of interest of
this type. However, the pursuit by the Fund of its investment objective does not currently create a meaningful conflict of
interest with USO as it relates to the imposition of the accountability levels and position limits imposed by the CME because
of (i) the Fund’s much smaller asset size as compared to that of USO and the fact that, as a result, the Fund holds far
fewer oil futures contracts than USO, and (ii) the Fund’s oil futures contracts holdings are equally apportioned over
each of the next consecutive 12 contract months, unlike USO’s holdings, which are concentrated in oil futures contracts
that are primarily in oil futures contracts that are in months that are in the front of the futures curve. USCF is able to
manage compliance with the CME accountability levels and position limits in a manner that currently does not limit the
Fund’s ability to invest in its Benchmark Oil Futures Contracts for the following reasons. First, the Fund holds
significantly fewer oil futures contracts in the months that are subject to the CME levels and limits than those held by USO
in the same contract months. Second, historically, the Fund has held a relatively small position in each of twelve months of
oil futures contracts because of the asset levels of the Fund so that even when the Fund’s holdings are aggregated with
USO’s holdings, there has not been an issue with respect to CME levels and limits due to the higher notional level of
value of the oil futures markets. Finally, as noted below, the risk mitigation measures imposed by the Fund’s futures
commission merchant (“FCM”) on USO but not, as noted below, imposed on the Fund, further reduce the impact on
investors of ownership of similar oil futures contracts subject to the CME limits.  As a result, there is no need to
include additional disclosure regarding any overlapping investment strategy of the Fund and USO beyond the risk factors and
discussions already included in the Fund’s prospectus.

        June 3, 2020

        Page 3

General

 4. We note your disclosure on page 16 of your Form 10-Q for the quarter
ended March 31, 2020 that "[d]ue to evolving market conditions, a change in regulator accountability levels and position limits
imposed on USL with respect to its investment in Oil Futures Contracts as discussed in the CME Letters, additional or different
risk mitigation measures taken by USL’s FCM with respect to USL acquiring additional Oil Futures contracts, USL intends to
invest in other permitted investments, beyond the Benchmark Oil Futures Contract." Please revise the disclosure in your registration
statement to describe your current plans, if any, to invest in these "other permitted investments." If you do not have
any current plans to change your investment strategy, please disclose this.

Response:
The disclosure in the Registration Statement is correct and the Fund will ensure
that any disclosure included in Forms 10-Q that it files in the future will be consistent with the Registration Statement disclosure. While
the Fund reserves the right to invest in other permitted investments, as disclosed in the Registration Statement, the Fund does not currently
plan to invest in investments other than the Benchmark Oil Futures Contracts to pursue its investment objective.

 5. Please describe any constraints placed on you by your FCM and how
those constraints impact your ability to invest in the Benchmark Oil Futures Contract or any other oil futures contracts. In this
regard, we note your disclosure in your Form 10-Q for the quarter ended March 31, 2020 that addresses risk mitigation measures
taken by your FCM with respect to the acquisition of additional oil futures contracts. In addition, please file your agreement
with your FCM as an exhibit to the registration statement.

Response:
Neither of the Fund’s FCMs have imposed risk mitigation measures
that limit the ability of the Fund to acquire additional oil futures contracts. The only such risk mitigation measures have been
imposed on USO.

We have also filed as exhibits to the Registration Statement, by
incorporation by reference to the relevant previously filed Current Report on Form 8-K, the forms of the Fund’s agreements
with its two FCMs.

If you have any questions about the foregoing, please do not hesitate
to contact me at (202) 383.0180 or JamesCain@eversheds-sutherland.com.

Sincerely,

/s/
James M. Cain

James
M. Cain, a partner

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