SEC Comment Letter for ProShares Trust II (AGQ, EUO, GLL, SCO, UCO, UGL, ULE, YCL, YCS, ZSL, BOIL, KOLD, SVXY, UVXY, VIXM, VIXY) (CIK 0001415311) (AGQ) — Jul 22, 2013
ProShares Trust II (AGQ, EUO, GLL, SCO, UCO, UGL, ULE, YCL, YCS, ZSL, BOIL, KOLD, SVXY, UVXY, VIXM, VIXY) (CIK 0001415311)
Date: July 22, 2013 · CIK: 0001415311 · Accession: 0000000000-13-040006
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July 22 , 2013 Via E -mail Edward Karpowicz Principal Financial Officer ProShares Trust II c/o ProShare Capital Management LLC 7501 Wisconsin Avenue Suite 1000 Bethesda, MD 20814 Re: ProShares Trust II Form 10-K Filed March 1 , 201 3 File No. 001 -34200 Dear M r. Karpowicz : We have completed our review of your filing. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. We urge all per sons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require. Sincerely, /s/ Kevin Woody Kevin Woody Branch Chief