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) — Dec 11, 2018
ProShares Trust II (AGQ, EUO, GLL, SCO, UCO, UGL, ULE, YCL, YCS, ZSL, BOIL, KOLD, SVXY, UVXY, VIXM, VIXY) (CIK 0001415311)
Date: Dec. 11, 2018 · CIK: 0001415311 · Accession: 0000000000-18-037717
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File numbers found in text: 333-228620
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December 11, 2018
Todd B. Johnson
Principal Executive Officer
ProShares Trust II
7501 Wisconsin Avenue, Suite 1000E
Bethesda, Maryland 20814
Re:ProShares Trust II
Registration Statement on Form S-1
Filed November 30, 2018
File No. 333-228620
Dear Mr. Johnson:
This is to advise you that we have not reviewed and will not review your registration
statement.
Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Please contact Joshua Lobert, Staff Attorney, at 202-551-7150 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate and
Commodities