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PIMCO ETF Trust

 1900 K Street, NW

 Washington, DC 20006-1110

+1 202 261 3300 Main

 +1 202 261 3333 Fax

www.dechert.com

 Adam T. Teufel

adam.teufel@dechert.com

 +1 202 261 3464 Direct

+1 202 261 3164 Fax

 July 3, 2024

 VIA EDGAR

 Division of Investment Management

 U.S. Securities and
Exchange Commission

 100 F Street, N.E.

 Washington, D.C.
20549

Attn:
 Ms. Anu Dubey and Mr. John Kernan

Re:
 PIMCO ETF Trust (the “Registrant”)

 
 File No. 333-279943

Ladies and Gentlemen:

 You previously communicated the
Securities and Exchange Commission (“SEC”) staff’s (the “Staff”) comments to the Registrant’s Information Statement/Prospectus on Form N-14 (“Information Statement/Prospectus”) with respect to the proposed
reorganization (“Reorganization”) of PIMCO Mortgage-Backed Securities Fund (the “Acquired Fund”), a series of PIMCO Funds, with and into PIMCO Mortgage-Backed Securities Active Exchange-Traded Fund (the “Acquiring
Fund”), a series of the Registrant. A summary of the Staff’s comments, along with the Registrant’s responses, is set forth below. Undefined capitalized terms used herein have the same meaning as in the Information
Statement/Prospectus.

 Accounting Comments

Comment 1: Please confirm the 10-year Expense Example for Class C Shares of the Acquired Fund. The Expense Example does not appear to correctly factor
in the expense impact of the automatic conversion to Class A shares after eight years.

 Anu Dubey and John Kernan

July 3, 2024

  Page
 2

 Response: The Registrant will update the Expense Example as follows:

Year
1

Year
3

Year
5

Year
10

 PIMCO Mortgage-Backed Securities Fund (Acquired Fund)

 Institutional Class

$
129

$
403

$
697

$
1,534

 Class I-2

$
139

$
434

$
750

$
1,646

 Class I-3

$
145

$
460

$
798

$
1,753

 Class A

$
538

$
882

$
1,248

$
2,277

 Class C

$
345

$
754

$
1,290

$
2,571

 Pro Forma - Acquiring Fund - PIMCO Mortgage-Backed Securities Active Exchange-Traded
Fund

$
119

$
372

$
644

$
1,420

 If you do not redeem your shares

Year
1

Year
3

Year
5

Year
10

 PIMCO Mortgage-Backed Securities Fund (Acquired Fund)

 Class A

$
538

$
882

$
1,248

$
2,277

 Class C

$
245

$
754

$
1,290

$
2,571

 Legal Comments

Letter to Shareholders

 Comment 2: In the letter to
Shareholders, given that the Acquiring Fund’s expense waiver is disclosed in the fee table as “Not Applicable,” please explain in correspondence why disclosure in the letter to Shareholders says that the Acquiring Fund has a lower
“net” expense ratio.

 Response: The Registrant has revised the disclosure as follows (deleted language struck through):

The Conversion will provide multiple potential benefits for shareholders, including an anticipated lower net expense ratio and
intraday trading flexibility.

 Questions and Answers

Comment 3: In the response to “What is happening to PIMCO Mortgage-Backed Securities Fund? Why am I receiving this document?”, please disclose
which class of shares of PIMCO Government Money Market Fund that each applicable Acquired Fund shareholder will receive in lieu of receiving Acquiring Fund shares.

Response: The Registrant has updated the disclosure as follows (new language underlined):

with respect to Acquired Fund Shareholders who hold Acquired Fund Shares with the Acquired Fund through a direct retirement account or through
a defined contribution plan, for direct accounts with UMB Bank, n.a. listed as the custodian, the exchange of Acquired Fund Shares for shares of the equivalent share class of PIMCO Government Money Market Fund, equal in value to the net asset
value of such Acquired Fund Shares held by such Acquired Fund Shareholders. I-3 Shares of the Acquired Fund may not be held through a direct retirement account or through a defined contribution plan.

 Anu Dubey and John Kernan

July 3, 2024

  Page
 3

 Comment 4: In response to “What is happening to PIMCO Mortgage-Backed Securities Fund? Why am I
receiving this document?”, please disclose what “indirect” means in connection with “indirect defined contribution plans.”

Response: The Registrant has updated the disclosure as follows (new language underlined):

For indirect defined contribution plans held through an intermediary (i.e., accounts not directly registered in the name of the defined
contribution plan at the Acquired Fund’s transfer agent) the handling of the of Acquired Fund shares is dependent on the terms of the applicable defined contribution plan agreement (or other applicable agreement). Below is additional
information regarding Acquiring Fund shareholders.

 Comment 5: In response to “How will the Conversion affect me as a shareholder?”,
please clarify what indirect accounts are and then also reconcile the reference to indirect accounts with the earlier disclosure regarding “indirect defined contribution accounts” referenced in Comment 4.

Response: The Registrant has updated the disclosure as follows (new language underlined):

For indirect accounts held through an intermediary (i.e., accounts not directly registered in the name of the shareholder or defined
contribution plan at the Acquired Fund’s transfer agent), the handling of the Acquired Fund shares is dependent on the terms of the applicable defined contribution plan agreement (or other applicable agreement).

Comment 6: In response to “How will the Conversion affect me as a shareholder?”, under the heading Direct Non-Retirement
Accounts, please state or disclose that Shareholders will receive cash equal to the NAV of the Acquired Fund rather than only saying that shares are expected to be liquidated.

Response: The Registrant has updated the disclosure as follows (new language underlined):

If your assets are not moved to a brokerage account in advance of the Conversion Date, your Acquired Fund shares are expected to be liquidated
and you will receive cash equal in value to the NAV of your liquidated Acquired Fund Shares upon the Conversion Date, which may be a taxable event.

 Anu Dubey and John Kernan

July 3, 2024

  Page
 4

 Comment 7: In response to “Will the fees and expenses of the Acquiring Fund be lower than the
fees and expenses of the Acquired Fund?”, if accurate, please disclose that PIMCO may recoup waived expenses from the Acquiring Fund and/or the Acquired Fund. With respect to the Acquired Fund, please disclose if such ability to recoup carries
over to the Acquiring Fund and briefly describe the terms of the ability to recoup.

 Response: The Registrant has revised the disclosure as follows
(new language underlined; deleted language struck through):

 Yes. Following the Conversion, the Acquiring Fund is expected to have a lower
net expense ratio than the net expense ratio of each share class of the Acquired Fund as the Acquiring Fund is subject to a lower management fee and no distribution and/or service (12b-1) fee. In addition, the Acquiring Fund is
expected to have a lower net expense ratio after taking into consideration fees waived and/or expenses reimbursed pursuant to an expense limitation agreement between the Investment Adviser and the Acquired Fund. Under the expense
limitation agreement, PIMCO may recoup these waivers and/or reimbursements in future periods, not exceeding three years, provided that applicable expenses, plus recoupment, do not exceed the expense limit (or the amount of the expense limit in place
at the time the amount being recouped was originally waived if lower than the expense limit). PIMCO may not recoup from the Acquiring Fund any expenses previously waived and/or reimbursed for the Acquired Fund. The Acquiring Fund is also
expected to have lower gross expenses, before giving effect to fee waivers and/or expense reimbursements, than any class of shares of the Acquired Fund.

Comment 8: In response to “Who will pay the costs in connection with the Conversion?”, please disclose who will pay “brokerage fees and
expenses related to the disposition and acquisition of Acquired Fund assets (including any disposition to raise cash to pay redemption proceeds) [that] will not be covered by PIMCO.”

Response: The Registrant has revised the disclosure as follows (new language underlined; deleted language struck through):

PIMCO will pay the costs incurred by the Funds associated with the Conversion (including the legal costs associated with the Conversion).
However, brokerage fees and expenses related to the disposition and acquisition of Acquired Fund assets (including any disposition to raise cash to pay redemption proceeds) will be borne by the Acquired Fund and/or the Acquiring Fund, as
applicable not be covered by PIMCO.

 Anu Dubey and John Kernan

July 3, 2024

  Page
 5

 Information Statement/Prospectus

Comment 9: In response to “How do the Funds’ investment objectives, principal investment strategies, and investment policies compare?”,
please revise the 80% policy of the Acquiring Fund to apply to “mortgage-backed securities.” See Rule 35d-1(a)(2).

 Response: The
disclosure accurately reflects the 80% policy of the Acquiring Fund.

 The Registrant acknowledges the Staff previously provided comments to the 80% policy
of the Acquiring Fund in connection with the Acquiring Fund’s preliminary registration statement filed as Post-Effective Amendment No. 486 to the Registrant’s registration statement under the Securities Act of 1933, as amended, and
Amendment No. 488 to the Registrant’s registration statement under the Investment Company Act of 1940, as amended (the “preliminary registration statement”), and the Registrant respectfully reiterates that it does not believe
that the Acquiring Fund’s use of the term “mortgage-related Fixed Income Instruments” rather than “mortgage-backed securities” in its 80% policy raises any issue under Rule 35d-1.

As discussed in the response letters provided in response to the Staff’s comments to the preliminary registration statement, funds may include, in
addition to the investments referenced in their names, other instruments (such as synthetic instruments) for purposes of a fund’s 80% policy so long as such other instruments have economic characteristics similar to the investment(s) referenced
in the fund name. The mortgage-related Fixed Income Instruments included in the Acquiring Fund’s 80% policy are mortgage-backed securities, or have economic characteristics similar to mortgage-backed securities, and, therefore, the Registrant
respectfully declines to make the requested change to the Acquiring Fund’s 80% policy.

 Further, the SEC has made it clear that industry usage of
terms is an important consideration in establishing an 80% policy. In that light, the Registrant is aware of other registered funds that include “Mortgage-Backed Securities” in their names and explicitly disclose that mortgage-related
fixed-income instruments are considered in scope for their 80% policies.

 Comment 10: Please revise Call and Put Strategy Risk to incorporate the
changes made in the Acquiring Fund’s registration statement in response to a Staff comment on the preliminary registration statement filing for the Acquiring Fund so that the risk disclosure describes maximum losses in addition to maximum
gains.

 Anu Dubey and John Kernan

July 3, 2024

  Page
 6

 Response: The Registrant has updated the disclosure as follows (new language underlined; deleted
language struck through):

 Call and Put Strategy Risk: The Fund may write calls and/or puts on instruments the Fund owns or otherwise has
exposure to (covered calls or covered puts) or write calls and/or puts on instruments to which the Fund has no exposure (naked calls or naked puts) in return for a premium. The Fund may pursue such a strategy directly or within the structure of an
asset-linked note (such as mortgage-linked notes that may count towards the Fund’s 80% policy). Under a call or put writing strategy (either directly or indirectly through an asset-linked note), the Fund typically would expect to receive cash
(or a premium) for having written (sold) a call or put option, which enables a purchaser of the call to buy (or the purchaser of the put to sell) the asset on which the option is written at a certain price within a specified time frame.

Writing call or put options will limit the Fund’s opportunity to profit from an increase in the market value and other
returns of the underlying asset to the exercise price (plus the premium received). In particular, this will mean that t The Fund’s maximum potential gain via a written covered call or put will
generally be expected to be the premium received from writing a covered call or put option plus the difference between any lower price at which the Fund acquired exposure to the applicable underlying asset and any higher price at
which a purchaser of the call or put option may exercise the call or put option. The Fund’s maximum potential gain via a written naked call or any put will generally be the premium received from writing the
option. The Fund’s maximum potential loss on a written covered call is the purchase price paid for the underlying asset minus the premium received for writing the option. The Fund’s maximum potential loss on a written uncovered call is
theoretically limitless as the value of the underlying asset rises. The Fund’s maximum potential loss on a written put is the entire strike price minus the premium received for writing the option as the value of the underlying asset could fall
to zero. Therefore, covered written calls and covered puts can result in overall losses and detract from the Fund’s total returns even though the call or put options produce premiums and may
initially produce income and cash flow to the Fund (and distributions by the Fund) for having written the call or put options. The Fund’s maximum potential gain via a naked call or put will generally be expected to be limited to
the premium received from writing a naked call or put option.

 Buying a call option or put option will generally involve the Fund
paying a premium on the option, which may detract from returns and may not limit losses. The Fund may lose the initial amount invested in the call option or put option.

When the Fund purchases an asset-linked note with call or put writing exposure embedded within it from a counterparty, the Fund is expected to
receive exposure to the premium of the call or put option within the note (such as in the form of a coupon from the note). Therefore, these notes can provide recurring cash flow and income to the Fund based on

 Anu Dubey and John Kernan

July 3, 2024

  Page
 7

the premiums that would be received from writing call or put options and this can be an important source of the Fund’s return, distributions and/or income. In a rising market, a
covered call or put option may require an underlying instrument to be sold at an exercise price that is lower than would be received if the instrument was sold at the market price. If a call or put expires, the Fund would generally
realize a gain in the amount of the premium received, but because there may have been a decline (unrealized loss) in the market value of the underlying instrument during the option period, the market value loss realized may exceed such gain. If the
underlying instrument declines by more than the option premium the Fund receives, there will be a loss on the overall position, which will detract from the Fund’s total returns even if the call or put options written by the Fund produced
premiums and initially produced distributable Fund distributions, returns, income and/or cash flow. When the Fund purchases an asset-linked note with call or put buying exposure, such exposure and any premiums paid for
the call or put option exposure will generally detract from returns and may not limit losses.

 Comment 11: In response to “How will the
Conversion affect the fees and expenses that I pay as a shareholder of a Fund?”, if accurate, please disclose that PIMCO may recoup waived fees and expens