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CORRESP
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www.dechert.com

      ADAM T. TEUFEL

adam.teufel@dechert.com

+1 202 261 3464 Direct

+1 202 261 3333 Fax

July 22, 2022

VIA EDGAR

Filing Desk

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Attn: Deborah L. O’Neal and Keith O’Connell

Re: Schwab Strategic Trust (File Nos. 333-160595
and 811-22311) (the “Registrant”)

Dear Ms. O’Neal and Mr. O’Connell:

The U.S. Securities and Exchange Commission (“SEC”)
staff (“Staff”) previously provided comments on Post-Effective Amendment (“PEA”) No. 141 to the Registrant’s
registration statement on Form N-1A (“Registration Statement”) under the Securities Act of 1933, as amended (“1933 Act”),
and Amendment No. 143 under the Investment Company Act of 1940, as amended (the “1940 Act”), filed pursuant to Rule 485(a)(2)
under the 1933 Act on March 2, 2022. Dechert LLP responded on behalf of the Registrant via letter dated June 2, 2022. This letter responds
to certain additional comments from the Staff following our prior response letter. PEA No. 141 relates to the registration of shares of
Schwab Crypto Economy ETF (the “Fund”), which is a new series of the Registrant. The SEC staff’s comments set forth
below were provided by you in a telephonic discussion on June 7, 2022.

Throughout this letter, capitalized terms have
the same meaning as in PEA No. 141, unless otherwise noted. A summary of the Staff’s comments, followed by the responses of the
Registrant, is set forth below:

1. Comment: Given the name of the Fund, please add additional disclosure regarding the objective/quantifiable
criteria that will be used by the Fund’s underlying index to determine whether an index constituent is tied economically to the
 “crypto economy.” For example, we suggest that the underlying index adopt a test requiring eligible issuers to derive at least
50% of their revenues or profits from the “crypto economy.” Otherwise, please change the Fund’s name.

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Response:

I. FUND’S NAME, INVESTMENT OBJECTIVE AND PRINCIPAL INVESTMENT
STRATEGIES

The Fund has changed its name to Schwab Crypto
Thematic ETF to more clearly demonstrate that the Fund seeks exposure to an investment theme, not a particular type of investment or industry
within the meaning of Rule 35d-1 under the 1940 Act.

The Fund’s investment objective is to track
as closely as possible, before fees and expenses, the total return of an index that is designed to deliver global exposure to companies
that may benefit from the development or utilization of cryptocurrencies (including bitcoin) and other digital assets, and the business
activities connected to blockchain and other distributed ledger technology. To pursue this investment objective, the Fund has a policy
that under normal circumstances it will invest at least 80% of its net assets (including, for this purpose, any borrowings for investment
purposes) in securities, including depositary receipts, included in the Schwab Crypto Thematic Index (the “Index”) (the “80%
Policy”). The Index’s rules-based methodology is summarized in the Fund’s prospectus. In response to the Staff’s
comment, the following additional disclosure has been added to the Fund’s prospectus:

Summary Section of the Prospectus:

The index is constructed using a proprietary rules-based
methodology. The index methodology identifies and weights securities for inclusion in the index based on an objective determination of
relevance and exposure to the Theme, which involves four steps:

 (1) Each company in the eligible universe (which
includes any company listed on a stock exchange in the Eligible Trading Venues) is scored based on its exposure to the
Theme, their “Thematic Beta”. Each company’s Thematic Beta is calculated by applying a proprietary natural language
algorithm using keyword terms to multiple review large
volumes of publicly available data, including datasets and documents. Each document
is then ‘scored’ for its relevance to the Theme based on a scoring algorithm and the scores for each company in the eligible
universe are aggregated to determine the overall Thematic Beta for each company.

 (2) Each company with a Thematic Beta score greater than zero is
then mapped to one or more common equity securities, including ADRs, GDRs and EDRs, listed on major
stock exchanges in the Eligible Trading Venues (the Index Universe). If a

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   corresponding security cannot be identified then the company
is removed from consideration.

 (3) Liquidity and investability screens are then applied to each
security in the Index Universe. Securities that do not meet the screen criteria are removed from the Index Universe.

 (4) The remaining securities in the Index Universe that have passed
the applicable liquidity and investability screens are ranked by a function of their Thematic Beta and the weight of the security from
the previous rebalancing (if applicable), and up. Up
to 50 companies are kept in the Index Universe. Each security is initially assigned aThe
securities are then reviewed by the index provider to ensure that they are positively exposed to the Theme based on one or more factors
and business metrics applied by the index provider. If it is not possible to gain confidence in the stock’s positive exposure to
the Theme, then the company’s securities are removed from the Index Universe and the next highest ranked company is added. Following
this review, each security is assigned an initial weight that is directly proportionate to its relative Thematic Beta which
is then adjusted based on minimum and maximum weight constraints.

The methodology used by the
index differs from the methodologies used by more traditional indexes to identify and weight index constituents because it utilizes a
natural language algorithm (i.e., searches for key words or terms) to determine a company’s relevance to the Theme, whereas more
traditional index methodologies may utilize financial metrics, such as a company’s past profits or revenue, to identify and weigh
index constituents. Using a natural language algorithm may result in the index including companies that would not be classified by a more
traditional index methodology as a company within the Theme, that do not have material exposure to the Theme based on profits, revenue
or other financial metrics, or that have significant business operations or lines of business unrelated to the Theme. This means that
the operating results of companies included in the index may not be tied economically to the Theme. Conversely, the index methodology
may overlook companies that have material economic exposure to the Theme that otherwise would have been included in the index if the publicly
available data for those companies had included the relevant keyword terms.

  July 22, 2022
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Statutory Prospectus:

Index Methodology

The index is constructed using a proprietary rules-based
methodology. The index methodology identifies and weights securities for inclusion in the index based on an objective determination of
relevance and exposure to the Theme that involves four steps:

Step 1: Calculation of Companies’ Thematic
Betas

Each company in the eligible universe (which
includes any company listed on a stock exchange in the Eligible Trading Venues) is scored based on its exposure to the
Theme, their “Thematic Betas”:

 · Each company’s Thematic Beta is calculated by applying a proprietary natural language algorithm
using keyword terms to multiple review large volumes
of publicly available data, including datasets and documents.

 · Each document is then ‘scored’ for its relevance to the Theme based on a scoring algorithm
and the scores for each company in the eligible universe are aggregated to determine the overall Thematic Beta for each company.

Step 2: Mapping from Companies to Securities

Each company with a Thematic Beta score greater
than zero is then mapped to one or more common equity securities, including ADRs, GDRs and EDRs, listed on major
stock exchanges in the Eligible Trading Venues (the Index Universe). If a corresponding security cannot be identified,
the company is removed from consideration.

Step 3: Applying Security Screens

Eligible companies must have:

 · A minimum average daily trading volume (ADTV) over the most recent 90-day period. The minimum ADTV of
each company will depend on whether the company is a current index constituent or a new index constituent.

 · A minimum free float percentage of total shares outstanding.

 · A minimum free float share class market cap. The minimum free float share class market cap of each company
will depend on whether the company is a current index constituent or a new constituent.

 · More than 30 days of historical returns data over a most recent 50 calendar day period.

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Step 4: Selecting and Weighting the Highest
Ranked Securities

The remaining Index Universe is ranked by a function
of their Thematic Beta and the weight of the security from the previous rebalancing (if applicable), and up to 50 companies are kept in
the Index Universe:. The securities are then reviewed
by the index provider to ensure that they are positively exposed to the Theme, as determined by the index provider, based on one or more
factors and business metrics, including: Theme-related language in the company’s annual report, recent company announcements and
events related to the Theme, evidence of exposure to the Theme through financial results for the company, investing in research and development
in the Theme, and other public evidence of positive exposure. If it is not possible to gain confidence in the company’s positive
exposure to the Theme, as determined by the index provider, then the security is removed from the Index Universe and the next highest
ranked company is added.

Once the underlying securities
have been selected, the Index target weights are calculated:

 · Each security is initially assigned a weight that is directly proportionate to its relative Thematic Beta
which is then adjusted based on maximum and minimum weight constraints, as well as its previous weight in the index (if applicable).

 · The maximum and minimum weight for each security is set at predetermined levels which may be adjusted
downward due to ADTV and free float market cap constraints, or on a constituent’s previous weight.

 · A limit on the aggregate weight of securities is also applied.

II. RELEVANT LAW

Section 35(d) of the 1940 Act prohibits funds
from employing names that are materially deceptive or misleading. The National Securities Markets Improvement Act of 1996 amended Section
35(d) of the 1940 Act to provide the SEC with rulemaking authority to define names or titles that are materially deceptive or misleading.
Pursuant to this authority, the SEC proposed Rule 35d-1 in 1997 (“Proposed Rule”).

A. Rule 35d-1 As Proposed

Under the Proposed Rule, a fund’s name would
be materially deceptive or misleading if the name suggested an investment in certain securities (later changed to investments in the final
Rule) or industries (“Investment/Industry Specific Fund”) unless the fund adopted a fundamental policy to invest at
least 80% of its assets in the type of security or industry indicated by the fund’s name (“80% Test”).

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Where a fund’s name suggested an investment
in a certain country or geographic region (“Location Specific Fund”), the Proposed Rule would have viewed such a name
as being materially deceptive or misleading unless the fund satisfied a two-part test (“Two-Part Test”). First, the
Location Specific Fund would be required to adopt a fundamental policy to invest at least 80% of its assets in securities of issuers that
are economically tied to the particular country or geographic region indicated by the fund’s name (i.e., the 80% Test). Second,
the fund would be required to invest in securities satisfying one of the following criteria:

(i) securities of issuers that are organized
under the laws of the country or of a country within the geographic region suggested by the fund’s name or that maintain their principal
place of business in that country or region;

(ii) securities that are traded principally
in the country or region suggested by the fund’s name; or

(iii) securities of issuers that, during
the issuer’s most recent fiscal year, derived at least 50% of their revenues or profits from goods produced or sold, investments
made, or services performed in the country or region suggested by the fund’s name or that have at least 50% of their assets in that
country or region.

B. Rule 35d-1 As Adopted

After considering comments on the Proposed Rule,
the SEC adopted Rule 35d-1 in 2001 with certain significant changes. In relevant part, the SEC modified the proposed Two-Part Test for
Location Specific Funds by removing the second requirement. The SEC noted that it was persuaded by commentators that this limitation under
the proposed Two-Part Test was “too restrictive” because the three additional criteria could prevent a Location Specific Fund
from investing in certain issuers that would “expose an investment company to the economic fortunes or risks of a country or geographic
region indicated in the fund’s name.” The SEC indicated that the disclosure approach adopted under Rule 35d-1 (without the
second requirement of the Two-Part Test) “will allow [a Location Specific Fund] the flexibility to invest in additional types of
investments that are not addressed by the three proposed criteria” but still expose the fund to the “economic fortunes and
risks of the country or geographic region indicated by its name.”

As adopted, Rule 35d-1 contains different 80%
Tests for Investment/Industry Specific Funds and Location Specific Funds. Under Rule 35d-1(a)(2), an Investment/Industry Specific Fund’s
name will be materially deceptive and misleading unless: (i) the fund adopts a policy to invest, under normal circumstances, at least
80% of its assets in the particular industry suggested by the fund’s name; and (ii) either the policy is a fundamental policy under
Section 8(b)(3) of the 1940 Act, or the fund has adopted a policy to provide the fund’s shareholders with at least 60 days prior
notice of any change in the policy (“Shareholder Notice Policy”).

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Under Rule 35d-1(a)(3), a Location Specific Fund’s
name will be materially deceptive and misleading unless: (i) the fund adopts a policy to invest, under normal circumstances, at least
80% of its assets in investments that are tied economically to the particular country or geographic region suggested by the fund’s
name; (ii) the fund discloses in its prospectus the specific criteria used by the fund to select investments that are consistent with
this policy; and (iii) either the policy is a fundamental policy or the fund has adopted a Shareholder Notice Policy.

III. ANALYSIS

A. The Fund’s Name Does Not Implicate
Rule 35d-1

The Registrant does not believe that Rule 35d-1
is applicable to the Fund. The Fund’s name corresponds with an investment theme, not a particular type of investment or industry,
and the Fund’s new name further emphasizes this distinction. The identification of a particular company as relevant to a particular
investment theme and the relevance of a particular investment theme to one or more companies or groups of companies is governed by the
Index’s proprietary rules-based methodology. Investment themes are not suggestive of a particular type of investment or industry.
Rather, an investment theme connotes a particular investment strategy as opposed to a particular type of investment.

However, as noted above, the Fund has adopted
the 80% Policy related to investment in the Index and discloses how the Index identifies the types of companies that fall within the Theme.

B. A 50% Revenues/Profits
Test is