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    Eversheds
    Sutherland (US) LLP

    700 Sixth Street, NW, Suite
    700
    Washington, DC 20001-3980

    D: 202.383.0262
    F: 202.637.3593

    OwenPinkerton@eversheds-sutherland.us

December 16, 2022

Via
EDGAR

Eric Envall

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549-4561

 Re: United
                                            States Brent Oil Fund, LP

Registration
Statement on Form S-3

Filed
November 8, 2022

File
No. 333-268246

Dear Mr.
Envall:

On behalf of United
States Brent 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 December 1, 2022, relating to the above referenced Registration Statement (the “Registration
Statement”). The Staff’s comments are set forth below in italics, followed by the Fund’s responses.

Registration
Statement on Form S-3 Filed November 8, 2022

Prospectus
Summary, page 1

 1. Please
prominently discuss the impact of current geopolitical events on the market for Brent crude oil and on BNO. Your discussion should address
volatility in prices and trading volume for Brent crude oil, Brent crude oil futures, and in your shares. Please place this discussion
in context by quantifying, to the extent information is available, the relative contribution of Russia and Ukraine in the global markets
for Brent crude oil, prices of Brent crude oil, the price of your shares, the price of any futures contracts for Brent crude oil, the
extent to which these futures markets are experiencing backwardation, and the increased trading volume of Brent crude oil, Brent crude
oil futures and your shares as of the most recent practicable date.

Similarly,
please revise your risk factors in the section titled “Investment Risk” to describe specific risks of current geopolitical
events for the Brent crude oil markets and for BNO and its investments. Also revise to describe the risks relating to the impact of current
events on underlying assumptions and expectations and the potential for resulting volatility and losses.

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.

    December 16, 2022

    Page 2

Response:	The
Fund respectfully advises the Staff that the global commodities markets are influenced by a number of factors, including seasonal supply
and demand, inflation, the health of the global economy and geopolitical events. The Fund advises the Staff that it believes that the
war between Russia and the Ukraine has impacted certain global commodity markets, including the Brent crude oil market. As a result of
this, disclosure responsive to this request is included in the Registration Statement and, more prominently, in the periodic reports
that are incorporated by reference into the Registration Statement. Specifically, the prospectus includes risk disclosure related to
Russia’s invasion of Ukraine and the impact on global commodity markets, including crude oil. Updates regarding the impact of the
war on the crude oil markets have been included in the quarterly reports on Form 10-Q filed since the war commenced in February 2022.
Finally, it is worth noting that while there has been volatility in the crude oil markets during the last year, which has been discussed
in the Fund’s periodic reports, the current market price for the Fund is approximately equal to what it was immediately prior to
beginning of the war. The most recent quarterly report on Form 10-Q, for example, includes the following disclosures:

Brent
Crude Oil Market:

Bullish
fundamentals for crude oil were already in place when Russia invaded Ukraine in February of 2022, causing the United States and other
countries and certain international organizations to impose broad-ranging economic sanctions on Russia and certain Russian individuals,
banking entities, and corporations as a response. As a result of these sanctions, Russian barrels of oil that were intended for export
have been left stranded, which is exacerbating an already limited supply situation. Russian oil producers have had to search for new
buyers, while those countries and organizations that have imposed sanctions continue to search for additional sources of crude oil supply,
including the 180 million barrels of crude oil that the U.S. announced would be released from the United States Strategic Petroleum Reserve.
The war in Ukraine, sanctions, and the corresponding disruption in the supply of Russian oil, have resulted in significant volatility
in the oil markets, particularly in early March when Brent crude oil briefly rose to over $127.98 per barrel on March 8, 2022, then fell
back to $98.02 per barrel on March 16, 2022, before rising and the falling again to end the first quarter of 2022 at $107.91 per barrel.
A bullish trend for crude oil emerged from mid-April through early June 2022 when Brent crude oil again topped $120 per barrel before,
once again, giving up gains to end the quarter at $114.81. The war in Ukraine and the potential for further supply disruptions and sanctions
could lead to further volatility. However, if a resolution to the conflict were to occur, volatility could decrease and prices could
decline somewhat in a short period of time. Conversely, crude oil prices may be highly reactive to developments as global buyers and
sellers of crude reposition their relationships.

During
the third quarter of 2022, crude oil prices declined substantially, in contrast to strong gains during the first half of the year. In
August 2022, U.S. production rose to a peak of 12.2 mbd while OPEC production peaked at 29.9 mbd. Despite a recovery in demand and tighter
supply (the U.S., Russia, and OPEC have still not returned to pre-pandemic production levels), bearish factors weighed on crude prices
during the third quarter, including a record drawdown in the United States Strategic Petroleum Reserve, OPEC supply cuts, consumer responses
to inflation, rising interest rates, a strong dollar, and concerns about global economic growth. These factors continue to affect crude
prices. Conversely, the ongoing demand recovery for crude oil during a time when supply is lower could lead to higher prices. Supply
constraints, worker shortages, infrastructure and manufacturing energy usage, the war in Ukraine, and other geopolitical tensions, are
factors that could contribute to another bull market for crude oil. Between competing bullish and bearish factors, crude could stay range
bound or could exhibit significant movement up or down over the next few quarters.

The Fund
reviews and updates, as needed, disclosure in its periodic reports in order to take into account, for example, geopolitical events. To
the extent that Russia’s invasion of Ukraine further impacts the crude oil markets, the Fund will consider the most appropriate
way to revise its disclosure, whether it be in its periodic reports or as a supplement to the prospectus. The Fund, however, believes
that its existing disclosures are materially accurate and address the items noted in the Staff’s comment.

    December 16, 2022

    Page 3

Exhibits

 2. The
fee table indicates that you intend to rely on Securities Act Rule 415(a)(6) to include unsold securities from prior registration statements,
file numbers 333-162015, 333-237185, and 333-238282, declared effective on May 27, 2010, April 20, 2020, and June 11, 2020, respectively.
However, it appears that you filed this registration statement more than three years after the initial effective date of one such prior
registration statement. To the extent that you intend to rely on Rule 415(a)(6) to include unsold securities from an earlier registration
statement that went effective within three years of the filing date of this registration statement, please revise to identify the form
type, file number, and initial effective date of the earlier registration statement from which the securities are to be carried forward.
Also please quantify the amount of unsold securities being carried forward. Please refer to Instructions to the Calculation of Filing
Fee Tables and Related Disclosure on Form S-3 for guidance.

Response:	The
Fund advises the Staff that, since the Registration Statement registers an unlimited number of shares as permitted by Rule 415(a)(xiii), there
is no need to carry forward unsold securities registered in prior registration statements. However, the Fund has revised the filing fee
exhibit to identify the source of the fee offset claims that it intends to utilize as additional securities are issued in the future.
Such fee offset claims were carried forward to the most recent registration statement, which was declared effective in June 2020. The
revised filing fee exhibit that we intend to file as part of a pre-effective amendment to the Registration Statement is attached to this
response letter for your convenience.

If you have
any questions about the foregoing, please do not hesitate to contact me at (202) 383-0262 or Raymond A. Ramirez at (202) 383-0868.

    Sincerely,

    /s/ Owen J. Pinkerton

    Owen J. Pinkerton, a partner

    cc:
    James M. Cain, Esq.

    Raymond A. Ramirez, Esq.

    Daphne G. Frydman, Esq.

    December 16, 2022

    Page 4

Filing
Fee Exhibit

Calculation
of Filing Fee Table

S-3

(Form Type)

United
States Brent Oil Fund, LP

(Exact Name of Registrant
as Specified in its Charter)

Table
1: Newly Registered and Carry Forward Securities

    Security

    Type
    Security

    Class Title
    Fee

    Calculation

 or Carry

 Forward

 Rule
    Amount

    Registered
    Proposed

    Maximum

 Offering Price

Per Unit
    Maximum

    Aggregate

 Offering

 Price
    Fee

    Rate
    Amount
    of

 Registration

 Fee
    Carry

    Forward

 Form

 Type
    Carry

    Forward

 File

 Number
    Carry

    Forward

 Initial

 Effective

 Date
    Filing
    Fee

 Previously Paid

 In Connection

 with Unsold

 Securities to be

 Carried Forward

    Newly
    Registered Securities

    Fees
    to Be Paid
    Exchange-Traded
    Security
    United
    States Brent Oil Fund
    Rule
    457(u)
    Indeterminate
    Amount of Securities
    (1)
    (1)
    (1)
    (1)

    Carry
    Forward Securities

    Total
    Offering Amounts

    (1)

    Total
    Fees Previously Paid

    —

    Total
    Fee Offsets

    —

    Net
    Fee Due

    (1)

 (1) The
                                            registration statement covers an indeterminate amount of securities to be offered or sold
                                            and the filing fee will be calculated and paid in accordance with Rule 456(d) and Rule 457(u).

    December 16, 2022

    Page 5

Table
2: Fee Offset Claims and Sources

    Registrant

or Filer

Name
    Form or

Filing

Type
    File

Number
    Initial

Filing Date
    Filing

Date
    Fee Offset

Claimed
    Security

Type

Associated

with Fee

Offset

Claimed
    Security

Title

Associated

with Fee

Offset

Claimed
    Unsold

Securities

Associated

with Fee

Offset

Claimed
    Unsold

Aggregate

Offering

Amount

Associated

with Fee

Offset

Claimed
    Fee Paid

with Fee

Offset

Source

    Rule 457(p)

    Fee Offset Claims
    United States Brent Oil Fund
    S-3
    333-238282
    March 13, 2020

    $181,945.64
    Exchange-Traded Vehicle Securities
    United States Brent Oil Fund
    32,600,000
    $328,608,000

    Fee Offset Sources
    United States Brent Oil Fund
     S-3
    333-238282
    March 13, 2020

    Exchange-Traded Vehicle Securities
    United States Brent Oil Fund
    32,600,000
    $328,608,000
    $181,945.64