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December 1, 2022
John P. Love
President and Chief Executive Officer
United States Commodity Funds LLC
1850 Mt. Diablo Boulevard
Suite 640
Walnut Creek, CA 94596
Re:United States Commodity Index Funds Trust
Registration Statement on Form S-3
Filed November 8, 2022
File No. 333-268250
Dear John P. Love:
            We have limited our review of your registration statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
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
commodities and on USCI. Your discussion should address volatility in prices and trading
volume for commodities, commodity 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 commodities, prices of
commodities, the price of your shares, the price of any futures contracts for commodities,
the extent to which these futures markets are experiencing backwardation, and the
increased trading volume of commodities, commodity futures and your shares as of the
most recent practicable date.

 FirstName LastNameJohn P. Love
 Comapany NameUnited States Commodity Funds LLC
 December 1, 2022 Page 2
 FirstName LastName
John P. Love
United States Commodity Funds LLC
December 1, 2022
Page 2

Similarly, please revise your risk factors in the section titled "Investment Risk" to describe
specific risks of current geopolitical events for the commodities markets and for USCI 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.
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 333-164024 and 333-
254046, declared effective on July 30, 2010 and April 30, 2021, 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.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Eric Envall at (202) 551-3234 or David Lin at (202) 551-3552 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Finance