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CORRESP
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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 Commodity Index Funds Trust

United
States Commodity Index Fund

Registration
Statement on Form S-3

Filed
November 8, 2022

File
No. 333-268250

Dear Mr.
Envall:

On behalf of United
States Commodity Index Funds Trust (the “Trust”),
set forth below are the Trust’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 Trust’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 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.

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.

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 Trust advises the Staff that it believes
that the war between Russia and the Ukraine has impacted certain global commodity markets. Since the Fund tracks an index composed of
14 separate commodity futures contracts, the impact of the war on the index as a whole has not been as significant as it has for certain
individual commodities.

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

The investment
objective of USCI is for the daily changes in percentage terms of its shares’ per share net asset value (“NAV”) to
reflect the daily changes in percentage terms of the SummerHaven Dynamic Commodity Index Total ReturnSM (the
“SDCI”), less USCI’s expenses. The SDCI is a commodity sector index designed to broadly represent major commodities
while overweighting the components that are assessed to be in a low inventory state and underweighting the components assessed to be
in a high inventory state.

The SDCI
is designed to reflect the performance of a fully margined or collateralized portfolio of 14 eligible commodity futures contracts with
equal weights, selected each month from a universe of 27 eligible commodity futures contracts. The SDCI is rules-based and rebalanced
monthly based on observable price signals. In this context, the term “rules-based” is meant to indicate that the composition
of the SDCI in any given month will be determined by quantitative formulas relating to the prices of the futures contracts that relate
to the commodities that are eligible to be included in the SDCI. Such formulas are not subject to adjustment based on other factors.

Because
of the number of commodities that comprise the SDCI, it is worth noting that while there has been volatility in various commodity markets
during the last year, the volatility in the SDCI as well as the market prices of the Fund’s shares is consistent with the general
volatility experienced in prior years, as demonstrated by the “Composite Performance Data” for the Fund found on page 36
of the prospectus.

Notwithstanding
this, the Trust has included disclosure that is responsive to this request 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.

Updates
regarding the impact of the war on the commodity markets have been included in the quarterly reports on Form 10-Q filed since the war
commenced in February 2022. The most recent quarterly report on Form 10-Q, for example, includes the following disclosures related to
the war between Russia and Ukraine:

The war
in Ukraine has raised concerns among investors that a global shortage of many commodities is possible. Russia, Ukraine, and Belarus are
major producers and exporters of many metals, grains, and energy products that are critical to global supply. Substantial productive
capacity has been halted in Ukraine, and Russia may be unable or unwilling to export what it produces. This has put upward pressure on
commodity prices globally, beyond the impact of bullish fundamentals that were already in place. Should the war continue or escalate,
or if sanctions or retaliation lead to a further reduction in production and exports from Ukraine, Russia, and Belarus, then commodity
prices could rise further and prices could become more volatile. Conversely, should concerns about commodity shortages resulting from
the war in Ukraine ebb due to an expected or actual resolution of the war, then commodity prices could stabilize or decline.

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 underlying components of the SDCI, 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 333-164024 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.

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 April 2021. 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 Commodity Index Funds Trust

(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 Commodity Index 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 Commodity Index Funds Trust
    S-3

    333-254046
    March
    9, 2021

    $70,436.38
    Exchange-Traded
    Vehicle Securities
    United
    States Commodity Index Fund
    12,650,000
    $459,068,500

    Fee
    Offset Sources
    United
    States Commodity Index Funds Trust
    S-3

    333-254046
    March
    9, 2021

    Exchange-Traded
    Vehicle Securities
    United
    States Commodity Index Fund
    12,650,000
    $459,068,500
    $70,436.38