SecProbe.io

CORRESP
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JOHN
H. LIVELY, Managing Partner

john.lively@practus.com

11300
Tomahawk Creek Pkwy., Suite 310

Leawood,
KS 66211

(913)
660-0778

February
4, 2025

Ms.
Alison T. White

Senior
Counsel

Division
of Investment Management

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

 Re: Precidian
                                            ETFs Trust (File Nos. 333-171987 and 811-22524)

Airbus
ADRhedged™, Bayer AG ADRhedged™, Bayerische Motoren Werke AG ADRhedged™, Deutsche Telekom AG ADRhedged™, Heineken
NV ADRhedged™, Hermes International SA ADRhedged™, Hitachi Ltd. ADRhedged™, L’Oreal SA ADRhedged™, LVMH
Moet Hennessy Louis Vuitton SE ADRhedged™, Nestle SA ADRhedged™, Roche Holding AG ADRhedged™, Siemens AG ADRhedged™,
and Softbank Group Corp. ADRhedged™ (the “Funds”)

Dear
Ms. White:

This
letter provides the responses of Precidian ETFs Trust (the “Trust” or the “Registrant”) to the comments of the
staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) that you provided to Practus,
LLP on January 22, 2025. The comments related to Post-Effective Amendment No. 175 to the registration statements of the Trust, which
was filed on October 24, 2024, under Rule 485(a) of the Securities Act of 1933, as amended (“PEA No. 175”). PEA No. 175 was
filed to register shares of thirteen series of the Trust (collectively the “Funds”). For your convenience, I have summarized
the comments in this letter and provided the Trust’s response below each comment. Capitalized terms not defined in this letter
shall have the same meaning ascribed to such term in the PEA No. 175.

 1. Comment: Disclose
                                            that each Fund will invest in unsponsored ADRs, explain what unsponsored ADRs are and what
                                            the implications of investing in them may be (e.g., type and frequency of available
                                            information, OTC trading volume, impacts to liquidity/valuation etc.).

Response: The
Trust has revised the disclosure to address the Staff’s comment.

 2. Comment: Disclose
                                            that each ADR is quoted in the OTC markets pursuant to SEC rules (and cite the rules) that
                                            require the company to be primarily listed in a foreign jurisdiction, subject to foreign
                                            regulation, and that the company may make the information available in English on its website.

Ms.
Allison White

U.S.
Securities and Exchange Commission

February
4, 2025

Response: The
Trust has revised the disclosure in an attempt to address what we believe the Staff’s comment to be. The Trust notes that in order
for a broker-dealer to publish a quotation for an OTC security (including an OTC ADR), the broker-dealer must comply with Rule 15c2-11
under the Securities Exchange Act of 1934, as amended (“Exchange Act”). Rule 15c2-11 requires the broker-dealer to obtain
and review certain current and publicly available information regarding the issuer of the security prior to publishing a quotation for
an OTC security. This information may be obtained from the issuer or from other reliable public sources. For instance, with respect to
a company that relies upon Rule 12g3-2 under the Exchange Act, a broker-dealer may satisfy its rule 15c2-11 obligations, in part, by
reviewing the information made available by the company to satisfy Rule 12g3-2.

 3. Comment: Indicate
                                            that information about each company underlying the ADRs is typically available in the news
                                            and through other publicly available sources.

Response: The
Trust has revised the disclosure to address the Staff’s comment.

 4. Comment: Briefly
                                            describe the primary business lines of each company underlying the ADRs and include a link
                                            to its website where it provides the required information.

Response: The
Trust has revised the disclosure to address the first part of the Staff’s comment. The Trust declines to take the comment relating
to including a link to the company’s website.

 5. Comment: Briefly
                                            describe material risks associated with each company underlying
                                            the ADRs and each Fund’s investment in its ADRs.

Response: The
Trust has revised the disclosure to address the Staff’s comment.

 6. Comment: The
                                            Staff is concerned that the supply of available ADRs for investment may be limited and impact
                                            each Fund’s ability to operate as an ETF. The Staff believes that it may be possible
                                            that as a Fund grows, its size will create problems in the underlying OTC market that will
                                            impact the arbitrage mechanism, liquidity, and valuation. In correspondence, please describe
                                            how the Fund has considered these issues, including what data and analysis it has considered
                                            prior to launching these products.

Response: The
Adviser has noted that the companies underlying the Funds are among the most well-known companies in the world. Both the ADRs and the
foreign ordinary shares underlying each of the ADRs are highly liquid. In addition to the available supply of ADRs, like ETFs, ADRs have
a mechanism that allows for both creating and redeeming additional ADRs. As a result, depending on liquidity needs, market makers can
easily create new underlying ADRs to meet any demand by delivering the foreign ordinary shares of the underlying company to the
ADR depository bank.

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Ms.
Allison White

U.S.
Securities and Exchange Commission

February
4, 2025

The
Adviser believes that many of the creations of shares of the Funds will be the result of existing underlying ADR shareholders that wish
to eliminate their current foreign exchange exposure. The creation of shares of the Funds by these ADR holders would not require
the purchase of additional ADRs by the purchasing shareholder or the Funds. With respect to additional demand beyond the current underlying
ADR holders, the mechanism described above would provide the necessary liquidity.

*                              *                              *

Please
contact me at (913) 660-0778 regarding the responses contained in this letter.

 Sincerely,

 /s/ John H. Lively

 John H. Lively

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