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 14, 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 additional comments of the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) that you provided to Practus, LLP on February 10, 2025.
The comments related to Post-Effective Amendment No. 175 to the registration statement 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”), as well as the Trust’s response dated February
4, 2025, to the Staff’s comments provided on January 22, 2025 (the “Prior Response Letter”). 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:	With respect to the Trust’s response in
the Prior Response Letter to the Staff’s first comment, please move the additional explanation of what unsponsored ADRs are, and
the implications of investing in such ADRs, to the strategy section of the prospectus and include a statement that underlying companies
are not required to file reports with the Commission.

  Response: The Trust has revised the disclosure as you have requested.

2. Comment:	With respect to the Trust’s response in the Prior Response Letter to the
Staff’s fourth comment, the Staff is reissuing the request that the Trust include a link to the underlying company’s website
in the prospectus.

  Response: The Trust has revised the disclosure as you
                              have requested.

    Ms. Allison White

U.S. Securities and Exchange Commission

February 14, 2025

3. Comment: With respect to the Trust’s response in the Prior Response Letter to
                                the Staff’s fifth comment, the Staff is reissuing the comment relating to the disclosure of the material risks of investing in
                                each underlying company. Please provide more fulsome risk disclosure as it relates to each underlying company.

  Response:	The Trust has revised the disclosure as you have requested.

4. Comment: With respect
                                            to the Trust’s response in the Prior Response Letter to the Staff’s sixth comment,
                                            supplementally, please provide specific information supporting the statement that the ADRs
                                            are highly liquid. In your response, please consider identifying how many ADRs are traded
                                            OTC on a daily basis and what is the bid/ask spread over the last quarter. Please also provide
                                            the basis for the Adviser’s belief that ADR depositary banks will, on a timely basis,
                                            create and redeem unsponsored ADRs in sufficient quantities to allow the efficient functioning
                                            of the Funds’ arbitrage mechanism.

  Response:	With respect to the trading data requested, the Adviser has
               provided the following:

    Name
    Ticker
    MKT CAP (U$)
    30D AVG V

OLUME
    100D AVG

 VOLUME
    90D AVG

 SPREAD

    AIRBUS SE - UNSP ADR
    EADSY
    136,962,080,280
    281,292
    337,461
    0.04

    BAYER AG-SPONSORED ADR
    BAYRY
    21,141,766,245
    1,461,124
    1,402,241
    0.01

    BAYERISCHE MOTOREN WERKE AG
    BMWKY
    45,745,878,126
    114,624

    0.08

    DEUTSCHE TELEKOM AG-SPON ADR
    DTEGY
    175,323,884,235
    399,492
    290,901
    0.06

    HEINEKEN NV-SPN ADR
    HEINY
    40,642,744,373
    305,066
    243,095
    0.08

    HERMES INTL - UNSPONSORED ADR
    HESAY
    300,218,293,846
    35,973
    46,360
    0.36

    HITACHI LTD - ADR
    HTHIY
    122,031,753,316
    137,341
    156,773
    0.21

    L'OREAL-UNSPONSORED ADR
    LRLCY
    188,678,932,416
    266,967
    314,614
    0.06

    LVMH MOET HENNESSY-UNSP ADR
    LVMUY
    355,259,401,990
    377,670
    410,377
    0.14

    NESTLE SA-SPONS ADR
    NSRGY
    224,206,500,000
    1,075,448
    1,139,911
    0.06

    ROCHE HOLDINGS LTD-SPONS ADR
    RHHBY
    257,401,259,360
    1,700,361
    1,300,411
    0.04

    SIEMENS AG-SPONS ADR
    SIEGY
    177,424,000,000
    220,366
    159,697
    0.12

    SOFTBANK GROUP CORP-UNSP ADR
    SFTBY
    90,779,555,429
    832,402
    567,887
    0.08

  The
Adviser has informed the Trust that it is common practice for depositary banks of unsponsored ADRs to facilitate the creation of new ADRs
and that Precidian is not aware of any circumstances in which the depositary bank has failed to do so. The Trust further notes that depositary
banks have an incentive to facilitate creations of ADRs to increase diversification of ownership, raise brand awareness and improve ADR
liquidity.

5. Comment:	In the Principal Investment Strategies
                                       section of the prospectus, please expand the underlying company strategy disclosure so that it
                                       is more specific to each underlying company, and state that the company’s ADRs are quoted
                                       in the OTC markets pursuant to SEC rules and state what those rules require. Please consider directing
                                       investors to where information about the underlying ADR is such that it is obvious that the underlying
                                       company is relying on the rule. Please also expand the business description so that it is more
                                       robust. This might include (1) disclosure of the foreign exchange on which the company is listed
                                       and its market capitalization; (2) the products, services and business units of the company; and
                                       (3) the most recent annual revenue and net income.

  Response:	The Trust has revised the disclosure as you have requested.

         2

    Ms. Allison White

U.S. Securities and Exchange Commission

February 14, 2025

6. Comment:	 During a follow-up discussion on February
                                       12, 2025, with Jay Williamson, we discussed the disclosures for, and publicly available information,
                                       with respect to each of the Funds and concepts surrounding each ADR’s F-6 filing, and applicability
                                       of Rules 12g3-2 and 15c2-11 under the Securities Exchange Act of 1934, as amended (the “Exchange
                                       Act”). Mr. Williamson asked us generally to comment on these topics in our response.

  Response: As we discussed with Mr. Williamson, each ADR that is an underlying
               asset of a particular Fund is traded in the over-the-counter markets (the “OTC markets”) in the United States.
               In a prior response to you, we provided you with information on the market capitalization of each of the ADRs, and as
               you will recall, each such ADR has significant market capitalization, as well as trading volume. Each ADR is traded in
               the United States based on quotes  in the OTC markets that are provided by broker-dealers pursuant to Rule 15c2-11. Rule
               15c2-11 generally prohibits a broker-dealer from publishing (or submitting for publication) a quotation for a covered
               OTC security in a quotation medium unless it has obtained and reviewed current information about the issuer. The broker-dealer
               must also have a reasonable basis for believing that the issuer (i.e., the company the securities of which are
               deposited with a depositary bank when an ADR is issued) information, when considered along with any supplemental information,
               is accurate and is from a reliable source. One of the specified types of information satisfying this Rule 15c2-11 obligation
               is information required by Rule 12g3-2(b). A broker-dealer must make this information reasonably available upon request
               to any person expressing an interest in a proposed transaction involving the security with the broker-dealer.

  Under
Rule 12g3-2(b), a foreign private issuer is provided an automatic exemption from registration under Section 12(g) of the Exchange Act
if it meets the following three conditions:

1. The foreign private issuer is not required to file
reports under Exchange Act Sections 13(a) or 15(d) (such obligations arising generally as a result of a public offering of securities,
a listing on a national securities exchange, or voluntary registration under the Exchange Act);

2. The foreign private issuer maintains a listing
of the subject class of securities on one or two exchanges in a non-U.S. jurisdiction(s) that comprise more than 55% of its worldwide
trading volume (its “Primary Trading Market”); and

3. The foreign private issuer publishes in English
on its website (or through an electronic information delivery system generally available to the public in its Primary Trading Market)
material items of information that:

 a. It has made public or been required to make public
pursuant to the laws of the country of its incorporation, organization or domicile;

 b. It has filed or been required to file with the
principal stock exchange in its Primary Trading Market on which its securities are traded and which has been made public by that exchange;
or

 c. It has distributed or been required to distribute
to its security holders.

         3

    Ms. Allison White

U.S. Securities and Exchange Commission

February 14, 2025

  The
exemption provided by Rule 12g3-2(b) is self-executing; it does not require foreign private issuers to make a formal application to the
Commission for the exemption or submit materials to the Commission to maintain the exemption. To establish the exemption initially, the
foreign private issuer must have published electronically in English its non-U.S. disclosure documents published since the first day of
its most recently completed fiscal year. To maintain the exemption, the foreign private issuer’s non-U.S. disclosure documents must,
on an on-going basis, be electronically published in English on its website promptly.

  ADRs
are issued by a depositary bank in the United States and represent the deposit of the foreign company’s shares in a custodian bank,
usually in the foreign company’s home jurisdiction. Pursuant to the terms of the underlying deposit agreement, ADR holders may exchange
ADRs for the representative number of shares in the foreign company. Conversely, those holding shares in the underlying foreign company
may deposit such shares in exchange for ADRs. ADRs may be “sponsored” or “unsponsored.” Sponsored ADRs are those
in which the foreign private issuer enters into an agreement directly with the U.S. depositary bank to arrange for record keeping, the
forwarding of shareholder communications, the payment of dividends, and other services as described above. An unsponsored facility is
set up without the cooperation of the foreign private issuer and may be initiated by a broker-dealer wishing to establish a trading market.

  The
filing of Securities Act Form F-6 is required to establish an ADR facility. The eligibility criteria for the use of Form F-6 include the
requirement that the issuer of the deposited securities have a reporting obligation under Exchange Act Section 13(a) or have established
the exemption under Rule 12g3-2(b). While required to be registered on Form F-6 under the Securities Act, ADRs are exempt from registration
under Exchange Act Section 12(g) pursuant to current Exchange Act Rule 12g3-2(c).

  The Commission adopted amendments to Rule 12g3-2 and Form F-6 in 20081to
  facilitate access to and trading in securities of foreign issuers in the form of ADRs. These amendments were adopted in light of developments
  that included the increased globalization of securities markets, advances in information technology, and the increased use of ADR facilities
  by foreign companies to trade their securities in the United States. As a result, the number of foreign companies engaged in cross-border
  activities multiplied, and the amount of U.S. investor interest in the securities of foreign companies increased. We note that since
  2008 these developments have only been amplified, especially with respect to advances in information technology. One of the policy
  objectives of these amendments was to “make it easier for U.S. investors to gain access to a foreign private issuer’s material
  non-United States disclosure documents and thereby to make better informed decisions regarding whether to invest in that issuer’s
  equity securities through the over-the-counter market (emphasis added) in the United States or otherwise.”2
  These amendments were also
  adopted to make it easier for broker-dealers to satisfy their requirements under Rule 15c2-11.

  1.
  SEC Release No. 34-58465 (September 5, 2008 (Adopting Release)

         4

    Ms. Allison White

U.S. Securities and Exchange Commission

February 14, 2025

  In
the numerous discussions we have had with members of the Staff, the only objection that we have been able to discern to the Trust allowing
the PEA No. 175 to go effective is the apparent concern of the Staff about the availability of information regarding the ADRs that will
be held by the Funds. Although it is not abundantly clear, in our discussions, we believe the Staff has made distinctions between “sponsored”
and “unsponsored” ADRs, and we are the view that the Staff may (emphasis added) believe that sponsored ADRs may have
more reliable or more available information for investors to access. We also believe that the Staff has expressed a concern about the
fact that the ADRs trade in the OTC markets, although we are not clear of the reasons for this concern. Notwithstanding our many discussions
with the Staff, we remain unclear as to the specific objection that the Staff has with PEA No. 175. We firmly believe that the Commission
was abundantly clear in the Adopting Release for the amendments to Rule 12g3-2 and Form F-6 that ADRs may be sponsored or unsponsored
and still satisfy the policy objectives of those amendments. Of particular note, the Commission stated in the Adopting Release that in
the case of an unsponsored ADR facility, a Form F-6 filer (i.e., an ADR registrant) may base its representation that the issuer
publishes information in English required to maintain the exemption from registration under Exchange Act Rule 12g3-2(b) upon the filer’s
reasonable, good faith belief after exercising reasonable diligence.

  The
amendments to Rule 12g3-2 and Form F-6 in the Adopting Release make it very clear that whether an ADR is sponsored or unsponsored OR whether
the ADR trades on an exchange or in the OTC markets are not relevant factors as to the determinatio