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 27, 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™ (each a “Fund” and collectively, 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” or “SEC”) that you provided to Practus, LLP on
February 25, 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”). 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 PEA No. 175.

1. Comment:	In the principal investment strategies disclosure
with respect to each Fund, please revise the disclosure to clarify that with respect to unsponsored ADRs, foreign issuers that are the
subject of such ADRs are generally not subject to U.S. reporting obligations and they are not required to make filings with the Commission.

  Response: The Trust has revised the disclosure in an attempt to address
               your comment.

2. Comment:	With respect to the description of the underlying issuer of each of the Funds
and the citation of the SEC website, consider revising the paragraph to reference the SEC website separately. In this regard, state that
the SEC's website has information about the unsponsored ADRs related to the underlying company; however, the SEC's website does not have
disclosure about the underlying company nor is such disclosure about the underlying company disclosed by such company.

  Response:	The Trust has revised the disclosure in an attempt to address
               your comment.

    Ms. Allison White

U.S. Securities and Exchange Commission

February 27, 2025

3. Comment:	The Staff notes that the disclosures
                             pertaining to Rule 15c2-11 for some of the Funds notes the applicability of Rule 12g3-2 while others do
                             not. Please revise the disclosure with respect to the Funds that have unsponsored ADRs to reflect that the
                             sponsor of such ADRs, based on its reasonable good faith belief after exercising reasonable diligence, has
                             represented that it believes the issuer of the securities underlying such unsponsored ADRs publishes the
                             information contemplated in Rule 12g3-2(b) on its internet website or through an electronic information
                             delivery system generally available to the public. Also consider disclosing in the Item 9 disclosure generally
                             the requirements of Rule 12g3-2.

  Response:	The Trust is declining, in part, to revise the disclosure in
               response to this comment. The ability of a broker-dealer to rely on an issuer’s compliance with Rule 12g3-2 is only
               applicable for sponsored ADRs. The Trust does not believe that references to the representations of the depositary of
               an unsponsored ADR made in Form F-6 adds any material information to the disclosure. The current disclosure already references
               sources of publicly available information about the underlying issuer. The Trust has added disclosure generally describing
               the requirements of Rule 12g3-2.

4. Comment:	With respect to the risk disclosure
                                    for unsponsored ADRs, please enhance the disclosure, particularly as it relates to the lack of control
                                    by the foreign company, limited information and regulatory risks. This disclosure should be tailored
                                    to the foreign issuer and the requirements of its home country (e.g., the frequency of filings relative
                                    to the United States). Also, given that the Funds will be sold to U.S. investors who invest in domestic
                                    companies in addition to ADRs, consider whether comparing the risk of unsponsored ADRs against those
                                    of sponsored ADRs is the correct comparison.

  Response:	The Trust is declining, in part, to revise the disclosure in
               response to this comment. The Trust believes that the risk of unsponsored ADRs is sufficiently, concisely and appropriately
               disclosed to investors. Notwithstanding, the Trust has revised the disclosure to make clear that the regulatory requirements
               applicable to a foreign issuer may be different than those of the United States, and as a result, the frequency and level
               of detail of disclosure about the operations of an issuer may be less than the requirements imposed on issuers whose securities
               are registered in the United States. The Trust also believes that comparing the risk of unsponsored ADRs against those
               of sponsored ADRs is the correct comparison in the context of the applicable disclosure provided, and as a result, it
               is not revising the disclosure to address this part of your comment. The Trust further notes that the risk disclosure
               that the Staff’s comment relates to is focused on the risks of unsponsored ADRs compared to sponsored ADRs, but
               this risk disclosure is one of many disclosures included in the prospectus regarding the risks of investing in ADRs, including
               market risk, foreign market risk, and risks of investing in the particular country of the underlying issuer, risks relating
               to the underlying issuer’s business, and risks relating to the underlying issuer’s industry.

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    Ms. Allison White

U.S. Securities and Exchange Commission

February 27, 2025

5. Comment:	The Staff notes that foreign
                                    companies are not required to provide the information required by Rule 12g3-2 and may cease doing
                                    so at any time. The Staff believes that this would, in turn, impact whether an ADR could be quoted
                                    in the over-the-counter markets. Please consider adding risk disclosure of this potentiality, and
                                    later in the prospectus (perhaps in the Funds’ item 9 disclosures) consider providing disclosure
                                    about how a Fund would handle situations where ADRs cannot be quoted in the over the counter markets
                                    or otherwise are not available.

  Response:	The Trust has revised the disclosure in an attempt to address
               your comment.

6. Comment:	The Staff notes that BMW’s
                                    ADR is not sponsored. Please add ADR unsponsored risk to this Fund’s disclosure.

  Response:	The Trust has revised the disclosure in an attempt to address
               your comment.

7. Comment:	Please add Nestle’s website
                             to the disclosure.

  Response:	The Trust has revised the disclosure in an attempt to address
               your comment.

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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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