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CORRESP
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CORRESP

 October 27, 2023

Via EDGAR Correspondence

 Ms. Samantha
Brutlag

 Division of Investment Management

 U.S. Securities
and Exchange Commission

 100 F Street, N.E.

 Washington, DC
20549-0505

 Re: JANUS DETROIT STREET TRUST (the “Registrant”)

Registration Statement on Form N-1A

1933 Act File No. 333-207814 (Post-Effective Amendment No. 51)

1940 Act File No. 811-23112 (Post-Effective Amendment No. 52)

Dear Ms. Brutlag:

 This letter responds to the comments to
Post-Effective Amendment No. 51 to the Registrant’s registration statement on Form N-1A (“PEA 51”) that were provided by teleconference on September 28, 2023 by the staff of the
Securities and Exchange Commission (the “Staff”) with respect to Janus Henderson Securitized Income ETF (the “Fund”). The Staff’s comments, as we understand them, and the Registrant’s responses are below. Unless
otherwise defined herein, capitalized terms have the meaning as prescribed in PEA 51.

1.
 Staff Comment: Please supplementally provide the Staff with the Fund’s ticker symbol, Annual
Fund Operating Expenses table, and expense example at least one week in advance of the effective date.

 
 Response: Registrant confirms that the Fund’s ticker is JSI.

Please see below for the Fund’s “Annual Fund Operating Expenses” table and “Example”:

 ANNUAL FUND OPERATING EXPENSES

(expenses that you pay each year as a percentage of the value of your investment)

 Management Fees

0.49
%

 Other Expenses(1)

0.00
%

 Acquired Fund Fees and Expenses(2)

0.04
%

 Total Annual Fund Operating Expenses

0.53
%

 Fee Waiver(3)

0.03
%

 Total Annual Fund Operating Expenses After Fee Waiver(3)

0.50
%

(1)
 Other Expenses are based on the estimated expenses that the Fund expects to incur during the current fiscal
year.

(2)
 Acquired Fund Fees and Expenses are indirect fees and expenses that the Fund incurs from investing in other
investment companies. These expenses are based on the total expense ratio of the underlying fund disclosed in such underlying fund’s most recent shareholder report. Acquired Fund Fees and Expenses are estimated for the current fiscal year.

(3)
 The Adviser has contractually agreed to waive and/or reimburse a portion of the Fund’s management fee in
an amount equal to the management fee it earns as an investment adviser to any affiliated exchange-traded funds (“ETFs”) with respect to the Fund’s investment in such affiliated ETF, less certain operating expenses. The fee waiver
agreement will remain in effect at least through February 28, 2025. The fee waiver agreement may be modified or terminated prior to this date only at the discretion of the Board of Trustees.

 EXAMPLE:

The Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other funds. The Example assumes
that you invest $10,000 in the Fund for the time periods indicated and then sell all of your shares at the end of those periods. The Example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses are
equal to the Total Annual Fund Operating Expenses After Fee Waiver for the first year and the Total Annual Fund Operating Expenses thereafter. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

1 Year

3 Years

$51

$
167  

2.
 Staff Comment: Under “Management,” please include the month and year that each
portfolio manager has managed the Fund.

 
 Response: As requested, the Registrant has revised the disclosure to state the following
(additional language shown in italics for comparison purposes):

 
 Nick Childs, CFA, is Co-Portfolio Manager of the Fund, which he
has co-managed since inception in November 2023. John Kerschner, CFA, is Co-Portfolio Manager of the Fund, which he has
co-managed since inception in November 2023.

3.
 Staff Comment: Under “Additional Information About the Fund,” the last bullet point
under the sub-header “Fees and Expenses” states that “Other Expenses” include “Acquired Fund Fees and Expenses.” Please confirm accuracy or revise accordingly given the
“Acquired Fund Fees and Expenses” is a separate line item in the Annual Fund Operating Expenses table.

 
 Response: The Registrant has revised the disclosure under “Additional Information About the
Fund” to distinguish and separate information regarding “Other Expenses” from information regarding “Acquired Fund Fees and Expenses” as follows:

•

 “Other Expenses” may include brokerage expenses or commissions, interest, dividends, taxes, litigation
expenses, and expenses and other extraordinary expenses not incurred in the ordinary course of the Fund’s business.”

•

 “Acquired Fund Fees and Expenses” are indirect expenses the Fund may incur as a result of investing in
shares of an underlying fund. “Acquired Fund” refers to any underlying fund (including, but not limited to, business development companies (“BDCs”) and exchange-traded funds (“ETFs”)) in which the Fund invests or has
invested during the period.”

 *    *    *

 Please call me at (303) 336-7903 with any questions or comments.

 Respectfully,

 /s/ Cara B. Owen           

Cara B. Owen

Secretary

Enclosures (via EDGAR only)

 cc:

 Eric Purple, Esq.