SecProbe.io

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DWS Investment Management Americas, Inc.

100 Summer Street

Boston, MA 02110

January 18, 2024

VIA EDGAR

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Rebecca Ament Marquigny

    Re:
    Post-Effective Amendment No. 501 to the Registration Statement on Form N-1A of Xtrackers RREEF Global Natural Resources ETF (the “Fund”), a series of DBX ETF Trust (the “Trust”) (Reg. Nos. 333-170122; 811-22487)

Dear Ms. Marquigny,

This letter is submitted on behalf of the Fund in
response to comments of the Staff of the Securities and Exchange Commission (“SEC”) regarding the above-referenced Post-Effective
Amendment (“Amendment”), which comments were received via telephone on January 4, 2024. The Amendment was filed on behalf
of the Fund on November 7, 2023 with an effective date of January 23, 2024. On January 12, 2024, a subsequent amendment to the Fund’s
Registration Statement was filed pursuant to Rule 485(b)(1)(iii) delaying the effectiveness of the Amendment to January 25, 2024.

The Staff’s comments are restated below, followed
by the Fund’s responses.

General
Comments

 1. Comment: Unless otherwise stated, comments to one part of the Amendment apply throughout the document.

Response: The Fund acknowledges
this comment and has made changes throughout the document as applicable.

 2. Comment: The Staff requests that any revised disclosure be included in correspondence filed with
the Staff and if corresponding changes are not made throughout the Fund’s Registration Statement when a comment contemplates as
such, the Fund will explain why such comment was not incorporated throughout.

Response: The Fund confirms it will
include any revised disclosure in correspondence filed with the Staff and will explain if corresponding changes are not made throughout
the Fund’s Registration Statement when a comment contemplates as such. For the Staff’s reference, clean and marked copies
of revised versions of the Fund’s Prospectus and Part I Statement of Additional Information (“SAI”) are included as
Attachment B to this letter. The marked copies of the Prospectus and Part I SAI show changes from the Amendment, including changes made
in response to Staff comments.

 3. Comment: With respect to any pages of the Fund’s Prospectus that omitted data in the Amendment,
please provide the Staff updated pages that include the missing data.

Response: All completed Prospectus
pages are included in Attachment B. The Fund’s standard creation and redemption transaction fee will be included in the Fund’s
485(b) filing.

 4. Comment: When available, please update the Fund’s Prospectus and SAI cover pages with the
Fund’s ticker symbol and listing exchange.

Response: The Trust hereby confirms
that the Fund’s ticker symbol and listing exchange will be disclosed on the Fund’s Prospectus and SAI cover pages concurrently
with the Fund’s 485(b) filing.

Prospectus
Comments

 5. Comment: Please include a completed fee table and expense example for the Fund prior to the Amendment’s
effective date of January 25, 2024.

Response: The completed fee table
and expense example for the Fund are included in Attachment A to this letter.

 6. Comment: Supplementally, please explain how the Fund’s estimated “Other Expenses”
were determined for the Fund’s fee table. Please also confirm that the Fund does not expect fees and expenses incurred as a result
of any investments made by the Fund in “Acquired Funds” (as said term is defined in Item 3(f)(i) of Form N-1A) during its
first fiscal year to exceed 0.01% of the Fund’s average net assets.

Response: Substantially all of the
expenses of the Fund are paid from the unitary advisory fee received by the Fund’s investment advisor from the Fund. Only interest
expense, acquired fund fees and expenses, taxes, brokerage expenses, distribution fees or expenses (if any), litigation expenses and other
extraordinary expenses are not covered by the unitary advisory fee. The Fund does not currently expect to incur “Other Expenses”
that are not included in the Fund’s unitary advisory fee. Accordingly, the Fund does not expect fees and expenses incurred as a
result of any investments made by the Fund in Acquired Funds during its first fiscal year to exceed 0.01% of the Fund’s average
net assets.

 7. Comment: Please move the last sentence of the first paragraph of “Portfolio Turnover”
to the “Principal Investment Strategies” section of the Prospectus.

Response: The above-referenced sentence
has been deleted from “Portfolio Turnover” and relocated to “Active ETF Management Risk” under “Main Risks.”
See Attachment B.

 8. Comment: Under “Main Investments” in the “Principal Investment Strategies”
section of the Fund’s Prospectus, please clarify how the Fund determines when a company’s exposure to natural resources is
sufficient to satisfy its 80% investment policy. In addition, please clarify what is meant by the phrase “and companies that
provide related services” as it appears in the sentence “For purposes of the fund’s 80% investment policy,
the natural resources sector includes companies that own, produce, refine, process, transport and market natural resources and companies
that provide related services.”

Response:  The Fund’s Prospectus
disclosure has been revised to clarify how the Fund determines when a company’s exposure to natural resources is sufficient to satisfy
its 80% investment policy. Specifically, the previously disclosed standard, including the reference to “companies that provide related
services,” has been replaced with following standard: “For purposes of the fund’s 80%

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investment
policy, the natural resources sector includes companies belonging to one of the following Global Industry Classification Standard®
(“GICS”) categories: (i) Agriculture: Agricultural Products & Services, Fertilizers & Agricultural Chemicals, Forest
Products, Paper & Plastic Packaging Products & Materials, Paper Products and Timber REITs; (ii) Oil and Gas: Integrated Oil &
Gas, Oil & Gas Drilling, Oil & Gas Exploration & Production, Oil & Gas Refining & Marketing and Oil & Gas Equipment
& Services; (iii) Coal: Coal & Consumable Fuels; (iv) Industrial Metals: Aluminum, Diversified Metals & Mining, Steel and
Copper; and (v) Precious Metals: Gold, Precious Metals & Minerals and Silver.”
See also Attachment B.

 9. Comment: The last sentence of the first paragraph under “Main Investments” in the “Principal
Investment Strategies” section of the Fund’s Prospectus states: “In addition to its investments in the natural resources
sector, the fund may also invest up to 20% of its net assets in equity or debt securities of any type of issuer.” Given the
broad nature of this disclosure, please clarify how the Fund will invest the remaining 20% of its assets to achieve its investment objective.

Response:  The foregoing sentence
has been deleted and the following disclosure added under “Main Investments” in the “Principal Investment Strategies”
section of the Fund’s Prospectus: “In addition, under normal circumstances, the Fund may invest up to 20% of its assets
in the following: (i) securities of issuers not included in the above-listed GICS natural resources categories that are, in the judgment
of portfolio management, otherwise connected to the natural resources sector; (ii) debt securities, including below-investment grade debt
securities, whether or not issued by companies in the natural resources sector; (iii) short-term investments for liquidity purposes, including
cash and cash equivalents, repurchase agreements and/or money market funds, including money market funds advised by the fund’s advisor
or its affiliates; or (iv) affiliated and unaffiliated exchange-traded funds (ETFs). The fund may invest in ETFs to gain exposure to certain
commodities or niche natural resources markets or to equitize portfolio cash positions.” See also Attachment B.

 10. Comment: Please delete the phrase “and may concentrate in one or more industries in
the natural resources sector” as is appears in the second paragraph under “Main Investments” in the “Principal
Investment Strategies” section of the Fund’s Prospectus, which paragraph states: “The fund will concentrate its investments
(i.e., hold 25% or more of its total assets) in the group of industries constituting the natural resources sector and may concentrate
in one or more industries in the natural resources sector.”

Response:  The Fund’s Prospectus
and corresponding SAI disclosure has been revised to delete the phrase “and may concentrate in one or more industries in the
natural resources sector.” See Attachment B.

 11. Comment: If the Fund will invest in unsponsored depositary receipts, consider including additional
risk disclosure with respect to such investments.

Response: Upon further consideration
of its anticipated investments in depositary receipts, the Fund does not believe any additional risk disclosure on this topic is warranted.

 12. Comment: The second sentence of the fourth paragraph under “Main Investments” in the
“Principal Investment Strategies” section of the Fund’s Prospectus states: “While it normally invests primarily
in equity and equity-related securities, the fund may also invest in fixed-income securities.” If fixed-income securities are
intended be part of the Fund’s principal investment strategies, please state that the Fund will invest in fixed-income securities
and describe in more detail the types of fixed-income securities in which the Fund will invest. If fixed-income securities are not intended
to be part of the

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Fund’s
principal investment strategies, please delete the reference to fixed-income securities in this section.

Response: See Response No. 9 above.
The Fund believes the revised disclosure provides a sufficient and accurate description of its intended use of debt securities, including
the overall limit applicable to such investments, and respectfully declines to modify it further. See also Attachment B.

 13. Comment: The last sentence of the fourth paragraph under “Main Investments” in the
“Principal Investment Strategies” section of the Fund’s Prospectus states: “In addition, the fund may invest,
on a limited basis in affiliated and unaffiliated exchange-traded funds (ETFs).” Please describe the criteria to be used when
selecting ETFs as well as any relevant limitations on the use of ETFs. How are ETFs intended to be used in furtherance of the Fund’s
investment strategy?

Response: See Response No. 9 above.
The Fund believes the revised disclosure provides a sufficient and accurate description of its intended use of ETFs, including the overall
limit applicable to such investments, and respectfully declines to modify it further. See also Attachment B.

 14. Comment: The fifth paragraph under “Main Investments” in the “Principal Investment
Strategies” section of the Fund’s Prospectus states: “The fund allocates its assets among various regions and countries,
including emerging market countries, and normally invests a majority of its assets in issuers that are organized or located outside the
US or that do a substantial amount of business outside the US.” Please clarify how the Fund intends to geographically allocate
its assets when pursuing its natural resources investment strategy.

Response: When making natural resources
investments, the Fund does not intend to focus on any particular geographic region or regions. Accordingly, the Fund believes the foregoing
disclosure sufficiently describes its investment approach with respect to geographical allocation and respectfully declines to make further
modifications.

 15. Comment: Under “Management Process” in the “Principal Investment Strategies”
section of the Fund’s Prospectus, please further clarify the parameters of the Fund’s allocation process. Consider an introductory
sentence that explains the basic criteria for how assets are allocated across various categories, such as region, market capitalization,
instrument type, etc.

Response: Portfolio management believes
the Fund’s Prospectus sufficiently and accurately describes its process for selecting Fund investments. Accordingly, except for
the Prospectus modification described in Response No. 16 below, the Fund respectfully declines to further modify this section.

 16. Comment: Please clarify what is meant by the phrase “natural resources market dynamics”
as it appears in the second sentence of the “Top-down Research” paragraph under “Management Process” in the “Principal
Investment Strategies” section of the Fund’s Prospectus, which sentence states: “First, RREEF portfolio management
utilizes top-down research analysis to determine allocation weights across market segments and regions. RREEF portfolio management analyzes
various factors, including natural resources market dynamics (such as supply/demand conditions), the economic environment (such
as interest rates, inflation and economic growth), expected capital flow dynamics and exchange rate conditions.” Consider disclosing
other examples of “natural resources market dynamics” in addition to “supply/demand conditions.”

Response: Portfolio management believes
the phrase “natural resources market dynamics” does not require additional general clarification. However, in the interest
of further illustrating this concept, additional examples of natural resources market dynamics have been included in the Prospectus. In

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addition,
the Fund has clarified the term “resource nationalism,” which term appears in the same sentence. See Attachment B.

 17. Comment: In the “Bottom-Up Research” paragraph under “Management Process”
in the “Principal Investment Strategies” section of the Fund’s Prospectus, please clarify the types of ESG factors that
portfolio management considers in connection with its selection of natural resources securities.

Response: The Fund’s Prospectus
disclosure has been revised to include the following disclosure enumerating examples of ESG factors typically considered by portfolio
management: “Examples of ESG factors typically considered by RREEF portfolio management include carbon emissions, water usage
and tailings/waste disposal (environmental); operational safety, Indigenous peoples/community relations, supply chain incidents and labor
rights (social); and ESG-linked compensation, independence of board membership and leadership, controlling shareholders, board diversity
and staggering of board membership (governance).” See also Attachment B.

 18. Comment: Please clarify what is meant by the phrase “considers the global natural resources
markets” as it appears in the last sentence of the “Bottom-Up Research” paragraph under “Management Process”
in the “Principal Investment Strategies” section of the Fund’s Prospectus, which sentence states: “Lastly,
RREEF portfolio management considers the global natural resources markets in general when making investment decisions.”

Response: The foregoing sentence
has been revised to read as follows: “Lastly, RREEF portfolio management considers the relationships between various segments
of the global natural resources markets when making investment decisions.” See also Attachment B.

 19. Comment: Please clarify the last sentence under “Derivatives” in the “Principal
Investment Strategies” section of the Fund’s Prospectus, which sentence states: “In particular, portfolio management
may use futures contracts, stock index futures, options on futures, swap contracts and other types of derivatives in seeking performance
and will not use such instruments for speculative purposes.” In addition, further clarify which derivatives the Fund will use
for what purposes as well as the criteria portfolio management will apply when investing in derivatives.

Response: In response to the foregoing
comments, the disclosure under “Derivatives” in the “Principal Investment Strategies” section of the Fund’s
Pros