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DWS Investment Management Americas, Inc.

100 Summer Street

Boston, MA 02110

July 17, 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. 508 to the Registration Statement on Form N-1A of Xtrackers US 0-1 Year Treasury 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 June 25, 2024. The Amendment was filed on behalf of
the Fund on May 10, 2024 with an effective date of July 24, 2024.

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

General
Comments

 1. 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, a marked copy of the revised
version of the Fund’s Prospectus is included as Attachment C to this letter. The marked copy of the Prospectus shows changes from
the Amendment, including changes made in response to Staff comments.

Prospectus
Comments

 1. Comment: Please disclose the Fund’s ticker symbol and listing exchange on the cover page
of its Prospectus.

Response: The cover page of the
Fund’s Prospectus has been revised to disclose its listing exchange (Cboe BZX Exchange, Inc.) and ticker symbol (TRSY).

 2. Comment: Supplementally, please provide the Staff a copy of the index methodology for the Fund’s
underlying index, the ICE U.S. Treasury Short Bond Index (the “Underlying Index”).

Response: A copy of the Underlying
Index’s methodology is included in this letter as Attachment A.

 3. Comment: As an attachment to your response letter, please include a completed fee table and expense
example for our review. We may have additional comments.

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

 4. Comment: Supplementally, please describe how you estimated “Other Expenses” and concluded
such estimate was reasonable. Also please confirm whether the Fund expects 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. If such fees and expenses are expected to exceed 0.01% of the Fund’s average net assets,
please include a corresponding separate line item in the fee table.

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.

 5. Comment: Under “Principal Investment Strategies,” you indicate that the Fund’s
Underlying Index (and consequently the Fund) is “designed to track the performance of certain U.S. Treasury securities that have
a remaining maturity between one month and one year.” Given this statement, please clarify supplementally whether the
Underlying Index also includes Treasury securities issued with maturities of less than or equal to one year. Please also
clarify how the inclusion of Treasury securities initially issued with maturities of more than one year but with remaining maturities
of less than one year impacts the Underlying Index’s performance.

Response: The Underlying Index includes
both U.S. Treasury bills issued with less than 1 year to maturity as well as U.S. Treasury notes and bonds issued with longer maturities
that have less than 1 year to maturity remaining. The inclusion of the latter type of Treasury securities is not expected to materially
affect the Underlying Index’s performance (as compared to a pure Treasury bill index).

 6. Comment: In the second paragraph under “Principal Investment Strategies,” please clarify
what is meant by the term “fixed coupon schedule.” In addition, in the same paragraph, please clarify what is meant
by the phrase “the amounts outstanding of qualified coupon securities are not reduced by any portions that have been stripped.”

Response: The Fund’s Prospectus
disclosure has been revised to address the Staff’s comments above. See Attachment C.

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 7. Comment: Referring to the statement “the Underlying Index also excludes government agency
debt issued with or without a US government guarantee and securities issued or marketed primarily to retail investors,” which
appears at the end of the second paragraph under “Principal Investment Strategies,” please explain why these security types
are excluded from the Underlying Index and clarify how the Underlying Index identifies for exclusion “securities issued or marketed
primarily to retail investors.” Moreover, given the various exclusions from the Underlying Index, please clarify in plain English
what the Underlying Index is intended to measure.

Response: The Fund’s Prospectus
disclosure has been revised to address the Staff’s comments above. See Attachment C.

 8. Comment: Please clarify what is meant by the statement “cash flows from bond payments
and redemptions are retained in the Underlying Index until the end of the month and then are removed as part of the rebalancing,”
which appears in the third paragraph under “Principal Investment Strategies.” Specifically, please clarify what is meant by
phrase “cash flows from bond payments and redemptions are … removed as part of the rebalancing.”  Are such cash
flows allocated to existing constituent security positions and/or used to purchase securities as part of the monthly rebalancing? Also,
if material, please disclose the percentage of the Underlying Index that typically remains in cash each month and the effect such cash
holdings may have on the Underlying Index’s performance.

Response: The Fund’s Prospectus
disclosure has been revised to address the Staff’s comments above. See Attachment C. Because the percentage of cash held in the
Underlying Index at the end of any given month typically averages only 0.02% of the Underlying Index, the Fund does not believe the percentage
is material enough to disclose in the Prospectus. However, the Fund has included Prospectus disclosure indicating that the Underlying
Index’s cash position does create a “slight drag on the Underlying Index’s performance.”

 9. Comment: Given that the Fund uses a representative sampling indexing strategy to track the Underlying
Index, please disclose the number of securities that the Fund will hold in its representative sample or identify a numerical range.

Response: Portfolio management’s
ongoing determinations as to what constitutes an accurate and effective representative sample of the Underlying Index depend on their
continuing assessments of a variety of factors and do not, at any given time, necessarily correlate to a simple percentage of the Underlying
Index’s constituent securities. Moreover, the amount of securities held in a representative sample can change over time while maintaining
(and often in order to maintain) the same result for investors (i.e., a close correlation between the return of the Fund’s portfolio
and that of the Underlying Index). Accordingly, we respectfully decline to include additional Prospectus disclosure that would describe
a typical representative sample in terms of the number or range of Underlying Index constituent securities held in the sample. We believe
such information is neither relevant nor useful to investors.

 10. Comment: Please clarify what is meant by the phrase “new issues must be auctioned on or
before the calendar month end rebalancing date in order to qualify for the coming month,” which appears in the

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fourth
paragraph from the end of the “Principal Investment Strategies” section. In addition, please explain why it matters to investors.

Response: The Fund’s Prospectus
disclosure has been revised to address the Staff’s comment above. See Attachment C. The Fund believes said disclosure provides helpful
information to investors regarding the Underlying Index’s rebalancing process.

 11. Comment: Please delete the second sentence of the last paragraph of the “Principal Investment
Strategies” section, which reads: “For additional details regarding the Underlying Index, including announcements and changes
to the Underlying Index methodology, please see ICE’s public indices website (the website does not form part of this prospectus).”

Response: The Fund’s Prospectus
disclosure has been revised to delete the foregoing sentence. See Attachment C.

 12. Comment: The last sentence under “Securities lending” states that in connection with
its securities loans, the Fund “receives liquid collateral in an amount that is based on the type and value of the securities
being lent, with riskier securities generally requiring higher levels of collateral.” Because the Underlying Index is
composed entirely of securities backed by the U.S. Government, please explain supplementally under what circumstances would the Fund lend
riskier securities requiring higher levels collateral?

Response: Given the low-risk nature
of the Fund’s investments, the disclosure “with riskier securities generally requiring higher levels of collateral”
has been deleted from the Fund’s prospectus. See Attachment C.

 13. Comment: Please consider streamlining the “Market disruption risk” disclosure
appearing in the summary section of the Fund’s Prospectus (Item 4) while preserving the full “Market disruption risk”
disclosure in the “Fund Details” section of the Fund’s Prospectus (Item 9).

Response: The Fund believes its
Item 4 Prospectus “Market disruption risk” disclosure is appropriate and respectfully declines to modify it at this time.

 14. Comment: Because the Fund invests only in U.S. government securities, please modify the “Geographic
focus risk” and “Issuer-specific risk” disclosures that appear in the “Main Risks” section of the Fund’s
Prospectus to clarify, respectively, the geographic and issuer risks specific to U.S government securities or, alternatively, delete these
risk disclosures.

Response: The risks specific to
the US Treasury securities in which the Fund invests are disclosed under “US Treasury obligations risk” in the “Main
Risks” section of the Fund’s Prospectus. The aforementioned “Geographic focus risk” and “Issuer-specific
risk” disclosures are intended to supplement the Fund’s “US Treasury obligations risk” disclosure. The Fund believes
that, when read in the context of the entire “Main Risks” section, the “Geographic focus risk” and “Issuer-specific
risk” disclosures provide helpful information to an investor. Accordingly, the Fund respectfully declines to modify or delete such
disclosures.

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 15. Comment: Referring to the “Tracking error risk” section in the “Main Risks”
section of the Fund’s Prospectus, please describe supplementally under what circumstances might the Fund’s return be expected
to deviate significantly from the return of the Underlying Index.

Response: The circumstances under
which tracking error risk could theoretically occur are spelled out in the aforementioned “Tracking effort risk” section of
the Fund’s Prospectus. We respectfully refer the Staff to said section in response to its comment above.

 16. Comment: Please confirm that all comments provided with respect to the summary section of the Fund’s
Prospectus (Item 4) have been applied to the “Fund Details” section of the Prospectus (Item 9), as appropriate.

Response: The Fund confirms that
all comments provided with respect to the summary section of the Fund’s Prospectus have been applied to the “Fund Details”
section of the Prospectus, as appropriate.

Part C Comments

 17. Comment: Please include the following disclosure as set forth in Rule 484(b)(3) of Regulation C
in Item 30 of Part C of the Fund’s Registration Statement or explain supplementally why it is not required:

“Insofar as indemnification for
liabilities arising under the Securities Act of 1933 (the “1933 Act”) may be permitted to directors, officers and controlling
persons of the Fund pursuant to the foregoing provisions, or otherwise, the Fund has been advised that in the opinion of the SEC such
indemnification is against public policy as expressed in the 1933 Act and is, therefore, unenforceable. In the event that a claim for
indemnification against such liabilities (other than the payment by the Fund of expenses incurred or paid by a director, officer or controlling
person of the Fund in the successful defense of any action, suit or proceeding) is asserted by such director, officer or controlling person
in connection with the securities being registered, the Fund will, unless in the opinion of its counsel the matter has been settled by
controlling precedent, submit to a court of appropriate jurisdiction the question whether such indemnification by it is against public
policy as expressed in the 1933 Act and will be governed by the final adjudication of such issue.”

Response: The Fund notes that pursuant
to Rule 484(a) of Regulation C, the above indemnification disclosure set forth in Rule 484(b)(3) is only required if “any acceleration
is requested of the effective date of the registration statement pursuant to Rule 461.” Because the Fund’s registration
statement will go effective automatically pursuant to Rule 485(a)(2) and the Fund, consequently, will not be requesting acceleration of
its Registration Statement pursuant to Rule 461, the Fund respectfully declines to include the indemnification disclosure set forth in
Rule 484(b)(3) in Item 30 of Part C of its Registration Statement.

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If you have any questions regarding any of the foregoing or require additional
information, please call me at (617) 295-3011 (email: jim.wall@dws.com).

Sincerely yours,

/s/James M. Wall

James M. Wall

Associate General Counsel

DWS Investment Management
Americas, Inc.

cc: 	Jeremy Senderowicz, Vedder Price P.C.

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Attachment A

Xtrackers US 0-1 Year Treasury ETF – Underlying
Index Methodology

ICE Data Indices - Rules & Methodology

ICE U.S. Treasury
Short Bond Index (IDCOTS)

ICE U.S. Treasury
Short Bond Index tracks the performance of short maturity US dollar denominated sovereign debt publicly issued by the US government in
its domestic market. Qualifying securities must have greater than one-month and less than or equal to one-year remaining term to final
maturity as of the rebalancing date, a fixed coupon schedule and an adjusted amount outstanding of at least $300 million. The amount outstanding
for all qualifying securities is adjusted to reduce by the amounts held by the Federal Reserve’s
SOMA account. Inflation-linked debt, original issue zero coupon securities and STRIPs are excluded from the Index; however,
the amounts outstanding of qualifying c