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DWS Investment Management Americas, Inc.

100 Summer Street

Boston, MA 02110

October 31, 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. 511 to the Registration Statement on Form N-1A of Xtrackers MSCI Emerging Markets ESG Leaders Equity ETF (to be renamed Xtrackers MSCI Emerging Markets Climate Selection 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 October 22, 2024. The Amendment was filed on behalf
of the Fund on September 6, 2024, with an effective date of November 5, 2024.

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

Prospectus
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, clean and marked copies
of a revised version of the Fund’s Prospectus are included as Attachment B to this letter. The marked copy of the Prospectus shows
changes from the Amendment, including changes made in response to Staff comments.

 2. Comment: With respect to the Fund’s proposed change in underlying index from the MSCI Emerging
Markets ESG Leaders Index (the “Old Underlying Index”) to the MSCI Global Climate 500 Emerging Markets Selection Index (the
“New Underlying Index”), please supplementally inform the Staff of any material changes in region, country, sector, investment
factors or issuers that are expected to result from the change in the Fund’s underlying index. If there are material changes, please
explain where and how the Fund’s disclosure has been revised to reflect such changes.

Response: The New Underlying Index
is more concentrated and contains fewer constituents than the Old Underlying Index. As of October 18, 2024, the New Underlying Index and
the Old Underlying Index contained 50 and 479 constituents, respectively. In addition, the New Underlying Index is invested in fewer countries
than the Old Underlying Index. As of October 18, 2024, the New Underlying Index and the Old Underlying Index were invested in 7 and 26
countries, respectively. That being said, the principal countries and sectors in which both indexes invest or may invest are similar.
As of October 18, 2024, both indexes were significantly invested China, Taiwan and India and the Financials, Information Technology, Consumer
Discretionary and Communication Services sectors. We also note that while different in certain respects, the ESG methodologies employed
by MSCI for the parent index of the New Underlying Index, the MSCI ACWI Select Climate 500 Index (the “Parent Index”), and
the Old Underlying Index share common elements. For example, both indexes screen for the same ESG problematic business activities and
ESG business controversies. The ESG methodology for the Parent Index differs notably from the methodology for the Old Underlying Index,
however, in that it also incorporates specific emissions intensity and reduction targets.

While the Fund believes that from a disclosure
perspective it would not be appropriate for the changed Fund to include general comparisons of its past and present investment strategies
and principal risks in its Prospectus, the Fund must accurately disclose its new investment strategies and attendant principal risks.
We believe that the Fund’s revised Prospectus accomplishes this goal. In our view, the Fund’s revised Prospectus accurately
discloses its new investment strategy and any new related principal risks (such as the Fund’s increased concentration and geographic
focus). We also note that the following paragraph, which appears towards the end of the “Principal Investment Strategies”
section of the Fund’s Prospectus, provides a recent, relatively detailed snapshot of the New Underlying Index and by inference the
changed Fund’s profile:

“As of October 18, 2024, the Underlying
Index consisted of 50 securities, with an average market capitalization of approximately $107 billion and a minimum market capitalization
of approximately $8.2 billion, from issuers in the following countries (as indicated by country of domicile): Brazil, China, India, Mexico,
South Africa, South Korea and Taiwan. As of October 18, 2024, a significant percentage of the Underlying Index was comprised of securities
of issuers from China, Taiwan and India. As of October 18, 2024, a significant percentage of the Underlying Index was comprised of issuers
in the financials, information technology and consumer discretionary sectors. The fund’s exposure to particular countries or sectors
may change over time to correspond to changes in the Underlying Index.”

 3. Comment: The Staff prefers that the Fund’s investment objective be stated as the Fund seeks
investment results that “track the performance” of the underlying index or seeks investment results that “correlate
to the performance” of the underlying index rather than its current formulation of the Fund seeks investment results that “correspond
generally to the performance” of the underlying index. Please make this change or supplementally explain why it would not be
accurate. In addition, please provide us a recent list of the New Underlying Index’s holdings and a copy of its methodology.

Response: The Fund’s investment
objective, which has already been approved by the Fund’s Board of Trustees, follows the same general formulation of the investment
objectives of the other Xtrackers ETFs. Accordingly, while we believe the alternative phrasings proposed by the SEC would be accurate,
we respectfully decline to revise the Fund’s investment objective as requested. A listing of the New Underlying Index’s holdings
as of October 18, 2024 is attached to this letter as Attachment C. In response to a request from the Staff, a copy of the New Underlying
Index’s methodology was previously provided to the Staff prior to the filing of this letter.

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 4. Comment: As an attachment to the EDGAR correspondence, please include a completed fee table and
expense example for our review. Supplementally, describe how you estimated “Other Expenses” and concluded it was a reasonable
estimate.

Response: The completed fee table
and expense example for the Fund are included in Attachment A to this letter. 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 expenses impacting the “Other Expenses”
line item of the fee table that are not included in the Fund’s unitary advisory fee.

 5. Comment: In the Staff’s view, the overall description of the New Underlying Index is too
detailed and difficult to follow. Please summarize the overall exposures of the New Underlying Index in Item 4 and provide more but clearer
disclosure about the New Underlying Index’s construction in Item 9.

Response: The Fund’s Prospectus
has been revised to address the Staff’s comment. See Attachment B.

 6. Comment: In the Staff’s view, the second paragraph of the “Principal Investment Strategy”
section, which utilizes references to “subsets,” is confusing and does not help investors understand what is in the New Underlying
Index. Please revise to clearly describe the investment exposure provided by the New Underlying Index; for example, what countries are
included and how are issuers selected for inclusion.

Response: The Fund’s Prospectus
has been revised to address the Staff’s comment. See Attachment B.

 7. Comment: Please clarify why Finland is excluded from the MSCI ACWI Ex Select Index. The Staff notes
that the Finland does not appear to be consistently defined as an excluded country in the Fund’s Prospectus. Please reconcile or
supplementally explain.

Response: MSCI specifically created
the MSCI ACWI Ex Select Index as a subset of the MSCI ACWI that excluded a short list of countries. One of the excluded countries was
Finland, which MSCI does not consider to be an emerging markets country. Since it is not considered to be an emerging markets country,
Finland is not relevant to the New Underlying Index or the Fund. Accordingly, all references to Finland have been deleted from the Fund’s
Prospectus.

 8. Comment: Under the “Overview of Parent Index Construction” sub-heading in the “Principal
Investment Strategies” section of the Fund’s Prospectus, please clarify how the Index Provider determines whether a company
is “in the business of” one of the five excluded groups (tobacco, controversial or nuclear weapons, thermal coal mining, thermal
coal-based power generation or fossil fuel power generation). In addition, please definitively name those categories that are categorically
excluded in lieu of providing examples. Lastly, please explain whether a company that is excluded through the application of the “ESG
business involvement screen” could somehow be included as an index constituent through the application of the “ESG business
controversy” screen.

Response: The Fund’s Prospectus
has been revised to address the first two of the Staff’s comments above. See Attachment B. With regard to the third comment, we
note that because the Parent Index’s ESG business involvement and business controversy screens work in tandem to exclude companies,
it is not possible for a company that is excluded by the ESG business involvement screen to be included in the Parent Index through a
subsequent application of the ESG business controversy screen.

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 9. Comment: The Staff notes that while the word “climate” appears in the Fund’s
name, the Parent Index’s ESG methodology covers all three ESG elements. Please clarify whether the use of the term climate in the
Fund’s name could affect the application of the Parent Index’s ESG business controversy screening. For example, with respect
to the Fund, could the application of the Parent Index’s ESG methodology result in the inclusion of companies that satisfy the methodology’s
environmental criteria but fail the methodology’s social and/or governance criteria? Please include in the “Principal Investment
Strategies” section of the Prospectus additional disclosure discussing the impact of non-climate related ESG issues on the Fund’s
potential investment universe.

Response: Based on input obtained
from MSCI, the Fund confirms that the use of the word “climate” in the Fund’s name does not affect the application of
the Parent Index’s ESG business controversy methodology with respect to the Fund. Companies that satisfy the methodology’s
environmental criteria but fail the methodology’s social and/or governance criteria would still be excluded from the Parent Index
and consequently the New Underlying Index and the Fund. The Fund believes that the current Prospectus disclosure regarding the operation
of the Parent Index’s ESG methodologies sufficiently describes the effect of non-climate related issues on the selection of constituent
securities. The Fund also believes that the changes made to Prospectus disclosure shown in Attachment B further clarify the application
of the ESG screens in the Parent Index.

 10. Comment: Please include additional context to help investors understand the Parent Index’s
current emissions intensity and emissions reduction targets. Please disclose the sources of information for the Index Provider’s
emissions intensity and reduction assessments. If it represents a material risk, please include additional risk disclosure addressing
the availability and reliability of such information.

Response: The Fund’s Prospectus
has been revised to address the first two of the Staff’s comments above. See Attachment B. With regard to the third comment, the
Fund does not believe additional risk disclosure is warranted.

 11. Comment: Please clarify what is meant by the phrase “designed to minimize the Parent Index’s
exposure to physical and transition risks of climate change,” which appears in the last sentence of the fourth paragraph under the
sub-heading “Overview of Parent Index Construction.” What does this phrase mean in practical terms? What is its import with
respect to portfolio construction?

Response: The Fund’s Prospectus
has been revised to delete the last sentence of the fourth paragraph under the sub-heading “Overview of Parent Index Construction.”
See Attachment B.

 12. Comment: In the description of the New Underlying Index as it appears under the sub-heading “Overview
of Underlying Index Construction,” please clarify whether the term “large and mid-cap representation” means large and
mid-cap relative to US companies or relative to companies located in emerging markets countries.

Response: MSCI has confirmed that
with respect to the New Underlying Index, the term “large and mid-cap representation” means relative only to companies located
in emerging markets countries. The Fund believes that the Prospectus disclosure is sufficiently clear on this point and respectfully declines
to modify it further.

 13. Comment: Please clarify in plain English what is meant by the sentence “[t]he weights are
then normalized to sum up to 100%,” which appears in the second paragraph under the sub-heading “Overview of Underlying Index
Construction.”

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Response: The Fund’s Prospectus
has been revised to address the Staff’s comment. See Attachment B.

 14. Comment: Please consider revising the Item 4 description of the “25/50 Methodology under
the sub-heading “Overview of Underlying Index Construction” to describe the practical impact of the methodology’s rebalancing
frequency on the Fund. Please also consider revising the description of the 25/50 Methodology to focus on the description’s second
paragraph and moving math specific details to Item 9.

Response: The Fund’s Prospectus
has been revised to simplify and condense the Item 4 description of the 25/50 Methodology. We note that the existing disclosure regarding
the rebalancing frequency of the 25/50 Methodology already states: “The MSCI 25/50 Methodology follows a quarterly rebalancing schedule.
Any changes resulting from a rebalancing are made as of the close of the last business day of each February, May, August and November
and would be reflected in the Underlying Index at that time.” For greater clarity, this disclosure is now also included in
the paragraph describing the New Underlying Index’s rebalancing frequency.

 15. Comment: The Staff notes that the Prospectus does not explicitly address whether the Fund’s
switch to the New Underlying Index will result in the Fund being more concentrated as compared to when the Fund tracked the Old Underlying
Index or whether the Fund’s more focused investing approach resulting from its switch to the New Underlying Index will affect its
performance. Please confirm that the Fund’s revised prospectus will address any material risks resulting from the Fund’s switch
to the New Underlying Index.

Response: With regard to the Staff’s
comment relating to disclosure on the Fund’