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Stone Ridge Trust

 ROPES & GRAY LLP

 PRUDENTIAL TOWER, 800 BOYLSTON STREET

 BOSTON, MA 02199-3600

WWW.ROPESGRAY.COM

December 2, 2024

       Andrew G. Lawson

      T +1 617 951 7149

      Andrew.Lawson@ropesgray.com

 VIA EDGAR

Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, D.C. 20549

Attention: Karen Rossotto

Re: Stone Ridge Trust (File No. 811-22761;
333-184477)

 Dear Ms. Rossotto:

On behalf of Stone Ridge Durable Income ETF (the “Fund”), a series of Stone Ridge Trust (the “Trust”), we
are writing to respond to comments of the staff (the “Staff”) of the Securities and Exchange Commission that you provided via phone on November 8, 2024 in connection with Post-Effective Amendment No. 93 to the Trust’s
Registration Statement on Form N-1A (the “Registration Statement”). The amendment was filed pursuant to Rule 485(a) under the Securities Act of 1933, as amended (“Securities Act”), on
September 25, 2024 to register for public offer and sale shares of the Fund, a new series of the Trust.

 The
following sets forth the Staff’s comments and the Fund’s responses thereto. We note that the responses set forth herein, as applicable, will be observed by the Fund but do not necessarily represent the position or policy of other funds
managed by Stone Ridge Asset Management LLC (“Stone Ridge” or the “Adviser”). The responses will be reflected, to the extent applicable, in the next amendment to the Fund’s Registration Statement. Terms used but not defined
herein are defined in the Registration Statement. Revisions to existing disclosure included below are reflected, as applicable, with the new text underlined in
blue and the deleted text shown in red
strikethrough.

 General Comments

1.
 Staff Comment: In correspondence, please explain why the Predecessor Fund is being reorganized with and into
the Fund and whether an N-14 will be filed in connection with the Reorganization.

Response: The Predecessor Fund is a prior iteration of the Trust’s longevity income series, similar to the
predecessor funds of the currently effective Longevity Income ETFs and Inflation-Protected

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Longevity Income ETFs (the “Existing ETFs”). The Predecessor Fund commenced operations in January 2024. The Fund is
an independent investment vehicle from the Existing ETFs. An N-14 will not be filed in connection with the Reorganization. Stone Ridge Ventures LLC is the sole shareholder of the Predecessor Fund and, in such
capacity, has approved the Agreement and Plan of Reorganization between the Predecessor Fund and the Fund.

 Summary
Prospectus

  Investment Objective

2.
 Staff Comment: We note that the Fund’s investment objective is “to provide reliable monthly
distributions consisting of income and principal.” The Staff also notes that the Fund’s name references “durable income.” The Staff’s view is that a distribution of “principal” is usually referred to as return of
capital. We are concerned that the inclusion of a term that in the Staff’s view connotes a return of capital in the Fund’s investment objective does not align with the use of the terms “durable” nor “income” in the
Fund’s name. In correspondence, explain why the Fund’s name is not materially misleading or revise the name or strategy in line with Rule 35d-1 under the Investment Company Act of 1940, as amended
(the “1940 Act”).

 Response: The Fund believes that the term “durable income”
as used in the Fund’s name should be commonly understood as a reference to an intended portfolio-wide result, similar to “real return,” “balanced” or “managed risk,” each of which the Staff noted in the adopting
release to the Rule 35d-1 amendments are “terms that do not communicate to investors the particular characteristics of investments that will make up the fund’s portfolio.” The Cambridge Advanced
Learner’s Dictionary & Thesaurus defines the word “durable” as “able to continue to exist for a long time.” This definition aptly describes the Fund’s monthly distributions, which include income, that are
designed to be generated in perpetuity and continuously recalibrated each year at a level that the Adviser believes would be sustainable for thirty years from such recalibration date. Further, a majority of the Fund’s monthly distributions are
expected to be composed of income rather than the return of principal.

 Additionally, the Fund notes that “return of
capital” is a tax characterization, not an investment objective, and that the “Tax Information” section of the Fund’s summary prospectus clearly discloses that “the Fund intends to make distributions for which a portion of
each distribution is expected and intended to constitute a return of capital, which will reduce the amount of capital available for investment and reduce a shareholder’s tax basis in his or her shares.” To address the Staff’s
concerns, however, the Fund has added disclosure in the “Tax Information” section of the Fund’s summary prospectus further explaining the concept of a “return of capital.”

The Fund does not expect to recognize capital gains on the distribution of its portfolio securities to
Authorized Participants in redemption of the Fund’s shares. The Fund intends to make distributions for which a portion of each distribution is expected and intended to constitute a return of capital, which. A return of capital is a distribution from the shareholder’s
investment principal, rather than net profits from the Fund’s returns, and should not be confused with the Fund’s “yield” or “income.” A return of capital will reduce
the amount of capital available for investment and reduce a shareholder’s tax basis in his or her shares. A return of

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capital is generally not taxable to the shareholder. However, if a shareholder’s tax basis in his or her
shares has been reduced to zero, the portion of the Fund’s distributions that exceeds such tax basis is expected to constitute capital gains. See “How to Purchase and Sell Fund Shares—Distributions and Federal Income Tax Matters”
for a discussion of the federal income tax treatment of a return of capital.

 The Fund believes that its name is
consistent with Section 35(d) of the 1940 Act and Rule 35d-1 thereunder; its disclosure regarding its investment objective and strategy is clear; and the term “durable income” in its name is not
inconsistent with reasonable investor expectations or its investment objective or strategy.

  Fees and Expenses

3.
 Staff Comment: If acquired fund fees and expenses as a result of investing in money market funds are
expected to exceed one basis point, please include in the Annual Fund Operating Expenses table.

Response: The Fund’s Acquired Fund Fees and Expenses are not expected to exceed one basis point.

4.
 Staff Comment: Footnote 1 to the fee table discloses that Management Fees are estimated for the
Fund’s current fiscal year. In correspondence, please explain why these fees are estimated.

Response: The Fund has revised its disclosure in response to this comment by removing the final sentence from footnote
1 to the fee table.

5.
 Staff Comment: Please disclose that Other Expenses are estimated for the fiscal year.

 Response: The Fund notes that footnote 2 to the fee table states that “Other Expenses have
been adjusted from amounts incurred during the period of LifeX Income Fund 1963M’s operations to reflect estimated current expenses.” (emphasis added).

 Principal Investment Strategies—The Investments

6.
 Staff Comment: Please revise the Fund’s strategy to address any criteria the Adviser considers
in deciding which U.S. Government Bonds to purchase.

 Response: The Fund has made the requested
change. The paragraph located at “Fund Summary—Principal Investment Strategies—The Investments” and “Investment Objectives, Strategies and Risks—More Information Regarding Investment Strategies—Investment
Strategies—The Investments” has been revised as follows:

 The Fund is an exchange-traded fund
(“ETF”) that pursues its investment objective by investing in debt securities issued by the U.S. Treasury (which we refer to as “U.S. Government Bonds”) as well as money market funds that invest exclusively in U.S. Government
Bonds or repurchase agreements collateralized by such securities. Securities issued by the U.S. Treasury historically have not had credit-related defaults (i.e., failures to fulfill payment-related obligations such as interest

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or principal payments) and therefore such securities are generally considered to be credit risk-free (i.e.,
free of the risk of non-payment of either interest or principal). When constructing its portfolio of U.S. Government Bonds, the Fund
seeks to select particular bond maturities and investment amounts that enable the Fund to “lock in” interest rates and reliably sustain its planned distributions and recalibration
strategy.

 Principal Investment Strategies—The
Offering

7.
 Staff Comment: In the second paragraph of this subsection, please address the following comments:

a.
 Please revise the disclosure to more clearly indicate the Fund’s process for recalibrating its per-share distribution rate annually and explain the reasoning for the annual recalibration.

Response: The Fund has made the requested change. The second paragraph of “Fund Summary—Principal Investment
Strategies—The Offering” and “Investment Objectives, Strategies and Risks—More Information Regarding Investment Strategies—Investment Strategies—The Offering” has been revised as follows:

In January of each year, the Fund’s per-share distribution rate
will be recalibrated based on current market interest rates to a level that the Adviser believes would be sustainable for thirty years from such recalibration date and
would, absent a subsequent recalibration, result in the distribution of the vast majority of the Fund’s assets over that a thirty-year time
horizon. The Fund will calibrate its distribution rate by calculating the payout rate of a 30-year Treasury bond ladder and
adjusting for the Fund’s Unified Management Fee. intends to operate indefinitely in this manner,
meaning that it will continue to recalibrate its per-share distribution rate annually based on successive thirty-year periods. The Fund is not actually designed to distribute all of its assets over thirty
years from its launch date, and its
per-share distribution rate is expected to decline over time.

The Fund is
designed purpose of including a portion of principal in the Fund’s distributions is to provide
investors with a higher level of cashflow than would be possible from distributing the Fund’s interest
income alone, while moderating the amount of principal distributed over time so that the Fund can continue to pay distributions in perpetuity.. The purpose of recalibrating the distribution rate annually is to enable the Fund to
operate and provide monthly distributions in perpetuity. As a result of returning principal and recalibrating annually, the Fund’s per-share distribution rate is expected to decline over time.

b.
 The Fund’s strategy states that “The Fund is not actually designed to distribute all of its assets
over thirty years from its launch date, and its per-share distribution rate is expected to decline over time. The Fund is designed to provide investors with a higher level of cashflow than would be
possible from interest income alone, while moderating the amount of principal distributed over time so that the Fund can continue to pay distributions in perpetuity.” (emphasis added). We are concerned that investors may not fully
understand

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 the extent and speed of the decline in per-share distributions, absent
additional disclosures about the assumptions you are using about the amount of capital you will return. Please revise the disclosure to more clearly explain how the Fund intends to operate indefinitely while the Fund’s return of capital and
distributions decline every year.

 Response: The Fund notes that the subsection
“—Principal Investment Strategies—Distributions” and the distribution table will illustrate to investors the expected extent and speed of the decline in per-share distributions on a
five-year look forward basis. Each year, as part of the Fund’s annual registration statement update, the Fund will update this table. Additionally, the Fund is an exchange-traded fund and therefore a shareholder will have a high degree of
transparency into the Fund’s NAV per share and will have daily liquidity in the event it decides that a lowered distribution rate is not attractive.

c.
 Please consider the need for additional Item 9 disclosure addressing why the
per-share distribution rate is expected to decline over time and what the trajectory of that decline might look like.

Response: The Fund has made the requested change regarding the decline in the
per-share distribution rate, as reflected in Comment Response 7(a) above. With respect to the trajectory of the decline in the per-share distribution rate, the Fund does
not believe additional disclosure is necessary given the distribution table will clearly show the expected extent and speed of the decline on a five-year look forward basis, which table will be updated at least annually.

 Principal Investment Strategies —Distributions

8.
 Staff Comment: We note that the figures provided in the Distributions table will be dependent on
economic and other factors. Please explain why the presentation of distributions in this table is not misleading.

Response: The Fund believes that the referenced table does not portray hypothetical fund performance and that an
investor would not be able to use the information in the table to derive expected returns from an investment in the Fund. An investor’s returns will be a function of the price the investor paid for shares, the monthly distributions as
recalibrated over time, and the price the investor receives when selling the shares. The table is intended to help investors understand the Fund’s annual recalibrations, which are simply an estimate of what the Fund will seek to distribute
based on current market interest rates. The Fund further notes that the table will be updated no less frequently than annually in connection with the Fund’s annual registration statement update. Additionally, the Distributions and Interest Rate
Risk disclosure states that “the Fund may ultimately recalibrate its distribution rate to be higher or lower than expected as a result of fluctuations in market interest rates.”

The second paragraph of “Fund Summary—Principal Investment Strategies—Distributions” and “Investment
Objectives, Strategies and Risks—More Information Regarding Investment Strategies—Investment Strategies—Distributions” has been revised as follows:

The following table illustrates the Fund’s intended distributions for each of the next five years for
an investor who purchases 100,000 shares, incorporating an estimate

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of the effect of its annual recalibrations, estimated based on current market interest rates as of October 31, 2024.

9.
 Staff Comment: We note that the Distributions table illustrates distributions for an investor who
purchases 100,000 shares. Please revise the disclosure to provide these distribution numbers on a per-share basis.

Response: The Fund respectfully declines to disclose distribution numbers on a
per-share basis. The Fund is not aware of any Form N-1A-related disclosure requirement requiring a lesser presentation and notes
that the 100,000 share basis is consistent with the disclosure of other series of Stone Ridge Trust. An investor can simply divide the estimated distribution amounts by 100,000 should they want this information on a
per-share basis. The Fund further notes that the text immediately preceding the Distributions table states that “[f]rom the date of its launch until the date of the first recalibration of its distributi