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    ROPES & GRAY LLP

191 NORTH WACKER DRIVE

32nd FLOOR

CHICAGO, ILLINOIS 60606-4302

WWW.ROPESGRAY.COM

December 26, 2023

Ms. Valerie Lithotomos

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549-4720

    Re:
    Calamos ETF Trust (File Nos. 333-191151 and 811-22887) (the “Registrant”)

Dear Ms. Lithotomos:

I am writing to respond to the comments of the
staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) that you provided
by telephone on October 17, 2023 in connection with the registration statement on Form N-1A, filed with the Commission pursuant
to Rule 485(a) under the Securities Act of 1933, as amended (the “Securities Act”), on September 15,
2023 (the “PEA”) for the purpose of adding Calamos CEF Income & Arbitrage ETF (the “Fund”)
as a new series of the Registrant. Your comments are summarized below, followed by our responses. Capitalized terms not otherwise defined
herein have the meanings ascribed to them in the PEA. The Registrant intends to file a future post-effective amendment pursuant to Rule 485(b) under
the Securities Act to (i) reflect the revisions discussed herein in response to your comments; (ii) make certain non-material
changes as appropriate; and (iii) file exhibits to the registration statement.

 1. Comment. The Staff requests that the Fund’s completed Annual Fund Operating Expenses
table and example expenses be provided in advance of effectiveness to allow an adequate opportunity for the Staff to review.

Response.
 The Fund’s Annual Fund Operating Expenses table and example expenses have been revised as follows:

The following table describes the fees and expenses that you
may pay if you buy, hold and sell shares of the Fund (“Fund Shares”). Investors may pay other fees, such as brokerage
commissions and other fees to financial intermediaries, which are not reflected in the tables and examples below.

Annual Fund Operating
Expenses

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

    Management Fees
      0.74 %

    Distribution and/or Service Fees (12b-1)
      0.00 %

    Other Expenses1
      0.00 %

    Acquired Fund Fees and Expenses2
      2.00 %

    Total Annual Fund Operating Expenses3
      2.74 %

1
 “Other Expenses” is an estimate based on the expenses the Fund expects to incur for the current fiscal year.

2
 “Acquired Fund Fees and Expenses” include certain expenses incurred in connection with the Fund’s investment in various
closed-end funds, exchange-traded funds (“ETFs”), and business development companies (“BDCs”). The amount shown
is based on estimated amounts for the current fiscal year.

3
The Total Annual Fund Operating Expenses in this fee table may not correlate to the expense ratios in the Fund’s financial highlights
and financial statements because the financial highlights and financial statements reflect only the operating expenses of the Fund and
do not include Acquired Fund Fees and Expenses, which are fees and expenses incurred indirectly by the Fund through its investments in
certain underlying investment companies.

Example

This 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 or hold all of your Fund 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 remain the same. Although your actual costs may be higher or lower, based on these
assumptions your costs, whether you sell or hold your Fund Shares, would be:

    Year 1
    Year 3

    $ 277
    $ 850

 2. Comment.  Will the Fund’s
investment strategy consider activist shareholder targets or efforts? If so, please consider adding disclosure with respect to the same
to the Fund’s investment strategy and risk disclosure.

Response.
 As noted in the section of the Fund’s prospectus titled “Principal Investment Strategies,” the Fund’s investment
adviser will consider a variety of factors, including quantitative and fundamental analysis, event research, and trading opportunities,
to identify closed-end funds that are trading at a discount and represent an opportunity for the Fund to achieve its investment objective.
As part of this investment selection process, the Fund’s investment adviser may consider the activities of activist shareholders
with respect to potential investment targets; however, the Fund’s investment adviser does not anticipate that activist shareholder
activity will represent a significant factor in its typical security selection process. Therefore, the Registrant is of the view that
additional or revised disclosure is not needed.

 3. Comment.  Please supplementally
explain what is meant by “regularly” in the following sentence from the section of the Fund’s prospectus titled “Principal
Investment Strategies”: “The Adviser intends to rebalance the portfolio regularly to ensure that the desired asset allocations
are maintained.”

Response.
The Registrant notes that the term “regularly,” as used in this context, is synonymous with “often.” The Fund’s
investment adviser intends to rebalance the portfolio as it deems appropriate based on market conditions; it does not intend to rebalance
the portfolio on a time-based schedule or at pre-prescribed intervals of time.

 4. Comment.  Are there any
particular instruments that the Fund will use for arbitrage purposes?

Response.
The Registrant respectfully directs the Staff’s attention to disclosure in the section of the Fund’s prospectus titled
 “Principal Investment Strategies,” which discloses the instruments that the Fund may use to achieve its investment objective
through an arbitrage-based strategy:

“The Fund is an actively managed
exchange-traded fund (“ETF”) that seeks high current income and long-term capital appreciation by investing in unaffiliated
closed-end funds that the Fund’s investment adviser, Calamos Advisors LLC (“Calamos Advisors” or the “Adviser”),
believes offer both attractive income opportunities as well as arbitrage opportunities resulting from such closed-end funds trading at
attractive discounts (market prices that are less than the closed-end funds’ net asset value (“NAV”)). The Fund’s
strategy seeks to identify closed-end funds trading at attractive discounts and sell such funds when the arbitrage opportunity has either
been achieved by capturing the benefit of discount narrowing or when the Adviser determines the discount level no longer represents an
unusual divergence from the Fund’s underlying asset value. Under normal circumstances, the Fund seeks to achieve its investment
objectives by investing at least 80% of its net assets (plus borrowings for investment purposes, if any) in U.S. and non-U.S. closed-end
funds.…The Fund also may invest in ETFs and business development companies (“BDCs”)…”

“The
Fund may invest in rights or warrants of equity securities and closed-end funds. The Fund also may use derivative instruments such as
options, index futures, and forward contracts. The Fund may purchase or sell securities on a when-issued, delayed delivery or forward
commitment basis…In order to capture the relative arbitrage value embedded in the discount, the Fund may from time to time
take short positions that approximate the value of the underlying closed-end fund assets…”

 5. Comment.  The Staff requests that the Registrant order the Fund’s principal risks
to prioritize those that are most likely to adversely affect the Fund’s performance. The Staff notes that after listing the most
significant risks to each Fund, the remaining risks may be alphabetized.

Response. The
Registrant respectfully declines to make the Staff’s requested change at this time. The Registrant acknowledges that it is
aware of the non-binding guidance issued by the Division of Investment Management’s Disclosure Review and Accounting Office
titled “Improving Principal Risks Disclosure” https://www.sec.gov/investment/accounting-and-disclosure-information/principal-risks/adi-2019-08-improving-principal-risks-disclosure
 “ADI-2019-08”). While the Registrant respects the Staff’s view on principal risk disclosure, ADI-2019-08 states
clearly that the update is not a rule, regulation or statement of the Commission. Moreover, Form N-1A does not require that a
fund’s principal risks be set forth in any particular order. Further, the Registrant believes that ordering the principal
risks alphabetically makes it easier for an investor to find particular risk factors of the Fund. In addition, the materiality of
each risk is fluid, i.e., what is the most material risk today may not be the most material risk tomorrow. The market disruptions
and volatility as a result of the global COVID-19 pandemic demonstrate that it is not possible to anticipate which risk will present
the greatest risk to the Registrant at any given moment. Therefore, the Registrant believes that emphasizing one risk over another
in a static document in a non-static market would not be appropriate.

Notwithstanding the foregoing, the Registrant
notes the following disclosure is included at the beginning of the “Principal Risks” section in the statutory and summary
portions of the Fund’s prospectus to help investors better understand the importance of reading each risk disclosure regardless
of their sequence:

“The principal risks are presented
in alphabetical order to facilitate finding particular risks and comparing them with other funds. Each risk summarized below is considered
a “principal risk” of investing in the Fund, regardless of the order in which it appears.”

 6. Comment.  Please consider
including arbitrage risk as a principal risk for the Fund.

Response.
 The Registrant has added the following disclosure in the Fund’s prospectus relating to the principal investment risks associated
with an investment in the Fund:

·
Arbitrage Risk — The Fund’s use of an arbitrage strategy in order to take advantage of a perceived discount
presents certain risks. The shares of the underlying closed-end funds in which the Fund invests may trade at a discount or premium to
their NAV. Historically, shares of underlying funds have frequently traded at a discount to their NAV, which discounts have, on occasion,
been substantial and lasted for sustained periods of time. This characteristic is a risk separate and distinct from the risk that an
underlying fund’s NAV could decrease as a result of investment activities. Whether investors, such as the Fund, will realize gains
or losses upon the sale of shares will depend not on the underlying funds’ NAVs, but entirely upon whether the market price of
the underlying funds’ shares at the time of sale is above or below an investor’s purchase price for shares. Forecasting market
movements is difficult, and securities may be mispriced or improperly valued by the Adviser.

 7. Comment. Please consider including a cybersecurity risk as a principal risk for the Fund.

Response.
The Registrant respectfully declines to include cybersecurity risk as a principal risk for the Fund in the Fund’s summary prospectus
but notes the following text is included as a non-principal risk for the Fund in response to Item 9 of Form N-1A.

Cybersecurity
Risk. Investment companies, such as the Fund, and their service providers are exposed to operational and information security
risks resulting from cyberattacks, which may result in financial losses to the Fund and its shareholders. Cyber- attacks include, among
other behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on websites, “ransomware”
that renders systems inoperable until ransom is paid, the unauthorized release of confidential information, or various other forms of
cybersecurity breaches. Cyber-attacks affecting the Fund, Calamos Advisors, custodian, transfer agent, distributor, administrator, intermediaries,
trading counterparties, and other third-party service providers may adversely impact the Fund or the companies in which the Fund invests,
causing the Fund’s investments to lose value or to prevent a shareholder redemption or purchase from clearing in a timely manner.

 8. Comment. Please discuss how the Fund’s strategy will comply with Rule 22e-4.
Consider revising the strategy and risk disclosure in the Fund’s prospectus as appropriate to address the types of closed-end funds
and business development companies that may be in the Fund’s portfolio. For example, perhaps there will be a focus on listed closed-end
funds and business development companies and/or perhaps the Fund will invest in only a limited number of illiquid non-traded closed-end
funds and business development companies. To the extent there are investment limits with respect to illiquid closed-end funds and business
development companies, consider disclosing such limits in the prospectus.

Response.
The Registrant respectfully directs the Staff’s attention to the following disclosure in the Fund’s registration statement
relating to the Fund’s limited investment in illiquid securities and strategy to comply with Rule 22e-4.

In the sub-section of the Fund’s
prospectus titled “Illiquid Investments,” under the section titled “Non-Principal Investments”:

“The Fund may invest up to 15% of
its net assets in securities and other instruments that are, at the time of investment, illiquid (determined using the Securities and
Exchange Commission’s standard applicable to investment companies, i.e., any investment that the Fund reasonably expects cannot
be sold or disposed of in current market conditions in seven calendar days or less without the sale or disposition significantly changing
the market value of the investment).”

In the sections of the Fund’s
prospectus titled “Principal Risks”:

“Liquidity Risk. Liquidity
risk exists when particular investments are difficult to purchase or sell. The Fund’s investments in illiquid securities may reduce
the returns of the Fund because it may be unable to sell the illiquid securities at an advantageous time or price.”

In the sub-section of the Fund’s
Statement of Additional Information titled “Illiquid Securities,” under the section titled “Investment Practices”:

“The Fund may invest up to 15% of
its net assets under regulatory rules, taken at market value, in illiquid investments that are assets, including any securities that are
not readily marketable either because they are restricted securities or for other reasons. . . . The liquidity of an investment will be
determined based on relevant market, trading and investment specific considerations as set out in the Fund’s liquidity risk management
program (the “Liquidity Program”) as required by Rule 22e-4 under the 1940 Act (the “Liquidity Rule”). Illiquid
investments may trade at a discount to comparable, more liquid investments and the Fund may not be able to dispose of illiquid investments
in a timely fashion or at their expected prices. If illiquid investments exceed 15% of the Fund’s net assets, the Liquidity Rule and
the Liquidity Program will require that certain remedial actions be taken.”

In the section of the Fund’s Statement
of Additional Information titled “Investment Restrictions”:

“In addition to the fundamental
restrictions listed above, the Fund has adopted the following as non-fundamental policies . . . (e) [t]he Fund will invest no more
than 15% of its net assets in illiquid securities. Illiquid securities means any investment that the Fund reasonably expects cannot be
sold or disposed of in current market conditions in seven calendar days or less without the sale or disposition significantly changing
the market value of the investment.”

The Registrant believes the existing
disclosure adequately addresses the Fund’s strategy to comply with Rule 22e-4 and discloses the risks associated with