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  ROPES & GRAY LLP

191 NORTH WACKER DRIVE

32nd FLOOR

CHICAGO, ILLINOIS 60606-4302

WWW.ROPESGRAY.COM

February 6, 2024

Ms. Kim McManus

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. McManus:

I am writing to respond to the comments of the
Staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) received by
the Registrant 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 October 6, 2023 (the “PEA”)
for the purpose of adding Calamos Alternative Nasdaq & Bond ETF (originally named Calamos [ ] Synthetic Convertible ETF (the
 “Fund”), as a new series of the Registrant. Your original comments provided by telephone on November 7, 2023,
and your follow-up comments provided by telephone on February 5, 2024, are summarized below, and each such comment is 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 at least five business days in advance of effectiveness for the Staff’s 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
      0.77 %

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

    Other Expenses1
      0.00 %

    Acquired Fund Fees and Expenses2
      0.13 %

    Total Annual Fund Operating Expenses3
      0.90 %

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”), other investment companies, 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

    $
    92

    $
    287

Follow-up
Comment. Does the Fund intend to invest a significant percentage in 3(c)(1) or 3(c)(7) entities?

Response.
No, the Fund does not intend to invest a significant percentage in 3(c)(1) or 3(c)(7) entities.

 2. Comment. The Staff requests that the Registrant confirm that acquired fund fees and expenses
for the Fund are expected to be less than 0.01% and that is why a line item for “Acquired Fund Fees and Expenses” is not included
in the “Annual Portfolio Operating Expenses” table and if such expenses are expected to be greater than 0.01%, a line item
will be added to the table.

Response.
The Registrant has revised the “Annual Portfolio Operating Expenses” table to account for anticipated acquired fund fees and
expenses. See response to comment 1 above.

 3. Comment.  The prospectus states that under normal circumstances the Fund invests at least
80% of its net assets in a portfolio of synthetic convertible instruments. The Staff requests that the Registrant provide disclosure describing
the type of securities in which the Fund may invest with respect to the remaining 20% of its net assets. The Staff asks that the Registrant
ensure its strategies and risks are disclosed with specificity if the remaining 20% of net assets are invested in derivative instruments.

Response.
 Please note that the Fund name and the description of the 80% policy have been modified. The name of the Fund has changed to “Calamos
Alternative Nasdaq & Bond ETF”. The modified 80% policy now reads: “The Fund pursues its objective by investing,
under normal circumstances, at least 80%, but up to 100%, of its net assets (plus borrowings for investment purposes, if any) in a portfolio
of equity instruments (including options and equity ETFs) and fixed income instruments (including bonds and fixed income ETFs) intended
to deliver convertible security-like exposure to companies in the Nasdaq-100 Index.” The Registrant believes the changes are not
material.

In response to the Staff’s comment,
the securities included in the 80% policy are anticipated to constitute up to 100% of the Fund’s net assets. As of the date hereof,
the Registrant does not expect that the Fund will invest in any securities other than those described in the Fund’s 80% policy,
except that the Fund may have non-principal investments, as described in the section of the prospectus titled “Additional Information
About Investment Strategies and Related Risks” under the sub-heading “Non-Principal Investments”.

Follow-up
Comment. Please include disclosure indicating you will consider the investments of the underlying funds when determining
compliance with your names policy.

Response.
The Registrant will add the following disclosure to the Fund’s prospectus:

“The Fund will consider the investments
of underlying funds when determining compliance with its 80% policy.”

 4. Comment. The Staff believes that the “Synthetic Convertible” strategy suggests
an investment strategy consisting of (i) debt instrument exposure coupled with (ii) an investment in a convertible feature tied
to the same issuer as the debt instrument exposure. As described in the Principal Investment Strategies section, however, it appears to
the Staff that these two elements of the investment strategy may in fact not pertain to the same issuer. The Staff requests that the Registrant add disclosure to explain this in the prospectus.

Further, the Staff requests that the Registrant address what happens to the long portion of a derivative held by the Fund on an underlying
equity security. Does the Fund hold that equity? Does the Fund instead roll the long exposure forward and/or cash settle the position?

Response.
The Registrant notes that the change of the strategy description no longer refers directly to “Synthetic Convertible”,
but rather seeks to emphasize the combination of equity upside potential through equity options with a fixed income “base”
comprised of multiple fixed income securities. This combination in effect offers a broad-based convertible-like exposure that does not
tie the equity exposure obtained through an option to the same issuer as the debt instrument. As a result, the first part of the Staff’s
comment is no longer relevant.

With regard to the second part of the
comment, when the Fund is long a call option and has the option to buy the equity security upon expiration of the option, the Fund does
not expect to exercise the option to buy the equity security. Instead, if the option expires in-the-money, the Fund expects to receive
the cash and subsequently reinvest it. The Fund also may write/sell options in order to receive income and will reinvest the cash. Under
normal circumstances, the Fund will generally not hold equity or cash in large amounts, choosing instead to re-deploy excess cash into
its principal investment strategy.

The following disclosure will be added
to the Fund’s prospectus:

“Under normal circumstances, the
Fund will generally not hold equity or cash in large amounts, choosing instead to re-deploy excess cash into its principal investment
strategy.”

Follow-up
Comment. Please provide the full text of the Fund’s principal investment strategies and risks. Please also
clarify what you mean by “the largest” companies in the Nasdaq-100 Index. Will you have a market cap minimum?

Response.
The Registrant has removed reference to “the largest” companies and instead refers to “companies within the Nasdaq-100
Index®”. Included as Appendix A is the full text of the Fund’s principal investment strategies and risks.

 5. Comment. The Staff requests that the Registrant provide disclosure describing any investment
limits to which the Fund must adhere when investing in equity securities, for example limits related to geographic, market capitalization,
and/or industry concentrations.

Response.
 The Registrant notes that the SAI contains disclosure stating that the Fund may not:

“invest more than 25% of its assets
in securities of issuers in any one industry or group of industries. This restriction does not apply to obligations issued or guaranteed
by the U.S. government, its agencies or instrumentalities, or securities of other investment companies.”

In addition, the Registrant will add
the following disclosure to the prospectus:

“The Fund’s investments may be domiciled in any
country and held in U.S. dollar and non-U.S. dollar denominations. With respect to the equity options component of its strategy, the Fund
will not allocate more than 10% to a given name or issuer. Under normal circumstances, the Fund will seek to deliver convertible security-like
exposure to companies in the Nasdaq-100 Index.”

 6. Comment.  The Staff requests that the Registrant provide numerical disclosure over the optimal
number as well as the range of stocks in which the Fund is to invest, and whether that range contains a fixed minimum that is meant to
avoid an extreme concentration of investments.

Response.
 The Registrant seeks to maintain flexibility in lieu of a fixed range or minimum and, accordingly, respectfully declines the Staff’s
request to provide numerical disclosure. However, the Registrant notes the relevant disclosure makes it clear that the number of stocks
to be selected at any given time is based on a variety of factors:

“The equity exposure will be achieved
by purchasing the right to acquire an optimal number of stocks from the Nasdaq-100 Index based on a variety of factors including but not
limited to liquidity and market capitalization and purchasing the right to acquire the corresponding stocks. In addition, equity exposure
also may be achieved through investments in equity ETFs.”

 7. Comment.  The Staff requests that the Registrant provide disclosure regarding any investment
limits to which the Fund must adhere when investing in debt securities, for example limits with respect to maturity, duration, credit
quality, and geographic concentration.

Response.
 The Registrant notes existing disclosures explaining that there are no such limits:

“The fixed income instruments will
be selected based on credit quality, yield, duration, liquidity, and such other factors as deemed relevant by the Adviser. The fixed income
instruments are intended to serve as a base for the Fund’s portfolio by creating bond-like returns.”

And

“The Fund may invest in investment
grade debt securities (those rated BBB or higher by S&P, or Baa or higher by Moody’s), which include securities issued or guaranteed
by the U.S. government, its agencies and instrumentalities, as well as securities rated or subject to a guarantee that is rated within
the investment grade categories listed by at least one of the Nationally Recognized Statistical Rating Organizations (NRSROs), and in
below investment grade debt securities, which are sometimes referred to as high yield or “junk” bonds, which include bonds,
bank loans and preferred securities. Junk bonds are securities rated BB or lower by S&P, or Ba or lower by Moody’s or securities
that are not rated but are considered by the Fund’s investment adviser to be of similar quality. These debt securities may include
mortgage-backed, mortgage-related and other asset-backed securities, which directly or indirectly represent a participation in, or are
secured by and payable from, mortgage loans, real property, or other assets such as car loans or aviation financing.”

Follow-up
Comment. Please state that there are no limits with regard to maturity, duration, credit quality, or geographic
concentration.

Response.
The Registrant will add to the prospectus the following disclosure:

“The Fund’s investments in
debt securities will have no limits with regard to maturity, duration, credit quality, or geographic concentration.”

 8. Comment.  The Staff requests that the Registrant provide additional disclosure to clarify
the extent to which the Fund may invest in non-U.S. issuers.

Response.
 As stated in Registrant’s response to comment 5, Registrant will add the following disclosure:

“The Fund’s investments may
be domiciled in any country and held in U.S. dollar and non-U.S. dollar denominations.”

Follow-up
Comment. Please consider including a risk factor to address foreign investment risk.

Response.
The Registrant will add the following disclosure to the Fund’s principal risks:

“●    Foreign
Securities Risk — Risks associated with investing in foreign securities include fluctuations in the exchange rates of foreign
currencies that may affect the U.S. dollar value of a security, the possibility of substantial price volatility as a result of political
and economic instability in the foreign country, less public information about issuers of securities, different securities regulation,
different accounting, auditing and financial reporting standards and less liquidity than in U.S. markets.”

 9. 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.

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 ri