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    ROPES
 & GRAY LLP

        191
NORTH WACKER DRIVE

        32nd
FLOOR

        CHICAGO,
ILLINOIS 60606-4302

        WWW.ROPESGRAY.COM

April
22, 2024

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”) received by the Registrant in connection with post-effective amendment number 26 and post-effective
amendment number 27 to the registration statement on Form N-1A, each filed with the Commission pursuant to Rule 485(a) under the
Securities Act of 1933, as amended (the “Securities Act”), on February 13, 20241 (each, as applicable,
a “PEA”) for the purpose of adding Calamos S&P 500 Structured Alt Protection ETF – May, Calamos
S&P 500 Structured Alt Protection ETF – August, Calamos S&P 500 Structured Alt Protection ETF – November,
Calamos S&P 500 Structured Alt Protection ETF – February, Calamos Nasdaq 100 Structured Alt Protection ETF – June,
Calamos Nasdaq 100 Structured Alt Protection ETF – September, Calamos Nasdaq 100 Structured Alt Protection ETF – December,
and Calamos Nasdaq 100 Structured Alt Protection ETF – March, respectively, as new series (each referred to herein as
 “the Fund”) of the Registrant. Your comments provided via a videoconference call on April 2, 2024 and on April
15, 2024 are summarized below, and each comment is followed by our responses. Capitalized terms not otherwise defined herein have
the meanings ascribed to them in the applicable PEA. The Registrant intends to file a future post-effective amendment to each
of the PEAs 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 notes that an upfront fee would have to be high for the Fund to be profitable.
                                         Please explain supplementally how the Fund will work without charging a high upfront
                                         fee.

Response.
The Fund is an ETF and does not charge an upfront fee. The Fund carries a unitary fee, which is calculated, accrued and deducted
from the Fund’s NAV daily.

There
is no need for the Fund to charge an upfront fee for the Fund to be profitable. The Fund is constructed similar to other “defined”
or “target” outcome ETFs, in that it is constructed via a fully financed combination of exchange-listed FLexible EXchange
Options (“FLEX Options”).

As
an example, specifically with regard to the four Calamos S&P 500 Structured Alt Protection ETFs, these FLEX Options work together
to seek to provide investment results that, before taking fees and expenses into account, match the positive price return of the
SPDR® S&P 500® ETF Trust (“Underlying ETF”) up to a predetermined upside cap (the “Cap”),
while protecting against 100% of the Underlying ETF’s losses (before fees and expenses), over a period of approximately
one-year (the “Outcome Period”).

1
The PEA for the Funds, now named Calamos S&P 500 Structured Alt Protection ETF – May, Calamos S&P 500 Structured Alt Protection ETF – August, Calamos S&P 500 Structured Alt Protection ETF – November, and Calamos S&P 500 Structured Alt Protection ETF – February, was filed after hours on February 13, 2024, with a filing date of February 14, 2024.

    1

    underlying asset
    SPY

    spot price
      519.46

    expiry date
      4/3/2025

    seed money
      2,500,000

    Strike
    Price
    Qty
    Value
    Weight

    Long Call
      3.43
      510.92
      48.00
    $ 2,452,416
      98.10 %

    Long Put
      519.62
      23.49
      48.00
    $ 112,752
      4.51 %

    Short Call
      568.45
      18.22
      (48.00 )
    $ (87,456 )
      -3.50 %

    Option Legs Total

    $ 2,477,712
      99.11 %

    Cash

    $ 22,288
      0.89 %

    Total account value

    $ 2,500,000
      100.00 %

    gross
    net

    Cap rate
      9.38 %
      8.69 %

    Protection
      100.00 %
      99.31 %

These
contract positions are broken down below, using prices as of April 3, 2024, illustrating the potential for the Fund to be profitable
(i.e., the upside cap), and the potential for the Fund to provide capital protection (i.e., downside protection equal to 100%
of losses (before fees and expenses) of the Underlying ETF), over the Outcome Period.

In
the table above, gross cap rate is the maximum return that can be earned by the option package, illustrating the potential for
the Fund to be profitable. The calculation is: ((((Short Call Strike - Long Call Strike) * 100* Option Quantity) + Cash)/Seed
Money) - 1. The gross cap rate of 9.38% can be considered the rate of return gross of fees and expenses. In qualitative terms,
this rate of return consists of the following components:

 I. “Short
                                         Call Strike minus Long Call Strike” The difference in the strike prices is
                                         the profit per option pair.

 a. Intuitively,
                                         a higher strike price on the short call means the owner of the call is less likely to
                                         exercise it, and therefore that the Fund is more likely to keep the premium, thereby
                                         making the option more valuable to the Fund.

 i. If
                                         the underlying is trading at $519, a call option with a strike price of $700 is far less
                                         likely to be exercised than one with a strike price of $525.

 b. Similarly,
                                         a higher strike price on the long call means that, upon exercise, the Fund enjoys less
                                         profit from the exercise.

 i. If
                                         the underlying is trading at $519, a call option with a strike price of $3 is worth far
                                         more than a call option with a strike price $509 to the owner of the option.

 II. “(*
                                         100)” That difference in strike prices is then multiplied by 100, which is
                                         the number of shares of the underlying security. Options contracts usually represent
                                         100 shares of the underlying security. This difference in strike price multiplied by
                                         its lot size gives the value of each option contract.

    2

 III. “(*
                                         Option Quantity)” The value of the option contract is then multiplied by the
                                         number of options contracts, which is 48 in the example above. This is the value of all
                                         long call and short call options contracts.

 IV. “(Plus
                                         amount of cash)” Cash available is then added to this total, and a rate of
                                         return against the initial amount of seed money is calculated.

 V. “(Everything
                                         in I to IV divided by Seed Money, and then minus 1)” The formula for a rate
                                         of return can be shown as X/Y-1 where X is current value and Y is initial value. For
                                         example, 120/100-1 = 20% is another way of saying that something purchased for $100 and
                                         now worth $120 has enjoyed a 20% rate of return. In this example the components of the
                                         current value as described in I to IV are divided by the initial $2.5M in seed money
                                         and the number 1 is subtracted to arrive at a rate of return percentage.

In
round figures, if the difference in strike prices was $600, each option contract would be worth $60,000. If the fund had entered
into 48 such contracts the total value of the contracts would be $2,880,000. If available cash is $20,000, the fund would be worth
$2.9 million, and would represent a rate of return of 16% versus the initial $2.5 million investment.

The
total account value is representative of the minimum value of the Fund at the beginning, and at the end of the Outcome Period,
before fees and expenses, illustrating the ability to deliver a capital protected outcome with upside potential. The third option
instrument – the long put position – provides downside protection against a decline in the underlying asset.

 2. Comment. Please explain what the investment experience is expected to be for an investor
                                         who invests in the Fund on any day other than the first day of the Outcome Period.

Response. The Registrant respectfully directs the Staff’s attention to relevant disclosure in the Fund’s registration
statement (excerpted and attached hereto as Appendix A).

 3. Comment.
                                         The registration statement contains references to calls and puts, but the Staff notes
                                         that only the calls seem to be covered in the payoff profile graph. Please describe supplementally
                                         and/or in the graph, as applicable.

Response.
The payoff profile graphs in the Fund’s Prospectus are illustrative of the entire options package, which consists of
three FLEX Options positions on the Underlying ETF, expiring approximately one year from the start of the outcome period. Together,
these positions create the payoff profile illustrated in the Prospectus.

The
payoff profile, as represented in the Prospectus, is similar in construct to the profiles outlined in the prospectuses of other
defined outcome and target outcome ETFs. The put position is a long position, not a covered short position (like the call option
leg). The put option increases in value as the reference asset declines in price, protecting against loss. The call is written
out-of-the-money, meaning the Fund will participate in gains up to the strike price (the “cap”) and forfeit gains
beyond the strike price of the call.

    3

Below
is a more detailed illustration of the payoff profile diagram, as well as an outline of each options position, and its contribution
to the overall payoff profile.

Explanation
of diagram:

1.       S&P
500 (or Nasdaq 100 for the Calamos Nasdaq 100 Structured Alt Protection ETFs) Participation Layer: The dotted grey line represents
the first layer, which involves purchasing a near zero-strike (i.e., deep in-the-money) call on the reference asset, at a pre-determined
strike to provide full participation to the price return of the underlying reference asset. In other words, the full price participation
provided by this layer provides potential gains and losses that are tantamount to that of owning the underlying reference asset
outright, except that this layer does not participate in the dividend yield of the underlying reference asset.

2.       Capital
Protection Layer: The orange line represents the second layer, which involves purchasing an at-the-money put option, which
produces protection equal to 100% of losses (before fees and expenses) of the price return of the reference asset, over the Outcome
Period.

3.       Upside
Participation Layer (the “Cap”): The blue line illustrates the final layer, which involves selling an out-of-the-money
call, thereby creating the upside cap. The strike price at which the call is sold is determined so that the combined net options
purchase price is approximately equal to the underlying asset’s current value. The cost of this layer is a credit equal
to the price that would make the total package “no-cost” or fully financed.

 4. Comment.
                                         Please disclose the full name of the Fund in the registration statement.

Response.
The requested update has been made.

    4

 5. Comment.
                                         Please add disclosure briefly describing that the Fund will not have the benefit
                                         of receiving dividends from the underlying ETF.

Response.
The Registrant respectfully directs the Staff’s attention to disclosure in the sections of the Fund’s Prospectus
titled “Principal Investment Strategies” and “Additional Information About Investment Strategies and Related
Risks” which states:

“The
Fund’s performance will not reflect the payment of dividends by the Underlying ETF.”

 6. Comment.
                                         The Staff notes that the name of the Fund contains the word “Protected.”
                                         Please explain supplementally how this comports with Rule 35d-1 under the Investment
                                         Company Act of 1940 (“1940 Act”) such that an investor will not confuse the
                                         term “Protected” with a guarantee.

Response.
The Registrant has considered the Fund’s name in light of Rule 35d-1 under the 1940 Act, and believes the name complies
with Rule 35d-1 and the Fund’s 80% policy is an accurate representation of the investment objective and principal investment
strategy of the Fund. Furthermore, the Registrant believes the Fund’s name is consistent with its plain English meaning
and established industry use, which illustrates a specific type of outcome-based investment profile, commonly referred to as “capital
protected.” In response to the word ‘Protect’ implying a guarantee, the Registrant believes that in this case,
the use of ‘Protect’ does not imply a guarantee, is not misleading, and appropriately reflects the investment profile
of the Fund. The Registrant further believes using a name other than “Capital Protected” would create further investor
misunderstanding, as it would be deviating from established industry use.

The
Registrant further indicates that the proposed name provides what it believes is an accurate depiction of the investment profile
of the Fund, consistent with its investment objective, which is to, “seek to provide investment results that, before taking
fees and expenses into account, match the positive price return of the SPDR® S&P 500® ETF Trust (“Underlying
ETF”) up to a cap of [ %] (the “Cap”), while protecting against 100% of negative price return of the Underlying
ETF (before fees and expenses), for the period from [____], 202[ ] through [___], 202[ ];”2 as well as the
principal investment strategy, which is to provide investors with the opportunity to benefit from increases in the reference asset’s
share price up to the stated cap over a specified period of time of approximately one-year (the “Outcome Period”),
while providing protection against decreases in the Underlying ETF’s share price over the same Outcome Period (before taking
fees and expenses into account).

By
definition, capital protected growth products, whether it be in the structured note or insurance space, seek to deliver upside
participation in the positive performance of an underlying security or “reference asset” (e.g., S&P 500) with
100% capital protection upon maturity, before any fees and expenses. This is the generally accepted definition of a capital protected
structured product. It is also generally known, and depicted in the prospectus that value may fall below the capital protection
during the term. Additionally, there is issuer exposure risk with capital protected notes that does not exist with Capital Protected
ETFs. Capital Protected is a product ca