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    ROPES & GRAY LLP

    191 NORTH WACKER DRIVE

    32nd FLOOR

    CHICAGO, ILLINOIS 60606-4302

    WWW.ROPESGRAY.COM

 

June 13, 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 29 to 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 April 12, 2024 (each,
as applicable, a “PEA”) for the purpose of adding Calamos Russell 2000 Structured Alt Protection ETF – July,
Calamos Russell 2000 Structured Alt Protection ETF – October, Calamos Russell 2000 Structured Alt Protection ETF – January,
and Calamos Russell 2000 Structured Alt Protection ETF – April, respectively, as new series (each referred to herein as “the
Fund”) of the Registrant. Your comments provided via a videoconference call on May 22, 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 the PEA 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 Russell 2000 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 iShares® Russell 2000® 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 

     

 

    underlying asset
    IWM

    spot price
      199.39

    expiry date
      6/10/2025

    seed money
      2,481,998

    Strike
    Price
    Qty
    Value
    Weight

    Long Call
      0.65
      195.41
      124.00
      2,423,084
      97.63 %

    Long Put
      199.41
      11.93
      124.00
      147,932
      5.96 %

    Short Call
      221.56
      8.58
      (124.00 )
      (106,392 )
      -4.29 %

    Option Legs Total

      2,464,624
      99.30 %

    Cash

      17,374
      0.70 %

    Total account value

      2,481,998
      100.00 %

    gross
    net

    Cap rate
      11.07 %
      10.38 %

    Protection
      100.00 %
      99.31 %

 

These contract positions are broken
down below, using prices as of June 7, 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 11.07% 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 $199, a call option with a strike price of $700 is far less likely to
be exercised than one with a strike price of $225.

 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 $199, a call option with a strike price of $3 is worth far more than a
call option with a strike price $209 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.

 

 III. “(* Option Quantity)” The value of the option contract is then multiplied by the number
of options contracts, which is 124 in the example above. This is the value of all long call and short call options contracts.

 

    2 

     

 

 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 $2,481,998 in seed money and the number 1 is subtracted to arrive at a rate of return
percentage.

 

As a hypothetical example using an initial
investment of $1 million, if the difference in the short call strike and long call strike prices was $100, the maximum value of the option
package would be $10,000. If the fund had entered into 110 such contracts the total value of the contracts would be $1,100,000. If available
cash is $10,000, the fund would be worth $1,110,000 million. This would represent a rate of return of 11% versus the initial $1 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.

 

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.

 

    3 

     

 

Explanation of diagram:

 

1.       Calamos
Russell 2000 Structured Alt Protection ETF 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 solid grey 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 solid black 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. In addition, please revise the fund names. The terms
 ‘capital protection’ may mislead investors into thinking that their capital is 100% protected in all circumstances.

 

Response.

 

In light of the Staff’s comment,
the Registrant is changing each Fund’s name. The Fund names have been changed, as follows:

 

    Old Name
    New Name

    Calamos Capital Protected Russell 2000 ETF – July
    Calamos Russell 2000 Structured Alt Protection ETF – July

    Calamos Capital Protected Russell 2000 ETF – October
    Calamos Russell 2000 Structured Alt Protection ETF – October

    Calamos Capital Protected Russell 2000 ETF – January
    Calamos Russell 2000 Structured Alt Protection ETF – January

    Calamos Capital Protected Russell 2000 ETF – April
    Calamos Russell 2000 Structured Alt Protection ETF – April

 

 7. Comment. Please provide completed fee and expense tables to the Staff with adequate time
to review in advance of the 485(b) filing.

 

Response. Each 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
      0.69 %

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

    Other Expenses1
      0.00 %

    Total Annual Fund Operating Expenses
      0.69 %

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

    5

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 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

    $
    70
     
     
    $
    221

 

The Registrant notes that the figures
provided in the preceding table and example are identical to the ones shown in the Prospectus of each of the four Funds.

 

 8. Comment. Please explain how the Fund will be managed so that there will not be a loss during
the Outcome Period.

 

Response. As noted in
the Fund’s Prospectus, the Fund is designed and managed to provide 100% downside protection over the outcome period. The Prospectus
also notes that if investors buy or sell on a date other than the start or end date of the Outcome Period, their returns will be different
and they may incur losses in excess of the Capital Protection level (i.e., losses exceeding 0%) and they may not experience gains up to
the Cap.

 

The Fund will be constructed and managed
similarly to other defined outcome and target outcome ETFs seeking to deliver a stated investment profile outcome over an outcome period.

 

During the outcome period, the Fund
will provide a level of capital protection between 100% and (100% - cap rate), before fees and expenses, depending on the movement of
the Underlying ETF after the start of the outcome period. This protection level can be known prior to purchasing shares in the Fund, via
the Fund’s website and through pricing tools available on the Fund’s website. For example, if the ETF exhibits a 9% cap and
capital protection at the beginning of the outcome period, and the ETF subsequently appreciates by 3%, the payoff profile for new investors
will be a 6% upside cap (9% - 3%), and a 97% protection level (because the ETF has appreciated above the Capital Protection level by 3%).
Existing shareholders should not be harmed by new investors, as they will be entering the Fund at values that are representative of the
then current market values.

 

 9. Comment. An analysis by the Staff that involved pricing the options on the index always
showed a loss. Please explain supplementally how this will not be the case with regard to the Fund’s investments.

 

Response. The
Registrant is not privy to the methodology used by the Staff to construct the options package. The Registrant notes that the options
and prices used are similar in construct to nearly all (more than 150) defined outcome