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    ROPES & GRAY LLP
 191 NORTH WACKER DRIVE
 32nd FLOOR
 CHICAGO, ILLINOIS 60606-4302
 WWW.ROPESGRAY.COM

September 25, 2024

Mr. Daniel Greenspan

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 Mr. Greenspan:

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 36 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 July 10,
2024 (the “PEA”) for the purpose of adding Calamos [Bitcoin Structured Alt Protection ETF] – [Month TBD1], Calamos [Bitcoin Structured Alt Protection ETF] – [Month TBD2],
Calamos [Bitcoin Structured Alt Protection ETF] – [Month TBD3], and Calamos [Bitcoin Structured Alt Protection ETF] – [Month
TBD4], respectively, as new series (each referred to herein as “the Fund”)
of the Registrant. Your comments provided via a videoconference calls on August 26, 2024 and September 23, 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 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. With respect to the Fund, please identify the underlying issuer (“Underlying
ETP”). Given the Fund’s concentrated exposure to a single underlying issuer, please demonstrate that the underlying issuer
is eligible to use Form S-3 for a primary offering of non-investment grade securities (pursuant to general instruction I.B.1 to Form S-3)
or in the alternative, please explain supplementally why there is sufficient market interest and publicly available information regarding
the underlying issuer notwithstanding its inability to use form S-3 for such an offering.

Response.
The Registrant has identified iShares Bitcoin Trust ETF as the underlying issuer. While it is a legal determination for the underlying issuer as to whether the underlying issuer meets the conditions to file a shelf registration
statement on Form S-3, the Registrant does not believe that, at the current time, the iShares Bitcoin Trust ETF meets the underlying criteria
making it eligible to file a shelf registration on Form S-3. The Registrant notes that, as of September 12, 2024, the Underlying ETP
had net assets in excess of $20 billion and over 600 million shares outstanding. Further, the Registrant notes that the Underlying ETP
makes required filings under Sections 13 or 15 of the Securities Exchange Act of 1934, as amended, which are readily available on the
Underlying ETP’s website.

Updated Response
(following September 23, 2024 discussion with Staff). The Registrant notes further that there is ample information about both
the Fund and Underlying ETP made available on a daily basis. This readily available information includes the Underlying ETP’s holdings,
net asset value, daily returns and trading volume.

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 2. Comment. In the section titled “Principal Investment Strategies,” please add
the following:

 a. A brief discussion of the underlying issuer and its operations with regards to creations/redemptions,
custody, and valuation.

 b. The name of the national securities exchange on which the Underlying ETP is listed and its ticker.

 c. A statement that the Commission maintains an internet site that contains reports, proxies and other information
about the Underlying ETP, including information about creations and redemptions.

 d. A statement that the Underlying ETP is subject to the information requirements of the Securities and Exchange
Act of 1934, as amended (the “1934 Act”), and files reports and other information with the Commission in accordance
with the 1934 Act.

Response.
The requested updates below have been added to the Principal Investment Strategies.

 a. The requested update has been made under the section titled “The Underlying ETP.”

 b. The requested update has been made under the section titled “The Underlying ETP.” The Underlying
ETP’s shares are listed and traded on the Nasdaq Stock Market LLC under the ticker symbol “IBIT.”

 c. The requested update has been made under the section titled “The Underlying ETP.”

 d. The requested update has been made under the section titled “The Underlying ETP.”

 3. Comment. Given the uncertain state of the Form 19b-4 process with respect to Flexible
EXchange Options (“FLEX Options”), with respect to the wording: “…and when available, Flexible EXchange
Options,” the Staff requests the following:

 a. Please relocate the disclosure about FLEX Options from the disclosure provided in response to Item 4 of
Form N-1A to the disclosure provided in response to Item 9 of Form N-1A.

 b. Please update this disclosure to state the Fund will invest in FLEX Options “if and when available”
as it is not yet a certainty.

 c. Please update this disclosure with additional context pertaining to the availability of FLEX Options such
as precedence, Form 19b-4 proceedings and a statement that it is possible that the FLEX Options may not be approved.

 d. Please provide more descriptive information about the OTC Options. The Staff notes that there needs to
be at least comparable disclosure about OTC Options as there is regarding FLEX Options. Please also add risk disclosure regarding such
OTC Options.

Response.
The Registrant updated the disclosures in accordance with the following below:

 a. The disclosure about FLEX Options has been moved to the disclosure provided in response to Item 9 of Form N-1A.

 b. The requested update has been made.

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 c. The Registrant has revised this disclosure as shown below.

 i. “Each of CBOE Exchange, Inc. (for options on any bitcoin ETP), NYSE Arca, Inc. (for options
on any commodity ETP, which would include those on any bitcoin ETP), and Nasdaq ISE, LLC (for options on the Underlying ETP) have filed
applications under Rule 19b-4 of the Securities Exchange Act of 1934, as amended (“Exchange Act”), with the SEC to amend
their listing standards and allow listing of options on bitcoin ETPs. Nasdaq ISE also filed a subsequent application to allow listing
of options on any bitcoin ETP. The SEC will solicit public comment on each of these applications and may request that the applications
be withdrawn and resubmitted. The SEC is required to approve or disapprove, or institute proceedings to determine whether to disapprove
the proposed rule change. Section 19(b)(2) of the Exchange Act requires that, after initiating disapproval proceedings,
the SEC issue an order approving or disapproving the proposed rule change within 180 days of the publication date of the notice of
the proposed rule change. The SEC may extend the period for issuing such order by not more than 60 days if the SEC determines that
a longer period is appropriate and publishes reasons for such determination. It is not possible to estimate when such applications may
be approved by the SEC and there is no guarantee that FLEX Options will ever be approved by the SEC.”

 d. The Registrant has revised this disclosure as shown in the section titled “General Information about
OTC Options” and has added risk disclosure regarding such OTC Options under the section titled “Principal Risks.”

 4. Comment. On page 6
of the Prospectus, in the second full paragraph, there is a sentence that states that the Fund “will also invest in other securities,
including U.S. Treasury securities….” What other securities is the Registrant referring to other than U.S Treasury securities?
If there are other securities contemplated, the Staff requests the Registrant to make that clear.

Response.
The Registrant confirms it currently contemplates investing only in OTC Options, U.S. Treasury securities with remaining maturities
of one year or less and cash and cash equivalents. The Registrant also intends to invest in FLEX Options if and when they become available.
The Registrant has revised the disclosure to make this clear.

 5. Comment. Please add a statement
in section titled “Principal Investment Strategies” that the Fund will not invest directly in bitcoin.

Response.
The requested update has been made.

 6. Comment. In the section titled “Principal Investment Strategies,” there is a
sentence that states “At such time as they become available, the Fund intends to utilize in place of OTC Options FLEX Options.”
For clarity’s sake, the Staff requests the Registrant to be more specific about the extent to which the Registrant is going to replace
the OTC Options. Will the OTC Options be replaced entirely or partially, and will portfolio repositioning be required?

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Response.
The Registrant confirms that it intends to utilize FLEX Options in place of all OTC Options. The Registrant directs the Staff
to the updated disclosure in the section titled “Principal Investment Strategies” stating the following:

“If and when they become available,
the Fund intends to utilize FLEX Options in place of all OTC Options.”

If the Fund has commenced operations
utilizing OTC Options, it will replace the OTC Options with FLEX Options noting that the overall risk profile of the Fund is expected
to remain unchanged.

 7. Comment. On page 7
of the Prospectus, the second paragraph from the bottom of the page states the following: “…the terms of the OTC Options
and FLEX Options do not generally change during an Outcome Period....” Please explain supplementally the circumstances in which
there could be a change in the terms during the Outcome Period.

Response.
 The Registrant intends to negotiate OTC Options and/or purchase FLEX Options, if and when available, at the commencement of the Outcome
Period to remain in effect for the duration of the Outcome Period. Registrant is not aware of circumstances in the normal course of business
in which there could be a change in the terms during the Outcome Period, save, in connection with OTC Options, mutual agreement by the
parties to the OTC Option to a change in the underlying terms thereof or in connection with the bankruptcy of the OTC counterparty.

 8. Comment. Please add disclosure addressing whether the Fund or shareholders will have the
benefit of receiving dividends from the Underlying ETP.

Response.
The Registrant has added disclosure under the section titled “The Underlying ETP” noting that the Fund investors will
not receive dividends from the Underlying ETP.

 9. Comment. It is the Staff’s understanding that treasury downside protection is unique
to this set of ETFs. Please add disclosure on how the treasury portfolio contributes to or provides 100% downside protection if the shareholder
invests on the start date of the Outcome Period.

Response.
The Registrant respectfully notes the following explanation of how the treasury portfolio contributes to downside protection included
under the heading “Explanation of Diagram” in the Principal Investment Strategies section of the Prospectus:

The Fund purchases multiple series of
US Treasury securities with weighted average maturities of approximately one (1) year or less to provide the protection level. In
the event that the Underlying ETP decreases in value over the duration of the option contracts to a price that is lower than the strike
price of the option contract, the Fund’s options positions would not be exercised and the Fund’s value would be comprised
primarily of the US Treasury securities, cash and cash equivalents. The U.S. Treasury securities held by the Fund are intended to provide
the downside protection against decreases in the price of the Underlying ETP. There is no guarantee that the portion of the Fund’s
portfolio consisting of U.S. Treasury securities will retain sufficient value to provide the level of portfolio protection sought by the
Fund. The value of the Fund’s holdings in U.S. Treasury securities may increase (providing a higher protection level and therefore
more protection to shareholders) or decrease (providing a lower protection level and therefore less protection to shareholders).

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 10. Comment. On the table on Page 9 of the Prospectus, the heading “Portfolio Investment
Percentage” has an asterisk next to it. To what does that asterisk correspond?

Response.
The Registrant confirms the asterisk was included in error and has removed the asterisk.

 11. Comment. On page 13 of the Prospectus, with respect to the section titled “General
Information about FLEX Options,” there should be analogous general information about the OTC Options in lieu of this disclosure.
Please move the information about FLEX Options to the disclosure provided in response to Item 9 of Form N-1A.

Response.
The Registrant has made the requested updates.

 12. Comment. The Staff notes
that the Fund will invest significantly in OTC Options. Given the liquidity profile of these instruments, please explain supplementally
how the Fund’s investment strategy is appropriate for an open-end structure. The Registrant’s response should include information
concerning the relevant factors referenced in the release adopting Rule 22e-4 under the Investment Company Act of 1940 (“1940
Act”).

Response.
The Fund currently anticipates that OTC Options will make up less than 15% of the overall Fund’s net assets at any given time.
The Registrant recognizes that in accordance with the requirements of Rule 22e-4, a fund’s liquidity risk management program
must include written policies and procedures that are reasonably designed to incorporate the following elements: (i) assess and periodically
review the fund’s liquidity risk; (ii) classify the liquidity of each of the fund’s investments; (iii) determine
the fund’s highly liquid investment minimum and respond to shortfalls; (iv) limit the fund’s investments in illiquid
investments that are assets to no more than 15% of the fund’s net assets; (v) in-kind redemption requirements; and (vi) Board
oversight of the Program.

Further, Rule 22e-4(b)(1)(ii) provides
that “each fund must, using information obtained after reasonable inquiry and taking into account relevant market, trading, and
investment-specific considerations, classify each of the fund’s portfolio investments (including each of the fund’s derivatives
transactions) as a highly liquid investment, moderately liquid investment, less liquid investment, or illiquid investment.”

As the Fund will not be deemed to be
an “In-Kind ETF” under Rule 22e-4, the Registrant acknowledges the need to classify and evaluate at least monthly its
OTC Options, and more frequently if changes in relevant market, trading, and investment-specific considerations are reasonably expected
to materially affect the classification of its OTC Options. The Registrant also acknowledges the need for written policies and procedures.

The Registrant noted that the Rule contemplates
that for option contracts, such as the OTC Options contracts expected to be held by the Fund, a fund may consider the frequency, volume
and quotes which are based on the underlying reference asset (such as the iShares Bitcoin Trust ETF) in determining liquidity. The Registrant
notes that the Fund will use OTC Options that derive their value from the actively-traded Underlying ETP, and draw upon that security’s
general pool of liquidity. The Registrant believes that the highly regulated options market make securities that derive their value from
the Underlying ETP less susceptible to liquidity concerns. Further, the OTC Options will be structured so that any amount owed by the
Fund on the written OTC Options wil