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    ROPES & GRAY LLP

    191 NORTH WACKER DRIVE

    32nd FLOOR

    CHICAGO, ILLINOIS 60606-4302

    WWW.ROPESGRAY.COM

January 31, 2025

Mr. Mark Cowan

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. Cowan:

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 numbers 45-47 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 November 20, 2024 (the “PEAs”)
with respect to the Funds set forth in Appendix A hereto (each a series of the Registrant) (each such series is referred to herein as
a “Fund” and, collectively, as the “Funds”). Your comments provided via a videoconference call on January 7, 2025,
are summarized below, and each comment is followed by our response. As the context of the comments and responses indicate, certain comments
apply to all Funds while others apply only to some of the Funds. Capitalized terms not otherwise defined herein have the meanings ascribed
to them in the PEAs. 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 use of the term “Protection” in the Fund names suggests a guarantee
when said term is coupled with or adjacent to a percentage such as “100%”. Please revise the Funds’ names.

Response.
The Registrant has revised the Fund names as requested. Specifically, rather than referring to the Funds as

“Calamos Bitcoin [Relevant Percentage]% Protection Strategy ETF — [Relevant Month]”,

the Registrant will refer to these Funds
as the

“Calamos
Bitcoin [ ] Series Structured Alt Protection ETF® – [Relevant Month]” Funds.

The Fund formerly known as the Calamos Bitcoin 80% Protection Strategy ETF – January, for example, is now the Calamos Bitcoin 80
Series Structured Alt Protection ETF® – January .

Further, the “Calamos Bitcoin
100% Protection Strategy (6 mo) ETF – [Month] will be known as the “Calamos Bitcoin Structured Alt Protection ETF®
 – 6 Mo [Relevant Months]”.

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 2. Comment. In some places within the prospectuses, the disclosure states that the protection
offered to investors is protection relative to losses experienced by the Underlying ETPs and/or Bitcoin Indexes. For example:

Floor Risk:
The Fund will be subject to the first 10% of losses experienced by the Underlying ETP over an Outcome Period, and
there can be no guarantee that the Fund will be successful in its strategy to limit the losses in excess of the first 10% experienced
by the Underlying ETP during an Outcome Period. [Emphasis Added]

In other places within the prospectuses,
the disclosure states that the protection offered to investors is protection relative to losses experienced by Spot bitcoin only. For
example:

As described
in more detail in the Fund’s summary, the Fund seeks to provide investment results that, before taking fees and expenses into account,
track the positive price return of the CME CF Bitcoin Reference Rate – New York Variant (“BRRNY”) (“Spot bitcoin”)
up to a predetermined upside cap (the “Cap”) while seeking to provide a Floor with protection to a maximum loss
of 10% of the negative price return of Spot bitcoin (before fees and expenses) over a period of approximately one year (the “Outcome
Period”). [Emphasis Added]

Please revise the disclosure to be consistent
in describing the protection investors are being offered.

Response.
The Registrant has revised the disclosure to specify that the protection that the Fund seeks to provide is protection against the negative
price return of Spot bitcoin (before total fund operating fees and expenses) over the Outcome Period (i.e., 80% or 90% of the negative
price return, as applicable for the particular fund).

 3. Comment. Please explain why the disclosure that states “When the Fund's management
fees are also taken into account, the Capital Protection level is reduced to ____ %.” includes only the management fee and does
not include fees and expenses.

Response.
The Registrant has revised the disclosure to refer to the management fee in this context by the more general “total fund operating
fees and expenses” which the Registrant notes would be the same percentage (0.69%, given that this is a unitary fee) but would provide
greater clarify and consistency to a reader.

 4. Comment. In the bullet point that states “Floor: The Fund seeks to provide a maximum
loss of [10]% (by providing a Floor against the negative price return of Spot bitcoin exceeding 10%) prior to taking into account any
fees or expenses charged to the Fund.”

Please include disclosure reflecting that a Floor provides no initial downside protection but instead provides protection beyond an initial
market decline.

In addition, please provide a simple definition/example of a Floor here and in each section in any of the prospectuses where the concept
of a Floor is introduced.

Response.
The Registrant has revised the disclosure as requested. The revised disclosure reads:

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Floor: The Fund seeks to provide protection
against a loss exceeding 10% (by providing a Floor against the negative price return of Spot bitcoin exceeding 10%) prior to taking into
account any fees or expenses charged to the Fund.

A Floor provides no initial downside protection,
but instead provides protection against a price decline that exceeds a certain percentage over the entirety of an Outcome Period.

If, for example, the Floor is 10% and
the price of Spot bitcoin declines by 8% over an Outcome Period, an investor would not receive any protection from the Floor because the
decline was not greater than 10%. If, by contrast, the decline of the price of Spot bitcoin over the Outcome Period was 23%, the Floor
feature is designed to limit that investor’s loss to only 10% of Spot bitcoin’s price decline (before total fund operating
fees and expenses) over the Outcome Period.

The Floor percentage (in this case, 10%) should therefore not be understood to apply to any given level of loss. Thus, a 23% decline in
the price of Spot bitcoin over an Outcome Period would not entitle the investor to protection against 90% of that loss (and therefore
would not entitle the investor to protection against all but 2.3% of that loss).

Although the disclosure and example
above apply to the 90 Series, the Registrant will include similar disclosure and examples, as applicable, in the registration statement
of the 80 Series as well.

 5. Comment. Please revise the following disclosure to read “twelve-month” or “one
year” instead of “six-month” in the prospectuses of the 90% Floor ETFs and in all other prospectuses, as applicable:

Outcome Period: The approximate one-year
period over which the Fund seeks to produce the Capital Protected Target Outcome. Subsequent Outcome Periods will begin on the day the
prior Outcome Period ends and are expected to end the day before the six-month anniversary of the new Outcome Period.

Response.
The Registrant has revised the disclosure as requested.

 6. Comment. The investment objective across the prospectuses generally reads as follows:

[The Fund]
seeks to provide investment results that, before taking fees and expenses into account, track the positive price return
of the CME CF Bitcoin Reference Rate – New York Variant (“BRRNY”) (“Spot bitcoin”). [Emphasis Added]

Given that investors could experience
losses and given that the word ‘track’ is already used, consider whether to remove the word ‘positive’ from this
disclosure.

Response.
The Registrant respectfully declines to make this change and notes that the words “seeks to” adequately reflects that
the Fund seeks to provide investment results that, before taking fees and expenses into account, track the positive price return Spot
bitcoin.

 7. Comment. Please disclose what is meant by “fees and expenses” in the disclosure
that follows and similar such disclosure. If what is meant is “total fund operating fees and expenses”, please revise the
disclosure accordingly.

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As described in more detail in the Fund's
summary, the Fund seeks to provide investment results that, before taking fees and expenses into account, track the positive price return
of the CME CF Bitcoin Reference Rate – New York Variant (“BRRNY”) (“Spot bitcoin”) up to a predetermined
upside cap (the “Cap”) while seeking to provide a Floor with protection to a maximum loss of 10% of the negative price return
of Spot bitcoin (before fees and expenses) over a period of approximately one year (the “Outcome Period”). [Emphasis
Added]

Response.
 The Registrant has revised the disclosure as requested.

 8. Comment. Please consider adding an example of the Floor protection to the Principal Investments
Strategies disclosure.

Response.
The Registrant has added this disclosure as requested.

 9. Comment. Please remove “, but not limited to” from the following disclosure
so that you are not insinuating that there are other approaches not disclosed in the prospectuses by which you may implement the principal
investment strategies:

Based on market conditions and other factors
at the commencement of the Outcome Period, Calamos Advisors LLC (“Calamos Advisors” or the “Advisor”) seeks to
provide investment exposure to the price performance of Spot bitcoin through various means of portfolio construction and management, including,
but not limited to the two methods/approaches as may be implemented by the Adviser in its discretion as described below.

Response.
The Registrant has revised the disclosure by deleting “, but not limited to” as requested.

 10. Comment.  Please revise the following sentence so that it is clear and consistent across
all ETFs.

In the second method/approach, the Fund’s
portfolio will be comprised of options and cash and cash equivalents. Under this approach, and under normal market conditions, the Fund
will invest substantially all of its assets in cash and cash equivalents and, if and when available, one or more of the following: (i)
FLEX Options or (ii) Listed Options – each of which reference the price performance of either: (A) one or more of the Underlying
ETPs or (B) a Bitcoin Index.

Response.
The Registrant has revised the disclosure as requested. The revision is as follows:

In the
second method/approach, the Fund’s portfolio will be comprised of options and cash and cash equivalents. Under this approach, and
under normal market conditions, the Fund will invest substantially all of its assets in cash and cash equivalents and, if and when available,
one or more of the following: (i) FLEX Options and/or Listed Options. The FLEX Options and/or Listed Options
will each reference the price performance of either: (A) one or more of the Underlying ETPs and/or (B)
a Bitcoin Index. [Additions in bold-faced text, deletions in strikethrough.]

 11. Comment. Please insert “the first” after the word “against” in the
following sentence across all Bitcoin ETF prospectuses where applicable:

The Fund does not seek to provide capital
protection against 10% of losses (before fees and expenses) of Spot bitcoin as of any time other than the end of the Outcome Period.

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Response.
The Registrant has revised the disclosure as requested.

 12. Comment. Please revise the following sentence so that it has softened ‘may include’
language across all ETF prospectuses. Some prospectuses do not have ‘may’ here.

The Fund has adopted a non-fundamental
operating policy that requires it, under normal circumstances, to invest at least 80% of its net assets (plus borrowings for investment
purposes, if any) in investments that provide exposure to Spot bitcoin. As described herein, the investments that the Fund intends to
utilize for its 80% investment policy may include OTC options and/or, if and when available, FLEX Options and/or Listed
Options in one or more of the Underlying ETPs and/or one or more Bitcoin Indexes. For purposes of compliance with this investment policy,
derivative contracts will be valued at their notional value. Although this requirement may be changed by the Board of Trustees without
shareholder approval, the Fund will notify shareholders in writing at least 60 days prior to any change in its 80% policy. [Emphasis Added]

Response.
The Registrant has revised the disclosure as requested.

 13. Comment. In discussing the First Approach/Method, the 90% Floor prospectuses mention that
 “References to the Bitcoin Reference Asset in the charts below are intended to refer to the Underlying ETPs.” In other portions
of these prospectuses, “or Bitcoin Index” is added to the end of this sentence. Please revise for consistency.

Response.
The Registrant has revised the disclosure as requested by adding “and/or Bitcoin Index” where applicable.

 14. Comment. Please update the language in the 90% Floor prospectus to state “one year”
where it states “(the final day of the option term set at approximately six months).”

Response.
The Registrant has revised the disclosure as requested.

 15. Comment. Please clarify the passage titled “Risks Associated with Investing in the
Underlying ETPs” given that the Funds do not invest directly in ETPs.

Response.
The Registrant has removed the passage titled “Risks Associated with Investing in the Underlying ETPs” given that the Funds
do not invest directly in the Underlying ETPs.

 16. Comment. Please explain that an investor can lose gains from a prior outcome period. In
other words, please disclose that gains earned in one period are not protected by a Floor in a subsequent outcome period.

Response.
The Registrant respectfully notes that it disclosed that the protection relates to the outcome period, and nothing the Registrant
has disclosed suggests that there is protection other than with respect to the subject outcome period.

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Further, the Registrant noted that the product is tied to the current outcome period, so if the Registrant were to add disclosure on cross-outcome-periods
it might confuse investors.

 17. Comment. Please provide disclosure on investing in a subsidiary somewhere within the principal investment strategies
section.

Response.
The Registrant has revised the disclosure as requested.

 18. Comment. Please address the following comments.

 I. All Subsidiaries should provide the following disclosure:

 a) Disclose that “Subsidiary” includes entities that engage in investment activities in securities or other assets that are
primarily controlled by the Fund.

The Subsidiary is not investing in other assets that are
primarily controlled by the Fund.

 b) Disclose that the fund complies with the provisions of the Investment Company Act governing investment policies (Section 8) on an
aggregate basis with the Subsidiary.

The Registrant confirms that the Fund complies with the
provisions of the Investment Company Act governing investment policies (Section 8) on an aggregate basis with the Subsidiary.

 c) Disclose that the fund complies with the provisions of the Investment Company Act governing capital structure and leverage (Section
18) on an aggregate basis with the Subsidiary so that the fund treats the Subsidiary’s debt as its own for purposes of Section 18.5

The Registrant confirms that the Fund complies with the
provisions of the Investment Company Act governing capital structure and leverage (Section 18) on an aggregate basis with the Subsidiary.

 d) Disclose that any investment adviser to the Subsidiary complies with provisions of the Investment Company Act relating to inves