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INVESTMENT MANAGERS SERIES TRUST II

235 W. Galena Street

Milwaukee, Wisconsin 53212

VIA EDGAR

January 25, 2024

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attention: Division of Investment Management

 Re: Investment Managers Series Trust II (the “Registrant”) (File Nos. 333-191476 and 811-22894)

on behalf of the AXS
Merger Fund

Ladies and Gentlemen:

This letter summarizes the additional comment
provided to me by Ms. Samantha Brutlag of the staff of the Securities and Exchange Commission (the “Commission”) by telephone
on January 19, 2024, regarding Post-Effective Amendment No. 393 to the Registrant’s registration statement filed on Form N-1A (the
“Registration Statement”) on November 29, 2023, relating to the AXS Merger Fund (the “Fund”), a series of the
Registrant. The Registrant’s response to the comment is included below. Additionally, this letter is being provided to provide a revised response to a comment provided to me by Ms. Brutlag by telephone on January
11, 2024 regarding the Registration Statement for the Fund. Capitalized terms not otherwise defined in this letter have
the meanings assigned to them in the Registration Statement.

SUMMARY SECTION

Principal Investment Strategies

 1. To restate the Staff’s position, funds with the term “Merger” in their names should
have an 80% investment policy in accordance with Rule 35d-1 under the Investment Company Act of 1940, as amended (the “Names Rule”).

Response: The Registrant acknowledges
the Staff’s comment; however, the Registrant continues to believe the current Names Rule does not apply to the term “merger”
in the Fund’s name, for the reasons stated in response to comment #2 in the letter dated January 18, 2024. As a result, the Registrant
respectfully declines to add an 80% Names Rule policy to the Fund’s investment strategies.

Fees and Expenses

 2. Please provide the Fund’s completed fee table and example to the Commission for review at least
five business days prior to filing the Amendment.

Response: The Fund’s completed
fee table and example are as follows:

Fees and Expenses of the Fund

This table describes the fees and
expenses that you may pay if you buy, hold and sell shares of the Fund. You may pay other fees, such as brokerage commissions and other
fees to financial intermediaries, which are not reflected in the table and example below.

    Investor

 Class

 Shares

    Class I

 Shares

    Shareholder Fees

    (fees paid directly from your investment)

    Maximum sales charge (load) imposed on purchases

    None

    None

    Maximum deferred sales charge (load)

    None

    None

    Redemption fee if redeemed within 30 days of
    purchase (as a percentage of amount redeemed)

    1.00%

    1.00%

    Wire fee

    $20

    $20

    Overnight check delivery fee

    $25

    $25

    Retirement account fees (annual maintenance fee)

    $15

    $15

    Annual Fund Operating Expenses

    (expenses that you pay each year as a percentage
    of the value of your investment)

    Management fees

    1.25%

    1.25%

    Distribution (Rule 12b-1) fees

    0.25%

    None

    Other expenses

    1.14%

    1.14%

    Dividends expense on securities sold short

    0.32%

    0.32%

    Interest expense
    0.50%

    0.50%

    All other expenses
    0.32%

    0.32%

    Acquired fund fees and expenses

    0.06%

    0.06%

    Total annual fund operating expenses1

    2.64%

    2.39%

    Fee waivers and expense reimbursement2

    (0.51)%

    (0.51)%

    Total annual fund operating expenses after fee waivers and expense reimbursement1,2

    2.13%

    1.88%

1 The total annual fund operating expenses and net operating expenses do not correlate
to the ratio of expenses to average net assets appearing in the financial highlights table, which reflects only the operating expenses
of the Fund and does not include acquired fund fees and expenses.

2 The Fund’s advisor has contractually agreed to waive its fees and/or pay for
operating expenses of the Fund to ensure that total annual fund operating expenses (excluding any taxes, leverage interest, brokerage
commissions, dividend and interest expenses on short sales, acquired fund fees and expenses (as determined in accordance with SEC Form
N-1A), expenses incurred in connection with any merger or reorganization, and extraordinary expenses such as litigation expenses) do not
exceed 1.75% and 1.50% of the average daily net assets of Investor Class and Class I shares of the Fund, respectively. This agreement
is in effect until January 31, 2025, and it may be terminated before that date only by the Trust’s Board of Trustees. The Fund’s
advisor is permitted to seek reimbursement from the Fund, subject to certain limitations, of fees waived or payments made to the Fund
for a period ending three full years after the date of the waiver or payment. Such reimbursement may be requested from the Fund if the
reimbursement will not cause the Fund’s annual expense ratio to exceed the lesser of (a) the expense limitation in effect at the
time such fees were waived or payments made, or (b) the expense limitation in effect at the time of the reimbursement. Reimbursements
of fees waived or payments made will be made on a “first in, first out” basis so that the oldest fees waived or payments are
satisfied first.

Example

This example
is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds. The example assumes
that you invest $10,000 in the Fund for the time periods indicated and then redeem all of your 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 would be:

    One Year
    Three Years
    Five Years
    Ten Years

    Investor Class Shares
    $216
    $772
    $1,355
    $2,936

    Class I Shares
    $191
    $697
    $1,229
    $2,687

*  *  *  *  *

If you have any further questions or require
further clarification of the response, please contact me at (626) 385-5777. I may also be reached at diane.drake@mfac-ca.com.

Sincerely,

/s/ Diane J. Drake

Diane J. Drake

Secretary