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INVESTMENT MANAGERS SERIES TRUST II

235 W. Galena Street

Milwaukee, Wisconsin 53212

VIA EDGAR

December 9, 2024

Ms. Deborah O’Neal

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attention: Division of Investment Management

 Re: Investment Managers Series Trust II (the “Registrant” or “Trust”) (File
Nos. 333-191476 and 811-22894) on behalf of the AXS Market Neutral Fund

Dear Ms. O’Neal:

This letter summarizes the comments provided to
me by telephone on December 5, 2024, regarding Post-Effective Amendment No. 425 to the Registrant’s registration statement on Form
N-1A (the “Registration Statement”) filed on October 17, 2024, with respect to the AXS Market Neutral Fund (the “Fund”),
a series of the Trust. Responses to all of the comments are included below and, as appropriate, will be reflected in a Post-Effective
Amendment to the Fund’s Registration Statement (the “Amendment”), which will be filed separately. Capitalized terms
not otherwise defined in this letter have the meanings assigned to them in the Registration Statement.

PROSPECTUS

SUMMARY SECTION

Fees and Expenses Table

 1. Please provide the Fund’s completed fees and expenses table and expense example for review at least
five business days prior to filing the Amendment.

Response: The Fund’s completed
fees and expenses table and expense example are as follows:

    Investor

Class

    Shares

    Class I

 Shares

    Shareholder Fees

    (fees paid directly from your investment)

    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 Expenses1

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

    Management fees
    1.40%
    1.40%

    Distribution (Rule 12b-1) fees
    0.25%
    None

    Other expenses
    1.06%
    1.06%

    Acquired
    fund fees and expenses2
    0.89%
    0.89%

    Total annual fund operating expenses
    3.60%
    3.35%

    Fee
    Waivers and Expense Reimbursement3
    (1.01)%
    (1.01)%

    Total annual fund operating expenses after fee waivers and expense reimbursement 3
    2.59%
    2.34%

 1 Annual Fund Operating Expenses have been restated to reflect current fees, as of
December 16, 2024.

 2 Acquired fund fees and expenses are based on estimated amounts for the current
fiscal year.

 3 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 1.70% and 1.45% of the average daily net assets of the Investor Class shares and Class I shares of the Fund, respectively. This
agreement is in effect until January 31, 2026, 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 years from 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. The example reflects the Fund’s
contractual fee waiver and/or expense reimbursement only for the term of the contractual fee waiver and/or expense reimbursement.

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
    $262
    $1,010
    $1,779
    $3,797

    Class I Shares
    $237
    $936
    $1,659
    $3,572

 2. Footnote 2 to the fees and expenses table provides that the 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. The recapture of fees should be made within three years of the date of the waiver or payment.

Response:
The Registrant confirms that the recapture of any fees waived or payments made will be made within three years of the date of the waiver
or payment.

Principal Risks

 3. Please consider revising the Fund’s risk disclosure to discuss any heightened risks applicable to
the Fund as a result of the ongoing conflict in the Middle East.

Response: The Registrant has
revised “Recent Market Events” to discuss the ongoing conflict in the Middle East as follows:

Recent market events. Periods
of market volatility may occur in response to market events, public health emergencies, natural disasters or climate events, and other
economic, political, and global macro factors. For example, in recent years the large expansion of government deficits and debt as a
result of government actions to mitigate the effects of the COVID-19 pandemic and inflation have resulted in extreme volatility in the
global economy and in global financial markets. In addition, military conflicts and wars, such as Russia’s invasion of Ukraine
and the war among Israel, Hamas and other militant groups in the Middle East, have increased tensions in Europe and the Middle East and
have caused and could continue to cause market disruptions in the regions and globally. These and other similar events could be prolonged
and could adversely affect the value and liquidity of the Fund’s investments, impair the Fund’s ability to satisfy redemption
requests, and negatively impact the Fund’s performance.

MORE ABOUT THE FUNDS’ INVESTMENT OBJECTIVES, PRINCIPAL INVESTMENT
STRATEGIES AND RISKS

Principal Investment Strategies and Principal Risks of Investing

 4. Apply all applicable comments from the summary section for the
Fund to Item 9 of Form N-1A.

Response: The Registrant confirms
that all applicable comments from the summary section have been made to the Fund’s Item 9 disclosure.

*********

The Registrant believes that it has fully responded
to each comment. If, however, you have any further questions or require further clarification of any response, please contact me at (626)
385-5777.

Sincerely,

/s/ Diane J. Drake

Diane J. Drake

Secretary