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INVESTMENT MANAGERS SERIES TRUST II

235 W. Galena Street

Milwaukee, Wisconsin
53212

VIA EDGAR

March 5, 2025

Ms. Soo Im-Tang

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

 Re: Investment
                                            Managers Series Trust II (File Nos. 333-191476 and 811-22894) (the “Registrant”)
                                            on behalf of the LeaderShares® Activist Leaders® ETF, LeaderShares®
                                            AlphaFactor® Tactical Focused ETF, LeaderShares® AlphaFactor®
                                            US Core Equity ETF, LeaderShares® Equity Skew ETF, and LeaderShares®
                                            Dynamic Yield ETF

Dear Ms. Im-Tang:

This letter summarizes the comments you provided
on behalf of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) via telephone
on November 6, 2024, regarding Post-Effective Amendment No. 423 to the Registrant’s registration statement filed on Form N-1A on
September 20, 2024 (the “Registration Statement”), with respect to the LeaderShares® Activist Leaders®
ETF, LeaderShares® AlphaFactor® Tactical Focused ETF, LeaderShares® AlphaFactor®
US Core Equity ETF, LeaderShares® Equity Skew ETF, and LeaderShares® Dynamic Yield ETF, each a series
of the Registrant (each a “Fund” and collectively, the “Funds”).

Responses to all of the comments are included
below and, as appropriate, will be reflected in a Post- Effective Amendment to the Funds’ 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.

GENERAL

 1. Comment:
                                            Please provide the full name of each Fund, the date of the Prospectus, and the ticker symbol
                                            for each Fund. In future filings, please ensure that each Fund’s full name is provided.
                                            In addition, please provide this information in advance for the Staff’s review, as
                                            the Staff may have additional comments regarding the names and ticker symbols.

 Response:
                                            The Registrant acknowledges the Staff’s comment and will ensure that each Fund’s
                                            full name is included in future filings. The Funds’ full names and ticker symbols are
                                            as follows:

    Fund
    Name
    Ticker
    Symbol

    LeaderShares®
    Activist Leaders® ETF
    ACTV

    LeaderShares®
    AlphaFactor® Tactical Focused ETF
    LSAT

    LeaderShares®
    AlphaFactor® US Core Equity ETF
    LSAF

    LeaderShares®
    Equity Skew ETF
    SQEW

    LeaderShares®
    Dynamic Yield ETF
    DYLD

    1

 2. Comment:
                                            Each Fund references a “Predecessor Fund.” Please identify each Predecessor Fund
                                            and provide additional details (e.g., is this filing in connection with a reorganization
                                            of existing funds?).

 Response:
                                            The Registrant confirms that each Predecessor Fund listed in the table below, each a series
                                            of Two Roads Shared Trust, is expected to reorganize into the corresponding Fund listed in
                                            the table below (each a “Reorganization” and collectively, the “Reorganizations”).
                                            A combined proxy statement and prospectus will be filed on Form N-14 for the purpose of seeking
                                            shareholder approval of the Reorganization of each Predecessor Fund.

    Two Roads Shared
    Trust

    Investment
    Managers Series Trust II

    LeaderShares®
    Activist Leaders® ETF
    →
    LeaderShares®
    Activist Leaders® ETF

    LeaderShares®
    AlphaFactor® Tactical Focused ETF
    →
    LeaderShares®
    AlphaFactor Tactical Focused ETF

    LeaderShares®
    AlphaFactor® US Core Equity ETF
    →
    LeaderShares®
    AlphaFactor US Core Equity ETF

    LeaderShares®
    Equity Skew ETF
    →
    LeaderShares®
    Equity Skew ETF

    LeaderShares®
    Dynamic Yield ETF
    →
    LeaderShares®
    Dynamic Yield ETF

 3. Comment:
                                            Please confirm that the Prospectus and Statement of Additional Information for each Fund
                                            will not be used to offer shares to investors until after the applicable Reorganization is
                                            completed.

 Response:
                                            The Registrant so confirms.

PROSPECTUS

Fees and Expenses Table – All Funds

 4. Comment:
                                            Please provide the completed Fees and Expenses Table and Expense Example for each Fund at
                                            least five days prior to the Registration Statement becoming effective.

  Response:
                                            The completed Fees and Expenses Table and Expense Example for each Fund, which will be included
                                            in the Amendment, are disclosed in Appendix A.

 5. Comment:
                                            If a Fund’s investments in other registered investment
                                            companies and ETFs exceed 0.01% of the average net assets of the Fund, include an “Acquired
                                            Fund Fees and Expenses” line item to the Fund’s Fees and Expenses Table.

  Response:
                                            The Registrant confirms that the LeaderShares® Equity Skew ETF is the only
                                            Fund that is expected to have Acquired Fund Fees and Expenses that exceed 0.01% of the Fund’s
                                            average net assets, and that an Acquired Fund Fees and Expenses line item is included in
                                            the LeaderShares® Equity Skew ETF’s Fees and Expenses Table. No Acquired
                                            Fund Fees and Expenses line item has been added to the Fees and Expenses Tables for the other
                                            Funds.

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Performance – All Funds

 6. Comment:
                                            Under the Performance section for each Fund, please identify the Predecessor Fund and indicate
                                            that the Fund is adopting the performance of the Predecessor Fund as a result of the Reorganization.

  Response:
                                            The completed Performance section for each Fund, which will be included in the Amendment,
                                            is disclosed in Appendix B.

Expense Example – LeaderShares®
Activist Leaders® ETF

 7. Comment:
                                            The disclosure in the Expense Example section indicates that the Example reflects the Fund’s
                                            contractual fee waiver and/or expense reimbursement; however, the Fees and Expenses Table
                                            does not reflect any contractual fee waiver and/or expense reimbursement. If this statement
                                            is accurate, please adjust the Fees and Expenses Table to reflect the contractual fee waiver
                                            and/or expense reimbursement.

  Response:
                                            The Registrant confirms that the Fund does not have a contractual
                                            fee wavier and/or expense reimbursement, and the Registrant has revised the Expense Example
                                            disclosure as follows:

  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.

Principal Investment Strategies and Principal
Risks – LeaderShares® Activist Leaders® ETF

 8. Comment:
                                            In the Fund’s Principal Investment Strategies section, please specify or provide examples
                                            of the types of equity securities in which the Fund will invest and add corresponding risk
                                            disclosures, as applicable.

  Response:
                                            The Registrant has added the following to the Fund’s Principal Investment Strategies
                                            disclosure:

  The
                                            types of equity securities the Fund invests in include common and preferred stock.

In
addition, the Registrant has added the following to the Fund’s Principal Risks:

  Preferred
                                            Stock Risk. Preferred stock represents an equity interest
                                            in a company that generally entitles the holder to receive, in preference to the holders
                                            of other stocks such as common stock, dividends and a fixed share of the proceeds resulting
                                            from a liquidation of the company. The market value of preferred stock is subject to company-specific
                                            and market risks applicable generally to equity securities and is also sensitive to changes
                                            in the company’s creditworthiness, the ability of the company to make payments on the
                                            preferred stock, and changes in interest rates, typically declining in value if interest
                                            rates rise.

    3

 9. Comment:
                                            The first sentence of the second paragraph in the Fund’s Principal Investment Strategies
                                            section indicates that the Advisor “…identifies activist investors utilizing
                                            a proprietary methodology based upon qualitative elements, including the effectiveness of
                                            activists investors’ achievement of stated objectives and positive shareholder returns
                                            in positions that were disclosed in Schedule 13D filings.” Please clarify the purposes
                                            of evaluation of the activist investors’ achievement of stated objectives and positive
                                            shareholder returns. In addition, please provide additional details of criteria used to determine
                                            the activists’ achievement of stated objectives.

Response: The Registrant has
amended the Principal Investment Strategies section as follows:

The Fund is an actively managed exchange-traded
fund (“ETF”) that employs an investment approach that focuses on investing in equity securities of
issuers that are the target of shareholder activism. The types of equity securities the Fund invests in include common and
preferred stock. These equity securities are identified using a proprietary quantitative methodology that begins with tracking Schedule
13D filings that are submitted , which are required to be filed with the Securities and Exchange Commission (“SEC”).
Rules adopted under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), require a shareholder an
investor that acquires, with an activist intent, more than 5% of a company’s shares, to file a form with the SEC known
as a Schedule 13D that discloses the investor’s identity and purpose in acquiring those shares.

The Fund’s investment advisor,
Redwood Investment Management, LLC (the “Advisor”), identifies activist investors Activist Leaders®
investors utilizing a proprietary methodology based upon qualitative elements, including research into the effectiveness
of such companies involved in shareholder activism activist investors’ achievement of stated objectives
and the creation of positive shareholder returns in positions of companies that were the subject of a disclosed
in Schedule 13D filings by them.

The Advisor looks for Activist Leaders®
investors with: (i) at least 85 Schedule 13D filings, a majority of which have an activism mandate; (ii) 30 or more Schedule 13D filings
after 2018; and (iii) a minimum of five Schedule 13D filings per year. An Activist Leaders® investor is removed from the group if
its assets under management drops below $500 million or if such Activist Leaders® investor had no Schedule 13D filings within the
last calendar year. Because the Advisor’s identification of Activist Leaders® investors is based on ongoing research, the
list of Activist Leaders® investors may change over time.

The Fund typically invests in equity
securities of U.S. and foreign companies listed on U.S. exchanges with market capitalizations of at least $1 billion
at the time of initial purchase. The Fund may, from time to time, focus its investments in a particular sector (including the information
technology sector), industry or group of industries. The Fund may engage in active and frequent trading.

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 10. Comment:
                                            The Fund’s Principal Investment Strategies disclosure indicates that the Fund may,
                                            from time to time, focus in particular sectors, including the information technology sector.
                                            Please identify the sectors in which the Fund may focus and add corresponding risk disclosures.

Response:
The Registrant has received confirmation from the Advisor that the Fund may, from time to time, focus in the information technology sector.
The Registrant has added the following bullet point under “Sector Focus Risk”:

 · Information
                                            Technology Sector Risk. Factors such as the failure to obtain, or delays
                                            in obtaining, financing or regulatory approval, intense competition, product compatibility,
                                            consumer preferences, corporate capital expenditure, rapid obsolescence, competition
                                            from alternative technologies, and research and development of new products may significantly
                                            affect the market value of securities of issuers in the information technology sector.

Principal Investment Strategies and Principal Risks – LeaderShares®
AlphaFactor® Tactical Focused ETF

 11. Comment:
                                            In the Fund’s Principal Investment Strategies section, please specify or provide examples
                                            of the types of equity securities in which the Fund will invest and add corresponding risk
                                            disclosures, as applicable.

Response:
The Registran