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 INVESTMENT MANAGERS SERIES TRUST II

 235 W. Galena Street

 Milwaukee, Wisconsin 53212

 VIA EDGAR

 July 18, 2025

 Ms. Mindy Rotter, Esq., CPA

 Ms. Soo Im-Tang

 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")

 Registration Statement on Form N-14
(File No. 333-287935)

 Dear Ms. Rotter
and Ms. Im-Tang:

 This letter summarizes the comments provided
to me by Ms. Rotter of the staff (the "Staff") of the U.S. Securities and Exchange Commission (the "Commission")
by telephone on July 1, 2025, and by Ms. Im-Tang of the Staff of the Commission by telephone on July 8, 2025 on the Registrant's
registration statement filed on Form N-14 (the "Registration Statement") relating to the proposed reorganization 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 (each, a "Target Fund" and together, the "Target Funds"),
each a series of Two Roads Shared Trust, into 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, an "Acquiring Fund" and together, the "Acquiring
Funds"), respectively, each a new series of the Registrant. This combined proxy statement/prospectus is referred to below as the
"Proxy Statement." The Target Funds and the Acquiring Funds are collectively referred to herein as the "Funds."

 Responses to all of the comments are included
below and, as appropriate, will be incorporated into a pre-effective amendment to the 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.

 Accounting
Comments

 1. Please confirm in correspondence that
 the semi-annual financial information will be updated in the Amendment and all applicable
 sections and hyperlinks will be updated. In addition, please confirm that an updated auditor
 consent will be provided.

 Response : The Registrant confirms
that the semi-annual financial information and all applicable sections and hyperlinks will be updated in the Amendment. In addition,
the Registrant confirms that the Amendment will contain an updated auditor consent.

 2. Please update the fees to represent current
 fees in accordance with Item 3 in Form N-14.

 Response : The Registrant has
updated the fees and expenses tables to reflect information as of April 30, 2025. The Registrant believes that the fees presented in
the fee tables represent current fees, as required by Item 3(a) of Form N-14. Please see the revised fee tables in Appendix A
attached hereto.

 3. Please consider updating the capitalization
 table to reflect data from within 30 days of the filing of the Amendment or alternatively,
 confirm in correspondence that there have been no material changes to the capitalization
 table since the date reflected in the table.

 Response : The Registrant has
updated the capitalization tables to reflect data as of June 30, 2025, and confirms that the updated capitalization tables will be included
in the Amendment. Please see the revised capitalization tables in Appendix B attached hereto.

 Legal Comments

 4. In the Dear Shareholder letter included
 in the Proxy Statement, it states "[t]he Reorganizations are not expected to result
 in any increases in shareholder fees or expenses." Please clarify in the disclosure
 if there will be any increase and if so, explain the increase.

 Response : The Registrant has
added the following disclosure:

 Both the Target Funds and the Acquiring
Funds operate under a unitary fee contract structure whereby each Fund pays Redwood a management fee and Redwood has agreed to pay all
operating expenses incurred by the Fund, except for the management fee and certain other expenses. The management fee for each Target
Fund and the corresponding Acquiring Fund are the same. Following the Reorganizations, the overall operating expenses incurred by each
Acquiring Fund and paid by Redwood are expected to be lower than the current operating expenses incurred by the corresponding Target
Fund and paid by Redwood.

 5. In the Dear Shareholder letter included
 in the Proxy Statement, it states "[after careful consideration, for the reasons discussed
 in the attached Proxy Statement/Prospectus, and based on the recommendation of the Target
 Funds' investment adviser, Redwood, as well as in reliance upon certain representations
 and commitments made by Redwood to the Board, the Board has approved the Reorganizations
 and the solicitation of the Target Funds' shareholders with respect to the Reorganization
 Agreement." Please add the Board unanimously approved the Reorganizations to be consistent
 with disclosure contained in the Proxy Statement.

 Response : The Registrant has
revised the disclosure as follows:

 After careful consideration, for the
reasons discussed in the attached Proxy Statement/Prospectus, and based on the recommendation of the Target Funds' investment adviser,
Redwood, as well as in reliance upon certain representations and commitments made by Redwood to the Board, the Board has unanimously
approved the Reorganizations and the solicitation of the Target Funds' shareholders with respect to the Reorganization Agreement.

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 6. Please add disclosure to the Dear Shareholder
 letter to indicate that the Board, including the independent trustees, unanimously recommends
 that shareholder of each Target Fund approve the Reorganization Agreement and the Reorganization.

 Response : The Registrant acknowledges
the Staff's comment and respectfully declines to add the requested disclosure. The Registrant believes that the current disclosure
is appropriate.

 7. In the Notice of Special Meeting of Shareholders,
 please define June 16, 2025, as the "Record Date."

 Response : The Registrant has
revised the disclosure as follows:

 Only shareholders of record of the
Target Funds at the close of business on June 16, 2025 (the "Record Date") , the record date for this Special Meeting,
will be entitled to notice of, and to vote at, the Special Meeting or any postponements or continuations after an adjournment thereof.

 8. In the Question and Answer regarding
 " How will each Reorganization work? ", please clarify that immediately
 after the Reorganization each shareholder of the Target Fund will hold a number of full shares
 of the Acquiring Fund equal in aggregate net asset value at the time of the exchange to the
 aggregate net asset value of such shareholder's shares of the Target Fund immediately
 prior to the Reorganization.

 Response : The Registrant has
revised the disclosure as follows:

 Shareholders of the Target Fund will
become shareholders of the Acquiring Fund, and immediately after the Reorganization each such shareholder will hold a number of shares
of the Acquiring Fund equal in aggregate net asset value at the time of the exchange to the aggregate net asset value of
such shareholder's shares of the Target Fund immediately prior to the Reorganization.

 9. In the Question and Answer regarding
 " Who is paying for expenses related to the Special Meeting and the Reorganizations? "
 please add disclosure that Redwood or any affiliate will bear the costs and expenses incurred
 in connection with the Reorganizations whether or not the Reorganizations are consummated.
 Additionally, please disclose the estimated direct expenses to be incurred by Redwood.

 Response : The Registrant confirms that the estimated direct expenses to be incurred by Redwood will be included in the definitive Proxy Statement.

 10. In the Question and Answer regarding
 " How do I cast my vote? " please add disclosure that a proxy solicitor
 is to be used, as well as their contract and their costs.

 Response : The Registrant has
added the following disclosure:

 Redwood has engaged Sodali &
Co. to provide shareholder meeting services, including the distribution of this Proxy Statement and related materials to shareholders
as well as assist the Target Funds in soliciting proxies for the Special Meeting at an anticipated cost of approximately $29,494 .

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 11. Under "Comparison of Investment
 Restrictions" please specify which fundamental investment policy applies to which Fund
 or make clear that the policies apply to all Funds.

 Response : The Registrant has
revised the disclosure as follows:

 The fundamental and non-fundamental
investment limitations for each Target Fund of the Target Funds and for each the Acquiring
Fund s are set forth in the following table.

 12. In the table of the comparison of non-fundamental
 investment restrictions please specify which non-fundamental investment policy apply to which
 Fund or make clear that the policies apply to all Funds.

 Response : The Registrant has
revised the disclosure as follows:

 The Funds observe the following
non-fundamental investment restrictions applicable to each Target Fund and each Acquiring Fund are set forth in the following table .

 13. Under "Background and Trustees'
 Considerations Relating to the Proposed Reorganization", please clarify why the Board
 considered the Reorganization in the first place (i.e., were the Funds losing assets or were
 there other issues?). Did the Board consider the Funds' performance? If so, please
 add disclosure to the discussion.

 Response : The Registrant confirms
that the Board initially considered the Reorganization due to a proposal from Redwood, the adviser of each Target Fund and proposed adviser
of each Acquiring Fund, that the Target Funds be reconstituted as series of IMST II. The Registrant notes this is disclosed in the first
sentence of the section, "Background and Trustees' Considerations Relating to the Proposed Reorganization" and considers
the current disclosure to be sufficient as it also includes a discussion of the Adviser's rationale for the Reorganizations. The
Registrant also notes that the current disclosure states that the Board considered the historical performance of each Target Fund in
determining whether to approve the Reorganization.

 14. In the sentence which reads, "[i]n
 reaching its decision to approve the Reorganizations, the Board concluded, in reliance upon
 the representations and commitments by Redwood to the Board, including with respect to actions
 taken or to be taken by Redwood, that the participation of the Target Funds in the Reorganizations
 is in the best interests of each Target Fund and that the interests of existing shareholders
 of each Target Fund would not be diluted as a result of the Reorganization", please
 consider whether it would be appropriate to disclose such representations and commitments
 here.

 Response : The Registrant has
revised the disclosure as follows:

 In reaching its decision to approve
the Reorganizations, the Board concluded, in reliance upon the representations and commitments by Redwood to the Board, including with
respect to actions taken or to be taken by Redwood, which include but were not limited to certain changes and enhancements to Redwood's
compliance program, that the participation of the Target Funds in the Reorganizations is in the best interests of each Target Fund
and that the interests of existing shareholders of each Target Fund would not be diluted as a result of the Reorganization.

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 15. In the disclosure regarding certain
 matters considered by the Board, please consider adding disclosure regarding any potential
 drawbacks or risks associated with the Reorganization to balance the disclosure regarding
 the expected benefits of the Reorganization.

 Response : The Registrant has
considered the Staff's comment and has determined that the current disclosure is appropriate.

 16. In the disclosure regarding certain
 matters considered by the Board, it states that the Board considered possible alternatives
 to the Reorganization, including liquidation. Please clarify why the Board considered liquidation
 should the Reorganizations not be approved.

 Response : The Registrant confirms
that the Board considered liquidation, among other possible alternatives, in the normal course of business of considering the Reorganization.

 17. In the capitalization table, please
 confirm that the information is consistent with the most current pro forma financial statements.
 Please ensure that any adjustments are reflected in a footnote to the capitalization table.

 Response : The Registrant has
updated the capitalization tables and confirms that the information is consistent with the most current pro forma financial statements.
The Registrant further confirms that the adjustments are reflected in a footnote to the capitalization table. Please see the revised
capitalization tables in Appendix B attached hereto.

 18. IMST II has six trustees, two of whom
 are considered "interested persons" as that term is defined under the 1940 Act.
 Please explain how the IMST II board satisfies the conditions of Section 15(f).

 Response : The Registrant confirms
the IMST II board currently satisfies the relevant provision of Section 15(f). In particular, Section 15(f) requires that,
during the three-year period following the transaction, at least 75% of the Fund's board of trustees must not be "interested
persons" of the investment adviser or predecessor investment adviser within the meaning of Section 2(a)(19) of the 1940 Act.
None of the IMST II trustees are "interested persons" of Redwood, the Funds' investment adviser.

 19. Under "Effect of Abstentions and
 Broker ‘Non-Votes'", please revise the disclosure to describe that broker
 non-votes will not be counted as votes present or as votes cast at the meeting.

 Response : The Registrant has
revised the disclosure as follows:

 For purposes of determining the presence of a quorum for transacting business at the Special Meeting, all proxies voted, including abstentions,
will be counted toward establishing a quorum. Because the proposal is expected to "affect substantially" a shareholder's
rights or privileges, a broker may not vote shares if the broker has not received instructions from beneficial owners or persons entitled
to vote, even if the broker has discretionary voting power (i.e., the proposal is non-discretionary). Because the proposal is non-discretionary,
the Trust does not expect to receive broker non-votes. Any broker non-votes received, however, will not be counted as votes present
at the Special Meeting for purposes of determining quorum or as votes cast at the Special Meeting.

 Assuming the presence of a quorum,
abstentions and broker "non-votes" will have the effect of votes against the proposal. Abstentions will
have no effect on the outcome of a vote on adjournment.

 * * * * *

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

 The Registrant intends to file the Amendment
on July 18, 2025 and seek acceleration of the Amendment to July 21, 2025.

 /s/ Diane J. Drake

 Diane J. Drake

 Secretary

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 Appendix A

 The following shows the fees and expenses for
each Target Fund as of April 30, 2025. Only pro forma information is provided for each Acquiring Fund because each Acquiring Fund will
not commence operations until the applicable Reorganization is completed, and the pro forma information is based on the average net assets
of the corresponding Target Fund as of April 30, 2025. Each Acquiring Fund and Target Fund operates under a unitary fee contract structure.
In a unitary fee contract structure, each Fund pays the adv