SecProbe.io

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INVESTMENT MANAGERS SERIES TRUST II

235 W. Galena Street

Milwaukee, Wisconsin 53212

VIA EDGAR

January 9, 2026

Ms. Deborah O’Neal

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 Tradr 2X Long ARQQ Daily ETF, Tradr 2X Long BETR Daily ETF, Tradr 2X Long
BKKT Daily ETF, Tradr 2X Long CRML Daily ETF, Tradr 2X Long EH Daily ETF, Tradr 2X Long EVEX Daily ETF, Tradr 2X Long FRMI Daily ETF,
Tradr 2X Long INOD Daily ETF, Tradr 2X Long IOT Daily ETF, Tradr 2X Long KDK Daily ETF, Tradr 2X Long LAC Daily ETF, Tradr 2X Long NTSK
Daily ETF, Tradr 2X Long ONDS Daily ETF, Tradr 2X Long PATH Daily ETF, Tradr 2X Long QURE Daily ETF, Tradr 2X Long RZLV Daily ETF, Tradr
2X Long SHLS Daily ETF, Tradr 2X Long SNAP Daily ETF, Tradr 2X Long USAR Daily ETF and Tradr 2X Long WDC Daily ETF

Dear Ms. O’Neal:

This letter
summarizes the comments you provided on behalf of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the
“SEC”) on December 8, 2025, regarding Post-Effective Amendment No. 470 to the Registrant’s registration statement filed
on Form N-1A on October 28, 2025 (the “Registration Statement”), with respect to the Tradr 2X Long ARQQ Daily ETF, Tradr 2X
Long BETR Daily ETF, Tradr 2X Long BKKT Daily ETF, Tradr 2X Long CRML Daily ETF, Tradr 2X Long EH Daily ETF, Tradr 2X Long EVEX Daily
ETF, Tradr 2X Long FRMI Daily ETF, Tradr 2X Long INOD Daily ETF, Tradr 2X Long IOT Daily ETF, Tradr 2X Long KDK Daily ETF, Tradr 2X Long
LAC Daily ETF, Tradr 2X Long NTSK Daily ETF, Tradr 2X Long ONDS Daily ETF, Tradr 2X Long PATH Daily ETF, Tradr 2X Long QURE Daily ETF,
Tradr 2X Long RZLV Daily ETF, Tradr 2X Long SHLS Daily ETF, Tradr 2X Long SNAP Daily ETF, Tradr 2X Long USAR Daily ETF and Tradr 2X Long
WDC Daily ETF, each a series of the Registrant (each, a “Fund” and collectively, the “Funds”).

Responses to 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.

PROSPECTUS

 1. Comment: On page 2 of the Prospectus, the second sentence
of the last paragraph states “[a]s a consequence, if a Fund’s underlying security moves more than 50% (for a Fund seeking
two times daily performance) on a given trading day in a direction adverse to the Fund, the Fund’s investors would lose all of
their money.” Please confirm if the disclosure contained in the parenthetical should be there.

Response:
The Registrant has deleted the parenthetical.

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Principal Investment Strategies – All
Funds

 2. Comment: The disclosure in the principal investment
strategies refers to the underlying security in some instances and the ticker symbol in other instances. Please revise the disclosure
so that it refers to the company’s ticker symbol to avoid confusion.

Response: The
Registrant has revised the disclosure to reflect the ticker symbol where appropriate.

 3. Comment: With respect to the disclosure regarding
the Fund being concentrated in the industry assigned to the underlying security, please add the underlying security’s industry.

Response: The Registrant has
made the requested revisions.

Principal Risks – All Funds

 4. Comment: Please add “or shorter” to the
second sentence under “Compounding Risk.”

Response: The Registrant has
revised the disclosure as follows:

The performance of the Fund for periods
longer or shorter than a single day will very likely differ in amount, and possibly even direction, from 200% of the daily return
of the underlying security for the same period, before accounting for fees and expenses.

 5. Comment: Please ensure that all principal risks have
corresponding disclosure in the principal investment strategies. For example, each Fund has “Portfolio Turnover” as a principal
risk, however, there is no disclosure regarding frequent and active trading in the Funds’ principal investment strategies. Please
reconcile.

Response: The Registrant has
made the requested revisions.

STATEMENT OF ADDITIONAL INFORMATION

 6. Comment: In the table below the third fundamental
investment policy in the Investment Restrictions section of the SAI, please identify the industry of each Underlying Security.

Response: The Registrant respectfully
declines to make the requested revisions, as the fundamental investment policy cannot be changed without a shareholder vote and the Registrant
has no control over what industry an Underlying Security is assigned to or whether that industry may change in the future. The Registrant
has combined the table listing each Fund and its Underlying Security with the separate table listing each Underlying Security and its
industry, and has included that combined table and the following introductory sentence immediately after the Funds’ non-fundamental
policies:

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As of the date of this SAI, each Underlying
Security referenced in the third fundamental policy listed above is assigned to the corresponding industry listed in the table below (which
may change from time to time as determined pursuant to the Standard Industrial Classification (SIC) Code that appears on the EDGAR page
of the Underlying Security or pursuant to another established industry classification framework):

    Fund
    Underlying Security
    Industry of Underlying Security

    Tradr 2X Long ARQQ Daily ETF
    Arqit Quantum Inc.
    Computer Software – Prepackaged Software

    Tradr 2X Long BETR Daily ETF
    Better Home & Finance Holding Co.
    Finance – Consumer Services

    Tradr 2X Long BKKT Daily ETF
    Bakkt Holdings, Inc.
    Finance Services

    Tradr 2X Long CRML Daily ETF
    Critical Metals Corp.
    Metal Mining

    Tradr 2X Long EH Daily ETF
    EHang Holdings Ltd.
    Aerospace

    Tradr 2X Long EVEX Daily ETF
    Eve Holding, Inc.
    Aerospace & Defense

    Tradr 2X Long FRMI Daily ETF
    Fermi Inc.
    Real Estate Investment Trust

    Tradr 2X Long INOD Daily ETF
    Innodata Inc.
    Information Technology Services

    Tradr 2X Long IOT Daily ETF
    Samsara Inc.
    Software – Infrastructure

    Tradr 2X Long KDK Daily ETF
    Kodiak AI, Inc.
    Automobiles & Components

    Tradr 2X Long LAC Daily ETF
    Lithium Americas Corp.
    Metal Mining

    Tradr 2X Long NTSK Daily ETF
    Netskope Inc.
    Computer Software – Prepackaged Software

    Tradr 2X Long ONDS Daily ETF
    Ondas Holdings Inc.
     Communications Equipment

    Tradr 2X Long PATH Daily ETF
    UiPath, Inc.
    Computer Software – Prepackaged Software

    Tradr 2X Long QURE Daily ETF
    uniQure N.V.
    Biotechnology – Pharmaceutical Preparations

    Tradr 2X Long RZLV Daily ETF
    Rezolve AI PLC
    Computer Software – Computer Programming, Data Processing

    Tradr 2X Long SHLS Daily ETF
    Shoals Technologies Group, Inc.
    Semiconductor

    Tradr 2X Long SNAP Daily ETF
    Snap Inc.
    Internet Content & Information

    Tradr 2X Long USAR Daily ETF
    USA Rare Earth, Inc.
    Metal Mining

    Tradr 2X Long WDC Daily ETF
    Western Digital Corp.
    Electronic Components

* * * * *

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The Registrant notes that it does not intend to
seek effectiveness for the Tradr 2X Long CIFR Daily ETF and the Tradr 2X Long KVUE Daily ETF contained in PEA 470 and those funds will
be marked inactive on EDGAR.

The Registrant believes that it has fully responded
to the comments. If, however, you have any further questions, 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

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