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        1900 K Street, NW

        Washington, DC 20006-1110

        +1 202 261 3300 Main

        +1 202 261 3333 Fax

        www.dechert.com

        Adam T. Teufel

        adam.teufel@dechert.com

        +1 202 261 3464 Direct

        +1 202 261 3164 Fax

January 17, 2020

VIA EDGAR
CORRESPONDENCE

Scott Lee

Sumeera Younis

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549-4644

 Re: Lattice Strategies Trust (the “Registrant”) (SEC File Nos. 333-199089 and 811-23002)

Dear Mr. Lee and Ms. Younis:

We are writing in response to comments
Ms. Younis provided telephonically to Alexander C. Karampatsos and Christopher Dotson on December 30, 2019 with respect to Post-Effective
Amendment No. 15 to the Registrant’s registration statement, filed on November 15, 2019, relating to the Hartford Multifactor
ETFs. We have reproduced your comments below and immediately thereafter have provided the Registrant’s responses or described
how the Registrant will address your comments in a post-effective amendment to the Registration Statement to be filed pursuant
to Rule 485(b) under the Securities Act of 1933, as amended. Capitalized terms have the meanings attributed to such terms in the
Post-Effective Amendment.

 1. Comment: We remind you that the Registrant and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Response: The Registrant
acknowledges this comment.

 2. Comment: Does the Registrant anticipate operating each Fund pursuant to new Rule
                                                          6c-11 (“New ETF Rule”) under the Investment Company Act of 1940, as amended (“1940 Act”), upon the
                                                          compliance date of the New ETF Rule?

Response: The Registrant
anticipates operating each Fund pursuant to the New ETF Rule prior to the rescission of its 1940 Act ETF exemptive relief in December
2020.

 3. Comment: The investment objective of each Fund states, in part, that the “Fund seeks
to provide investment results that, before fees and expenses, correspond to the total return performance of an index. . . .”
The staff prefers the use of “correlate” or “track” instead of “correspond.”

Response: The Registrant
acknowledges the staff’s preference but notes that the use of “correspond” is consistent with the Registrant’s
1940 Act ETF exemptive relief and with the wording of each Fund’s investment objective since inception. Accordingly, the
Registrant respectfully declines to make any changes in response to this comment.

 4. Comment: Please provide supplementally a completed Annual Fund Operating Expenses table
and Expense Example for each Fund.

Response: The completed
Expense Examples and Annual Fund Operating Expense tables for the Funds are included in Appendix I attached hereto.

 5. Comment: If a Fund has a portfolio turnover rate of over 100% within its last fiscal year,
please ensure that there is a corresponding principal risk.

Response: The Registrant
notes that each Fund had a portfolio turnover rate of less than 100% during its last fiscal year. Accordingly, the Registrant believes
it is unnecessary to make any changes in response to this comment.

 6. Comment: The principal investment strategy section for Hartford Multifactor Developed Markets
(ex-US) ETF states that the Fund’s Index seeks to have “up to 15% less volatility” and that the principal investment
strategy section for each other Fund, except the Hartford Multifactor REIT ETF, has similar disclosure. Please consider revising
the disclosure to clarify how the specific baseline volatility is measured and how the Index seeks to reduce volatility.

Response: The Registrant
confirms that it will revise the disclosure in response to this comment.

 7. Comment: The principal investment strategy section for Hartford Multifactor Developed Markets
(ex-US) ETF states that “Risk-Optimized refers to the approach Lattice Strategies LLC (‘Lattice’ or the ‘Adviser’)
takes in the development and management of the Index. . . The Index is calculated and distributed by Solactive AG.” In this
section and the principal investment strategy section for each other Fund, as applicable, please consider clarifying the relationship
between Lattice and Solactive AG in calculating and maintaining each Fund’s Index.

Response: As disclosed
in the principal investment strategy section for each Fund, each “Index is sponsored by Lattice. Lattice determines the composition
and relative weightings of the securities in the Index and publishes information regarding the market value of the Index. The Index
is calculated and distributed by Solactive AG.” As disclosed in the SAI, “Lattice, as the index provider, is responsible
for the methodology and selection of the index components. Solactive AG, as index calculation agent, calculates price and total
return indices.” The Registrant believes that the prospectus and SAI sufficiently disclose that each Index is maintained
by Lattice and calculated and administered by Solactive AG. Accordingly, the Registrant respectfully declines to make any changes
in response to this comment.

 8. Comment: Please provide supplementally the methodology rule book for each Index.

Response: The methodology
rule book for each Index is attached hereto as Appendix II.

 9. Comment: The principal investment strategy section for each of Hartford Multifactor Developed
Markets (ex-US) ETF, Hartford Multifactor Diversified International ETF, and Hartford Multifactor Small Cap ETF states that
the Index employs an approach that seeks to address “active risks versus the cap-weighted universe.” Please consider
revising the aforementioned principal investment strategy sections to clarify what is meant by “active risks versus the cap-weighted
universe” and also provide any changes supplementally.

Response: The Registrant
confirms that it will revise the disclosure consistent with this comment as shown below.

The Index is built with a rules-based,
proprietary methodology that employs a multi-layered risk-controlled approach that seeks to address active risks
associated with versus the cap-weighted universe, accounting for size, country, liquidity and volatility
risks.

 10. Comment: The principal investment strategy section for each of Hartford Multifactor Developed
Markets (ex-US) ETF, Hartford Multifactor Diversified International ETF, Hartford Multifactor REIT ETF, and Hartford Multifactor
Small Cap ETF refers to “risk premium factors” or “risk premium profiles.” Please consider revising the
aforementioned principal investment strategy sections to clarify what is meant by “risk premium factors” and “risk
premium profiles” and also provide any changes supplementally.

Response: The Registrant
confirms that it will revise the disclosure consistent with this comment. For example, the Registrant will revise the disclosure
in the principal investment strategy section for the Hartford Multifactor Developed Markets (ex-US) ETF as shown below.

Specifically, the Index seeks to
de-concentrate individual country and currency risks while emphasizing companies that exhibit persistent risk premium factors,
including but not limited to, quality, momentum, and value.

 11. Comment: The principal investment strategy section of each Fund states that “[t]he
Index was established with a base value of 1,000. . . .” Please revise the disclosure to indicate the unit that corresponds
to the 1,000 figure.

Response: The Registrant
respectfully notes that the Indexes are not measured by any specified units. The Registrant notes that each Index was initially
set at a positive base number and that changes to the Index’s value are meant to reflect the returns of the Index rather
than any change in any units of measurement. The Registrant notes that this approach is consistent with the approach taken by other
indices in the industry (e.g., the S&P 500 Index). Accordingly, the Registrant respectfully declines to make any changes
in response to this comment.

 12. Comment: Each Fund’s principal investment strategy section states that “[u]nlike
many investment companies, the Fund does not try to ‘beat’ the index it tracks. . . .” The staff notes that other
funds that track an index typically do not try to “beat” the index they track. Please consider deleting or revising
the reference to “[u]nlike many investment companies”.

Response: The Registrant
confirms that it will revise the disclosure consistent with this comment by deleting the reference to “[u]nlike many investment
companies”.

 13. Comment: The performance section of each Fund includes multiples indexes. Please include
narrative disclosure regarding each additional index pursuant to Instruction 2(b) to Item 4(b)(2) of Form N-1A. Please also consider
moving each Fund’s additional index (i.e. the Russell or MSCI Index) before the Fund’s proprietary custom benchmark
index.

Response: The Registrant
respectfully notes that it refers to each additional index in its narrative disclosure as “another broad measure of market
performance” in accordance with Instruction 2(b) to Item 4(b)(2) of Form N-1A. The Registrant takes the view that each Fund’s
custom benchmark index qualifies as an “appropriate broad-based securities market index” within the meaning of Form
N-1A. The Registrant believes that the placement of each Fund’s custom benchmark index adjacent to the Fund’s returns
provides investors with a clear basis for evaluating the Fund’s performance and risks relative to an appropriate broad-based
securities market index, consistent with the requirements of Form N-1A. Accordingly, the Registrant respectfully declines to make
any changes in response to this comment.

 14. Comment: Each Fund’s principal investment strategy section makes reference to “[e]ach
strategy index developed by Lattice. . . .” Please revise each Fund’s principal investment strategy section to discuss
the Index that the Fund tracks and to remove references to other indexes.

Response: The Registrant
confirms that it will revise the disclosure consistent with this comment.

 15. Comment: Each Fund’s principal investment strategy section states that Lattice “seeks
to address identified risks within its asset class” and then provides a list of examples of certain risks. Please revise
this list so that it is an exhaustive list of such risks or clarify that this list is not exhaustive.

Response: The Registrant
respectfully notes that the use of the phrase “[f]or example” at the beginning of the sentence, as well as “and
other unmanaged risk factors” in the middle of the sentence, that contains the list of such risks indicates that the list
is not exhaustive. Accordingly, the Registrant respectfully declines to make any changes in response to this comment.

 16. Comment: The staff notes that for each Fund that has undergone a name change since its last
annual update filing, the prior name of such Fund should be placed under the Fund’s current name on the cover page and in
summary sections for each such Fund.

Response: The Registrant
respectfully notes that for the two Funds that underwent name changes since the Funds’ last annual update filing, the prior
name is placed under the current name on the cover page and in the summary sections for each such Fund. Accordingly, the Registrant
respectfully declines to make any changes in response to this comment.

 17. Comment: The staff notes that the Registrant discloses “liquidity risk” as sub-risk
in the “Additional Information Regarding Investment Strategies and Risks” section of the Prospectus. Please consider
adding liquidity risk as a principal risk for each Fund.

Response: The Registrant
does not believe that liquidity risk, on its own, is a principal risk of the Funds. The Registrant respectfully notes that its
Prospectus sufficiently discloses the risks associated with liquidity risk in the “Additional Information Regarding Investment
Strategies and Risks” section of the Prospectus. Accordingly, the Registrant respectfully declines to make any changes in
response to this comment.

 18. Comment: The “Performance Notes” section states that “each Fund may
measure its performance and that of its proprietary custom benchmark against a broad-based measure of market performance.”
The staff notes that each Fund in fact does do so. Please revise this discloses to indicate that each Fund will measure
its performance and that of its proprietary custom benchmark against a broad-based measure of market performance.

Response: The Registrant
confirms that it will revise the disclosure consistent with this comment.

Should you
have any questions, please feel free to contact me at (202) 261-3464.

    Sincerely,

    /s/ Adam T. Teufel

    Adam T. Teufel

 

Appendix I

Hartford Multifactor Developed Markets (ex-US) ETF

ANNUAL FUND OPERATING EXPENSES (expenses that you
pay each year as a percentage of the value of your investment):

    Management fees
      0.29 %

    Distribution and service (12b-1) fees
      None

    Other expenses
      0.00 %

    Total annual fund operating expenses
      0.29 %

EXAMPLE: The examples below are
intended to help you compare the cost of investing in the Fund with the cost of investing in other exchange-traded funds. The examples
assume that:

 · Your investment has a 5% return each year

 · The Fund’s operating expenses remain the same

Your actual costs may be higher or lower. Based on these assumptions,
for every $10,000 invested, you would pay the following expenses if you sell all of your shares at the end of each time period
indicated:

    Year 1
    Year 3
    Year 5
    Year 10

    $ 30
    $ 93
    $ 163
    $ 368

Hartford Multifactor Diversified International ETF

ANNUAL FUND OPERATING EXPENSES
(expenses that you pay each year as a percentage of the value of your investment):

    Management fees
      0.29 %

    Distribution and service (12b-1) fees
      None

    Other expenses
      0.00 %

    Total annual fund operating expenses
      0.29 %

EXAMPLE: The examples below are
intended to help you compare the cost of investing in the Fund with the cost of investing in other exchange-traded funds. The examples
assume that:

 · Your investment has a 5% return each year

 · The Fund’s operating expenses remain the same

Your actual costs may be higher or lower. Based on these assumptions,
for every $10,000 invested, you would pay the following expenses if you sell all of your shares at the end of each time period
indicated:

    Year 1
    Year 3
    Year 5
    Year 10

    $ 30
    $ 93
    $ 163
    $ 368

Hartford Multifactor Emerging Markets ETF

ANNUAL FUND OPERATING EXPENSES (expenses that you
pay each year as a percentage of the value of your investment):

    Management fees(1)
      0.44 %

    Distribution and service (12b-1) fees
      None

    Other expenses
      0.00 %

    Total annual fund operating expenses(2)
      0.44 %

 (1) “Management fees” have been restated to reflect current fees.

 (2) “Total annual fund operating expenses” do not correlate to the ratio of expenses to average net assets that is
disclosed in the Fund’s annual report in the financial highlights table, which reflects the operating expenses of the Fund
and does not include the restated “Management Fees.”

EXAMPLE: The examples below are
intended to help you compare the cost of investing in the Fund with the cost of investing in other exchange-traded funds. The examples
assume that:

 · Your investment has a 5% return each year

 · The Fund’s operating expenses remain the same

Your actual costs may be higher or lower. Based on these assumptions,
for every $10,000 invested, you would pay the following expenses if you sell all of your shares at the end of each time period
indicated:

    Year 1
    Year 3
    Year 5