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United States securities and exchange commission logo

                             January 18, 2024

       Matthew J. Bromberg
       Chief Executive Officer
       ETF Managers Group Commodity Trust I
       350 Springfield Avenue, Suite 200
       Summit, NJ 07901

                                                        Re: ETF Managers Group
Commodity Trust I
                                                            Post-Effective
Amendment No. 1 to Registration Statement on Form S-1
                                                            Filed January 5,
2024
                                                            File No. 333-266945

       Dear Matthew J. Bromberg:

                                                        We have reviewed your
post-effective amendment and have the following comments.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe a comment applies to your
facts and circumstances
       or do not believe an amendment is appropriate, please tell us why in
your response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to this letter, we may have additional comments.

       Post-Effective Amendment No. 1 to Registration Statement on Form S-1

       General

   1.                                                   Please revise your
disclosures throughout the filing to clarify whether the replacement of
                                                        the Sponsor has taken
place yet and the date that the Sponsor replacement has been, or
                                                        will be, effectuated.
In this regard, please revise to address the following points:
                                                            We note that you
have included bracketed dates indicating the date on which the
                                                             Sponsor
replacement occurred. See the prospectus cover page and page 1 of the
                                                             prospectus
summary. To the extent that the Sponsor replacement has been
                                                             effectuated,
please revise to complete the bracketed dates.
                                                            Alternatively, to
the extent that the Sponsor replacement has not occurred yet, please
                                                             clarify the date
on which you expect the replacement will occur, including whether
                                                             the replacement
will occur prior to the effectiveness of this post-effective
                                                             amendment. In this
regard, on one hand, we note that: (i) on the facing page you
                                                             include ETF
Managers Capital LLC ("ETFMC") as an agent for service and the
                                                             address of ETFMC
as the address of your principal executive office, (ii) the signature
 Matthew J. Bromberg
ETF Managers Group Commodity Trust I
January 18, 2024
Page 2
           page identifies ETFMC as the Sponsor, and (iii) on December 28, 2023
you filed a
           Rule 424(b)(3) prospectus disclosing that "[i]t is expected that the
Sponsor
           Replacement will occur during the first quarter of 2024, subject to
certain conditions,
           including, but not limited to, a post-effective amendment to the
Fund   s registration
           statement being declared effective by the SEC." On the other hand,
we note that your
           disclosure throughout the filing refers to ETFMC as the "Former
Sponsor."

      Please revise to clarify or reconcile your disclosures, as appropriate.
2.    Please revise throughout your filing to ensure that you correctly
reference the name of the
      Trust of which the Fund is a series. In this regard, the facing page of
this registration
      statement identifies the Trust as    ETF Managers Group Commodity Trust
I,    while the
      prospectus cover page identifies the Trust as    Amplify Commodity Trust.
   Please revise
      to clarify or reconcile your disclosure, as appropriate.
3.    We note that on December 28, 2023, you filed a Form 8-K disclosing that
ETF Managers
      Capital LLC, as the sponsor of the Trust, entered into an agreement to
resign as sponsor to
      the Trust and transfer its role as the sponsor to Amplify Investments
LLC. In an
      appropriate section, please revise to discuss the material terms of this
agreement and file it
      as an exhibit to the registration statement.
4.    Please complete and update all information that is currently in brackets
or missing in the
      filing, including exhibits.
Prospectus Summary, page 1

5.    Please revise the prospectus summary to disclose, consistent with the
fourth risk factor on
      page 16, that the Sponsor has no experience operating a commodity pool or
trading other
      commodity accounts, and, as a result, the operation and performance of
the Fund may be
      adversely affected by this lack of experience.
        We remind you that the company 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.

       Please contact Jessica Livingston at 202-551-3448 or David Lin at
202-551-3552 with
any questions.

                                                             Sincerely,
FirstName LastNameMatthew J. Bromberg
                                                  Division of Corporation
Finance
Comapany NameETF Managers Group Commodity Trust I
                                                  Office of Crypto Assets
January 18, 2024 Page 2
cc:       Eric Simanek
FirstName LastName
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