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June 11, 2024
Bradley H. Bailey
Chief Financial Officer
ETF Managers Group Commodity Trust I
3333 Warrenville Road, Suite 350
Lisle, IL 60532
Re:ETF Managers Group Commodity Trust I
Form 10-K for the Fiscal Year Ended June 30, 2023
File No. 001-36851
Dear Bradley H. Bailey:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended June 30, 2023
Report of Independent Registered Accounting Firm, page 58
1.We note that your auditors' report does not appear to identify and cover the following
financial statements:
•Combined Statements of Assets and Liabilities;
•BDRY Statements of Operations;
•BDRY Statements of Changes in Net Assets; and
•BDRY Statements of Cash Flows.
Please address this matter with your auditors and have them confirm for us that their
audits covered these financial statements. If so, tell us in your response and have them
represent that they will properly identify all the financial statements and schedules of each
individual Fund and the combined results of the Trust in your upcoming Form 10-K and
all future Forms 10-K. See Securities Act Sections Compliance and Disclosure
Interpretations Question (CDI) 104.01.

 FirstName LastNameBradley H. Bailey
 Comapany NameETF Managers Group Commodity Trust I
 June 11, 2024 Page 2
 FirstName LastName
Bradley H. Bailey
ETF Managers Group Commodity Trust I
June 11, 2024
Page 2
Item 9A. Controls and Procedures, page 59
2.We note your use of the possessive plural "Funds'" in your conclusions on disclosure
controls and procedures (DCP) and internal control over financial reporting (ICFR). We
also note that the possessive form of your DCP conclusion is the singular "Fund's" in your
Forms 10-Q for the quarterly periods ended December 31, 2023 and March 31, 2024.
Please confirm for us that your DCP and ICFR conclusions, as relevant, in your fiscal
2023 Form 10-K and fiscal 2024 Forms 10-Q covered the Trust and each of your
individual Funds. If so, represent to us that you will:
•revise your DCP and your ICFR disclosures, as appropriate, in future filings to
separately identify and conclude on each series Fund as well as the Trust; and
•add disclosure in future filings to specifically indicate that your CEO and CFO
certifications are applicable to each series Fund as well as to the Trust.
See Securities Act Sections CDI Question 104.01.
            In closing, 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 Rolf Sundwall at 202-551-3105 or Mark Brunhofer at 202-551-3638 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets