Correspondence 0001999371-25-002530 from Legg Mason ETF Investment Trust (CIK 0001645194)
Legg Mason ETF Investment Trust (CIK 0001645194)
Date: March 10, 2025 · CIK: 0001645194 · Accession: 0001999371-25-002530
AI Filing Summary & Sentiment
File numbers found in text: 333-206784, 811-23096
Letter
Stradley Ronon Stevens & Young, LLP
2005 Market Street, Suite 2600
Philadelphia, PA 19103
Telephone 215.564.8000
Fax 215.564.8120
www.stradley.com
Kenneth L Greenberg
Partner
kgreenberg@stradley.com
215.564.8149
March 10, 2025
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549-9303
Attention: Alison White, Esq.
Re:
ClearBridge Large Cap Growth ESG ETF (the “Fund”) of the
Legg Mason ETF Investment Trust (the “Registrant”)
(File No. 333-206784 and 811-23096)
This letter responds to the comments provided by Ms. Alison White on March 5, 2025 to Kenneth L. Greenberg, Esq., the counsel of the Registrant, regarding the proxy statement filed by the Registrant on March 4, 2025 for a special meeting of shareholders of the Fund (the “Meeting”) to be held on May 28, 2025. We have summarized each of your comments below, in the order you provided them, and have set forth the Registrant’s responses immediately below each comment. Defined terms not herein defined shall have the meaning set forth in the proxy statement.
Proxy Statement Comments
1. Comment: On the cover page of the proxy statement, add disclosure about the date on which the proxy statement will first be mailed to shareholders.
Response: Revised as requested.
2. Comment: On page 8, regarding the discussion of the MoM Order, add disclosure clarifying why the FT Order is needed in addition to the LM Order.
Response: Revised as requested.
3. Text: On page 13, in the section titled “FURTHER INFORMATION ABOUT VOTING AND THE MEETING- Solicitation of Proxies”, the second sentence states:
The cost of soliciting proxies, including the fees of a proxy solicitation agent, will be borne entirely by the Fund’s investment managers.
Pennsylvania • New Jersey • Delaware • DC • New York • Illinois • California
A Pennsylvania Limited Liability Partnership
Alison White, Esq.
March 10, 2025
Page 2
Comment: Should the reference to “investment managers” be changed to singular?
Response: Registrant will revise the reference to “investment managers” to “investment manager.”
* * * * * * * *
Please do not hesitate to contact me at (215) 564-8149, or in my absence, David Garton at (215) 564-8721 if you have any questions or wish to discuss any of the responses presented above.
Respectfully submitted,
/s/ Kenneth L. Greenberg, Esq.
Show Raw Text
CORRESP 1 filename1.htm Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 Telephone 215.564.8000 Fax 215.564.8120 www.stradley.com Kenneth L Greenberg Partner kgreenberg@stradley.com 215.564.8149 March 10, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549-9303 Attention: Alison White, Esq. Re: ClearBridge Large Cap Growth ESG ETF (the “Fund”) of the Legg Mason ETF Investment Trust (the “Registrant”) (File No. 333-206784 and 811-23096) This letter responds to the comments provided by Ms. Alison White on March 5, 2025 to Kenneth L. Greenberg, Esq., the counsel of the Registrant, regarding the proxy statement filed by the Registrant on March 4, 2025 for a special meeting of shareholders of the Fund (the “Meeting”) to be held on May 28, 2025. We have summarized each of your comments below, in the order you provided them, and have set forth the Registrant’s responses immediately below each comment. Defined terms not herein defined shall have the meaning set forth in the proxy statement. Proxy Statement Comments 1. Comment: On the cover page of the proxy statement, add disclosure about the date on which the proxy statement will first be mailed to shareholders. Response: Revised as requested. 2. Comment: On page 8, regarding the discussion of the MoM Order, add disclosure clarifying why the FT Order is needed in addition to the LM Order. Response: Revised as requested. 3. Text: On page 13, in the section titled “FURTHER INFORMATION ABOUT VOTING AND THE MEETING- Solicitation of Proxies”, the second sentence states: The cost of soliciting proxies, including the fees of a proxy solicitation agent, will be borne entirely by the Fund’s investment managers. Pennsylvania • New Jersey • Delaware • DC • New York • Illinois • California A Pennsylvania Limited Liability Partnership Alison White, Esq. March 10, 2025 Page 2 Comment: Should the reference to “investment managers” be changed to singular? Response: Registrant will revise the reference to “investment managers” to “investment manager.” * * * * * * * * Please do not hesitate to contact me at (215) 564-8149, or in my absence, David Garton at (215) 564-8721 if you have any questions or wish to discuss any of the responses presented above. Respectfully submitted, /s/ Kenneth L. Greenberg, Esq.