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CORRESP
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March 6, 2020

VIA EDGAR

    Ms. Elena Stojic

Division of Investment Management

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

 Re: AltShares Trust (the “Trust”) (File Nos. 333-233772, 811-23475)

Registration Statement on Form N-1A

Dear Ms. Stojic:

The following are responses by and on behalf
of the AltShares Trust (“Registrant”) to the comments received from you on March 3, 2020, regarding Pre-Effective Amendment
No. 2 (“Pre-Effective Amendment”) to the Registration Statement on Form N-1A for the AltShares Merger Arbitrage ETF
(the “Fund”), a series of the Registrant, that was filed with the Securities and Exchange Commission (“SEC”)
on February 19, 2020. Your comments and the Registrant’s responses are set forth below. Defined terms used but not defined
herein have the respective meanings assigned to them in the Pre-Effective Amendment.

Prospectus

 1. The SEC staff notes that the Fund pays a unitary fee to the Water Island Capital, LLC (the “Adviser”).
Please supplementally confirm that the Fund could be required to pay the Fund’s service providers in the event that Adviser
does not pay.

Response: The Registrant expects
that the Adviser will pay all service providers and confirms that the Adviser is current in all its payments to the Fund’s
service providers. However, the Fund could be required to pay the Fund’s service providers in the event that the Adviser
does not pay.

 2. For purposes of the Fund’s revised 80% policy, please clarify what “financial instruments
with economic characteristics similar to” the index constituents the Fund will invest in.

Response: The Registrant revised
the Fund’s Item 4 disclosure to clarify that the Fund may invest in total return swaps on index securities and, to the extent
that cash is represented in the Fund’s underlying index, extra short-term bond exchange-traded funds, money market funds,
or other cash alternatives as “financial instruments with economic characteristics similar to” index constituents.

        K&L Gates LLP

        1601 K Street NW Washington DC 20006

        T +1 202 778 9000 F +1 202 778 9100 klgates.com

    304497198 v5

 3. Please reinsert the percentages in the Item 9 disclosure about the underlying index’s
methodology. State that these are the percentages as of the date of the prospectus but that these amounts may fluctuate.

Response: The Registrant revised
the disclosure as requested.

Additionally, the Registrant made the following
revisions to the disclosure:

 · Corrected the name of the Fund’s underlying index;

 · Clarified the affiliation between the Adviser and the Index Provider; and

 · Added disclosure to the “Net Asset Value” section of the Prospectus to describe how
swaps are priced, given that the Fund will obtain certain exposures (to index securities) by transacting in swap contracts.

*     *     *     *     *

If you have any questions regarding the
matters discussed above, please feel free to call me at (202) 778-9475.

    Sincerely,

    /s/ Stacy L. Fuller

    Stacy L. Fuller

 cc: Marianne Dobelbower, Branch Chief

Christian Sandoe, Assistant Director

Fatima S. Sulaiman, K&L Gates LLP

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