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Chapman and Cutler LLP

111 West Monroe Street

Chicago, Illinois 60603

May 26, 2020

Via EDGAR Filing

Mr. Edward Bartz

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Re:	Guggenheim Defined Portfolios, Series 2005

Blue Chip Dividend Portfolio, Series
1

File Nos. 333-237377 and 811-03763

Dear Mr. Bartz:

This letter
responds to your comment letter dated April 21, 2020, regarding the registration statement on Form S-6 for Guggenheim Defined
Portfolios, Series 2005, filed on March 25, 2020 with the Securities and Exchange Commission (the “Commission”).
The registration statement proposes to offer the Blue Chip Dividend Portfolio, Series 1 (the “trust”).

PROSPECTUS

Investment
Summary — Investment Objective

1.       This
section states that the trust “seeks to provide above average dividend income potential.” Please delete the term “potential”
from this portion of the trust’s investment objective.

Response:
The disclosure will be revised as requested in response to this comment.

Investment
Summary — Principal Investment Strategy

2.       The
name of the trust includes the terms “blue chip” and “dividend,” both of which suggest particular types
of investments. Please revise the trust’s current 80% policy to state that the trust will invest at least 80% of the value
of its assets in dividend-paying blue chip securities. See Rule 35d-1(a)(2)(i) under the Investment Company Act of 1940.
Please also provide a definition of “blue chip” in this section (e.g., an established company with a national
reputation for quality, reliability, financial strength).

Response:       In
response to this comment, the first sentence of this section will be replaced with the following: “Under normal circumstances,
the trust will invest at least 80% of the value of its assets in dividend-paying securities of blue chip companies. A blue chip
company is a nationally recognized company with a long-term reputation for quality, reliability and financial strength.”

3.       The
first paragraph of this section states that the trust may invest in non-U.S. companies. Please explain to us whether the trust’s
investments in non-U.S. companies will include emerging market issuers as a principal investment strategy and, if so, provide appropriate
disclosure in this section and in the discussions of the trust’s principal risks. Alternatively, please explain to us why
the requested disclosures are not necessary.

Response:       The
trust will not invest in non-U.S. companies, therefore, the non-U.S. companies disclosures have been removed from this section
and the risk sections. Additionally, the phrase “U.S.-traded” in the “Principal Investment Strategies”
section has been replaced with “U.S.”

Investment
Summary — Security Selection

4.       The
fifth bullet point in the second paragraph of this section states that the sponsor “favors companies that possess a strong
competitive position among their domestic and global peers.” Please provide examples in this section of what the sponsor
believes are determinants of a “strong competitive position.”

Response:       In
response to this comment, the following will be added to the end of the bullet: “Examples of a strong competitive position
include, but are not limited to, possessing proprietary technology or processes, a brand strength, network effects, superior management
or an absolute cost advantage.”

Investment
Summary — Principal Risks

5.       Significant
market events have occurred as a result of the COVID-19 pandemic since this registration statement was filed. Please consider whether
the trust’s disclosures, including risk disclosures, should be revised based on how these events may affect the fund and
its investments. If the trust believes that no additional disclosure is warranted, please explain supplementally why not.

Response:       In
response to this comment, both risk sections will include language relating to the COVID-19 pandemic and its potential effect on
the trust.

Investment
Summary — Who Should Invest

6.       The
first and fifth bullet points in this section indicate that the trust will hold significant investments in the financial sector.
If so, please provide corresponding disclosures in the discussions of the trust’s principal investment strategies and principal
risks. If the trust will not have significant investments in the financial sector, please revise this section accordingly.

Response:       In
response to this comment, the first bullet will be replaced with the following and moved to become the second bullet:

 · “The trust is combined with other investment vehicles to provide diversification of method to your overall portfolio;
and”

Additionally, the fifth bullet will be replaced with the following
and moved to become the fourth bullet:

 · You are uncomfortable with the trust’s investment strategy;

Furthermore, the sixth bullet will remove the phrase “high
current income or.”

Additional
Revision

The trust will
not employ a quantitative screening process. As a result, references to a quantitative screening process in the “Principal
Investment Strategies” section will be removed.

We appreciate
your prompt attention to this registration statement. If you have any questions or comments or would like to discuss our responses
to your questions, please feel free to contact the undersigned at (312) 845-3484.

Very truly
yours,

Chapman
and Cutler LLP

By /s/
Morrison C. Warren

    	Morrison
C. Warren