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CORRESP
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CORRESP

 ROPES & GRAY LLP

 191 NORTH WACKER
DRIVE

 32nd FLOOR

CHICAGO, ILLINOIS 60606-4302

 WWW.ROPESGRAY.COM

November 18, 2020

 Patrick J. Valenti

T +1 312 845 1371

patrick.valenti@ropesgray.com

 VIA EDGAR

Division of Investment Management

 Securities and Exchange
Commission

 100 F Street, NE

 Washington, DC 20549

Attn: Ms. Anu Dubey

Re:
 PIMCO Dynamic Income Opportunities Fund

File Nos. 333-235966 and 811-23505

Dear Ms. Dubey:

 On behalf of PIMCO Dynamic Income
Opportunities Fund (the “Fund”), we are writing to provide responses to comments provided by the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) via telephone on March 26, 2020 and
August 4, 2020, on Pre-Effective Amendment No. 1, dated March 24, 2020, to the Fund’s registration statement on Form N-2 (the “Registration
Statement”). The Staff previously provided comments on the Fund’s initial registration statement filing on February 13, 2020, to which we provided responses in correspondence submitted to the SEC on March 24, 2020. Any disclosure
changes described in the below responses will be reflected, to the extent applicable, in Pre-Effective Amendment No. 2 to the Registration Statement, to be filed on or about November 18, 2020, or in
additional pre-effective amendments to be filed subsequently. We have also provided the Staff with a form of opinion of Ropes & Gray LLP for purposes of Item 25.2.l. of Form N-2 under separate cover. Capitalized terms not otherwise defined herein have the meanings given to them in the Registration Statement.

The following sets forth the Staff’s comments and the Fund’s responses thereto.

PROSPECTUS

1.
 Comment: We note that significant market events from the coronavirus have occurred and that you have
added disclosure on page 72 of the effect of the virus on the Fund. Please consider whether the Fund’s disclosures, including its risk disclosures, should be revised and, specifically with respect to the risk disclosures, whether such
disclosures should be enhanced and/or tailored based on how these events are effecting the markets. If the Fund believes that no additional disclosure is warranted, please explain to us in your letter why not.

 Response: The Fund has further enhanced its current risk disclosure in the Prospectus
regarding the coronavirus known as COVID-19, and the significant market events that have occurred as a result of COVID-19, as follows:

In addition, market risk includes the risk that geopolitical and other events will disrupt the economy on a national or global level.
For instance, war, terrorism, market manipulation, government defaults, government shutdowns, political changes or diplomatic developments, public health emergencies (such as the spread of infectious diseases, pandemics and epidemics) and
natural/environmental disasters, and widespread disease and virus epidemics, such as the recent coronavirus outbreak, can all negatively impact the securities markets, which could cause the Fund to lose value. Beginning
in January 2020, global financial markets have experienced and may continue to experience significant volatility resulting from the spread of a novel coronavirus known as
COVID-19. The outbreak of COVID-19 has resulted in travel and border restrictions, quarantines, supply chain disruptions, lower
consumer demand and general market uncertainty. The effects of COVID-19 have and may continue to adversely affect the global economy, the economies of certain nations and
individual issuers, all of which may negatively impact the Fund’s performance. These events could reduce consumer demand or economic output, result in market closures, travel restrictions or quarantines, and significantly adversely
impact the economy. The current contentious domestic political environment, as well as political and diplomatic events within the United States and abroad, such as presidential elections in the U.S. or abroad or the U.S. government’s
inability at times to agree on a long-term budget and deficit reduction plan, has in the past resulted, and may in the future result, in a government shutdown or otherwise adversely affect the U.S. regulatory landscape, the general market
environment and/or investment sentiment, which could have an adverse impact on the Fund’s investments and operations. Additional and/or prolonged U.S. federal government shutdowns may affect investor and consumer confidence and may
adversely impact financial markets and the broader economy, perhaps suddenly and to a significant degree. Governmental and quasi-governmental authorities and regulators throughout the world have previously responded to serious economic
disruptions with a variety of significant fiscal and monetary policy changes, including but not limited to, direct capital infusions into companies, new monetary programs and dramatically lower interest rates. An unexpected or sudden reversal of
these policies, or the ineffectiveness of these policies, could increase volatility in securities markets, which could adversely affect the Fund’s investments. Any market disruptions could also prevent the Fund from executing advantageous
investment decisions in a timely manner. To the extent the Fund focuses its investments in a region enduring geopolitical market disruption, it will face higher risks of loss. Thus, investors should closely monitor current market conditions
to determine whether the Fund meets their individual financial needs and tolerance for risk.

 Current market conditions may pose
heightened risks with respect to the Fund’s investment in fixed income securities. As discussed more under “Principal Risks

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of the Fund—Interest Rate Risk,” iInterest rates in the U.S. are near historically low levels. Any interest rate increases in the future could cause the value of
any Ffund that invests in fixed income securities to decrease. As such, fixed income securities markets may experience heightened levels of interest rate, volatility and liquidity risk.

Exchanges and securities markets may close early, close late or issue trading halts on specific securities, which may result in, among other
things, the Fund being unable to buy or sell certain securities or financial instruments at an advantageous time or accurately price its portfolio investments.

Additionally, the Fund has added the following COVID-19 disclosure to the Statement of Additional
Information:

 The recent spread of an infectious respiratory illness caused by a novel strain
of coronavirus (known as COVID-19) has caused volatility, severe market dislocations and liquidity constraints in many markets, including markets for
the securities the Fund holds, and may adversely affect the Fund’s investments and operations. The transmission of COVID-19 and efforts to contain its spread have resulted in travel
restrictions and disruptions, closed international borders, enhanced health screenings at ports of entry and elsewhere, disruption of and delays in healthcare service preparation and delivery, quarantines, event and service cancellations or
interruptions, disruptions to business operations (including staff furloughs and reductions) and supply chains, and a reduction in consumer and business spending, as well as general concern and uncertainty that has negatively affected the economy.
These disruptions have led to instability in the market place, including equity and debt market losses and overall volatility, and the jobs market. The impact of COVID-19, and other
infectious illness outbreaks, epidemics or pandemics that may arise in the future, could adversely affect the economies of many nations or the entire global economy, the financial well-being and performance of individual issuers, borrowers and
sectors and the health of the markets generally in potentially significant and unforeseen ways. In addition, the impact of infectious illnesses, such as COVID-19, in emerging market
countries may be greater due to generally less established healthcare systems. This crisis or other public health crises may exacerbate other pre-existing political,
social and economic risks in certain countries or globally.

 The foregoing could lead to a significant economic downturn or
recession, increased market volatility, a greater number of market closures, higher default rates and adverse effects on the values and liquidity of securities or other assets. Such impacts, which may vary across asset classes, may adversely affect
the performance of the Fund. In certain cases, an exchange or market may close or issue trading halts on specific securities or even the entire market, which may result in the Fund being, among other things, unable to buy or sell certain securities
or financial instruments or to accurately price their investments.

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 Prospectus Summary

2.
 Comment: Please include summary versions in the Prospectus Summary of any risks identified as principal
risks of investing in the Fund under the “Principal Risks of the Fund” section of the Prospectus. Please also further revise the Prospectus Summary to provide a clear and concise description of the offering and the Fund, with
cross-references to relevant disclosure elsewhere in the Prospectus or the Fund’s Statement of Additional Information. See Instruction to Item 3.2. of Form N-2.

Response: The Fund respectfully submits that the disclosure in the “Principal Risks of the Fund” section of the Prospectus
Summary summarizes each of the risks set forth in the “Principal Risks of the Fund” section of the Prospectus and is consistent with the approach taken by other PIMCO-sponsored closed-end funds.
However, the Fund has revised the Prospectus Summary to clarify certain disclosure regarding the offering and the principal risks of investing in the Fund.

Use of Proceeds

3.
 Comment: Please consider whether, under current market conditions, it may take longer than three months
for the Fund to invest offering proceeds. If the Fund expects a delay beyond such time period, please disclose the reason for the delay and any corresponding risk disclosure. See Guide 1 to Form N-2.

 Response: The Fund believes the current disclosure remains accurate.

Investment Objectives and Strategies — Portfolio Contents — Common Stocks and Other Equity Securities

4.
 Comment: The second sentence of this section states that the Fund may invest to a limited degree in
equity interests issued by public or private issuers. Please advise whether the Fund is subject to an upper limit on its investments in (1) entities that would be required to register as investment companies under the 1940 Act but for Sections
(3)(c)(1) or 3(c)(7) thereof or (2) entities that would be required to register as investment companies under the 1940 Act but for Section (3)(c)(5) thereof.

Response: The Fund does not currently intend to invest more than 15% of its assets in entities that would be required to register as
investment companies under the 1940 Act but for Sections 3(c)(1) or 3(c)(7) thereof; provided, however, that this limit does not apply to any wholly-owned and/or controlled subsidiaries of the Fund or any structured finance vehicles, collateralized
debt obligations or other entities not traditionally considered pooled investment vehicles, certain of which may, in some cases, rely on Sections 3(c)(1) or 3(c)(7) of the 1940 Act. The Fund confirms that it is not subject to an upper limit on its
investments in entities that would be required to register as investment companies under the 1940 Act but for Section 3(c)(5) thereof, aside from the Fund’s 20% guideline on investments in equity interests as described in the Prospectus.

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 Principal Risks of the Fund

5.
 Comment: Please enhance the “Emerging Markets Risk” disclosure, including with respect to the
availability and quality of financial information about emerging market issuers, or explain why it is not necessary to enhance this disclosure. See Chairman Clayton’s Statement, “Emerging Market Investments Entail Significant Disclosure,
Financial Reporting and Other Risks” (April 21, 2020).

 Response: The Fund has updated a portion of the
disclosure in the “Principal Risks of the Fund—Emerging Markets Risk” section in the Prospectus as follows:

 Emerging
market countries typically have less established legal, accounting and financial reporting systems than those in more developed markets, which may reduce the scope or quality of financial information available to investors. Governments in emerging
market countries are often less stable and more likely to take extra-legal action with respect to companies, industries, assets, or foreign ownership than those in more developed markets. Moreover, it can be more difficult for investors to bring
litigation or enforce judgments against issuers in emerging markets or for U.S. regulators to bring enforcement actions against such issuers. The Fund may also be subject to Emerging Markets Risk if it invests in derivatives or other securities or
instruments whose value or return are related to the value or returns of emerging markets securities.

 Other heightened risks
associated with emerging markets investments include without limit, (i) risks due to less social, political and economic stability; (ii) the smaller size of the market for
such securities and a lower volume of trading, resulting in a lack of liquidity and in price volatility; (iii) certain national policies which may restrict the Fund’s investment opportunities, including
restrictions on investing in issuers or industries deemed sensitive to relevant national interests and requirements that government approval be obtained prior to investment by foreign persons; (iv) certain
national policies that may restrict the Fund’s repatriation of investment income, capital or the proceeds of sales of securities, including temporary restrictions on foreign capital remittances; (v) the
lack of uniform accounting and auditing standards and/or standards that may be significantly different from the standards required in the United States; (vi) less publicly available financial and other
information regarding issuers; (vii) potential difficulties in enforcing contractual obligations; and (viii) higher rates of inflation, higher interest rates and other
economic concerns. The Fund may invest to a substantial extent in emerging market securities that are denominated in local currencies, subjecting the Fund to a greater degree of foreign currency risk.

Also, investing in emerging market countries may entail purchases of securities of issuers that are insolvent, bankrupt or otherwise
of questionable ability to satisfy their payment obligations as they become due, subjecting the Fund to a greater amount of credit risk and/or high yield risk. See “Principal Risks of the Fund—Credit Risk” and “Principal Risks of
the Fund—High Yield Securities Risk.” The economy of some emerging markets may be particularly exposed to or affected by a certain industry or sector, and therefore issuers and/or securities of such

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emerging markets may be more affected by the performance of such industries or sectors.

Anti-Takeover and Other Provisions

6.
 Comment: Response 25 of the March 24 Response Letter states that the Fund will revise Article III,
Sections 5 and 6 of the Fund’s Agreement and Declaration of Trust and Article 11 of the Fund’s Bylaws to clarify that these provisions do not apply to claims made under the federal securities laws. Please add disclosure describing these
provisions stating that they shall not apply to claims made under the federal securities laws. Please also add disclosure regarding the risks associated with Article 11 of the Fund’s Bylaws (relating to forum for adjudication of disputes),
including (1) the increased costs for investors in bringing a claim, (2) the uncertainty as to whether a court would enforce such provisions, and (3) a statement that investors cannot waive their rights under the federal