Correspondence 0001193125-24-078978 from Alger ETF Trust (CIK 0001807486)
Alger ETF Trust (CIK 0001807486)
Date: March 27, 2024 · CIK: 0001807486 · Accession: 0001193125-24-078978
AI Filing Summary & Sentiment
File numbers found in text: 333-248085
Letter
VIA EDGAR Securities and Exchange Commission Attn: Eileen Smiley Re: Alger Concentrated Equity ETF and Alger AI Enablers and Adopters ETF, each, a series of The Alger ETF Trust (File Nos.: 333-248085, 23603)
Dear Ms. Smiley:
On behalf of Alger Concentrated Equity ETF (the “CE Fund”) and Alger AI Enablers & Adopters ETF (formerly the Alger Artificial Intelligence ETF) (the “AI Fund” and together with the CE Fund, the “Funds” and each, a “Fund”), each a series of The Alger ETF Trust (the “Registrant”), this letter responds to the comments provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “Commission”) to the undersigned and Mia G. Pillinger by telephone on February 8, 2024, March 12, 2024, March 20, 2024, March 21, 2024, March 25, 2024 and March 26, 2024, regarding Post-Effective Amendment No. 5 to the Registrant’s Registration Statement on Form N-1A under the Securities Act of 1933, as amended, and the Investment Company Act of 1940, as amended (the “1940 Act”), which was filed with the Commission on December 26, 2023 (the “Registration Statement”) in order to launch the Funds.
The Staff’s comments have been restated below in italicized text. The Registrant’s responses to the Staff’s comments are set out immediately under the restated comment. The Registrant plans to file an amendment to the Registration Statement (the “Amendment”) on or about March 28, 2024, in order to (i) reflect changes made in response to the Staff’s comments, (ii) file certain exhibits, and (iii) make certain other non-material revisions. Unless otherwise indicated, defined terms used herein have the meanings set forth in the Registration Statement.
General Comments
Comment No. 1:
The Staff notes that the comments apply to similar disclosures throughout the Registration Statement, as applicable.
Response No. 1:
The Registrant acknowledges this statement and has responded accordingly.
Comment No. 2:
Please confirm that the Amendment will be complete (i.e., all bracketed/blank information will be completed).
Response No. 2:
The Registrant confirms that the Amendment is complete.
March 27, 2024
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CE Fund—Prospectus Summary—Fund Fees and Expenses
Comment No. 3:
Please confirm supplementally to the Staff that the fee waiver disclosed in the footnote to the Fund Fees and Expenses table will remain in effect for one year from the effective date of the prospectus.
Response No. 3:
The Registrant confirms that the fee waiver disclosed in the footnote to the Fund Fees and Expenses table will remain in effect for one year from the effective date of the prospectus, in accordance with instruction 3(e) to Item 3 of Form N-1A.
CE Fund—Prospectus Summary—Principal Investment Strategy
Comment No. 4:
The first paragraph of the Fund’s principal investment strategy discusses the Manager’s growth philosophy but is not tied to the second paragraph of the Fund’s principal investment strategy and uses different terminology. Please either remove the discussion of the Manager’s growth philosophy from the Fund’s Item 4 disclosure, since it is also discussed in the Fund’s Item 9 disclosure, or revise the disclosure to align it with the Fund’s investment strategy.
Response No. 4:
The Registrant removed the paragraph from the Fund’s Item 4 disclosure in the Amendment.
Comment No. 5:
The Staff notes that the Fund’s name represents a focus in “equity” securities and that the Fund must therefore comply with the requirements Rule 35d-1 under the 1940 Act (the “Names Rule”). Please revise the Fund’s principal investment strategy to incorporate an 80% policy in accordance with the Names Rule.
Response No. 5:
In the Amendment, the Registrant revised the Fund’s principal investment strategy to invest, under normal circumstances, at least 80% of the Fund’s net assets, plus any borrowings for investment purposes, in equity securities of large-cap companies that the Manager believes demonstrate promising growth potential.
Comment No. 6:
The Fund defines equity securities to include securities convertible into or exchangeable for equity securities. Please explain supplementally to the Staff whether such convertible securities will count towards the Fund’s 80% policy.
Response No. 6:
The Fund does not intend for convertible securities to be part of its principal investment strategies. Therefore, the Registrant has revised the definition of equity securities in the Amendment to remove references to convertible securities.
Comment No. 7:
The SAI states that the Fund can invest up to 20% of its net assets in foreign securities, but foreign securities are not included in the Fund’s Item 4 or Item 9 disclosure. Please reconcile the disclosure regarding foreign investments between the SAI and the Fund’s Item 4 and Item 9 disclosure. The Staff notes that reserving the right to invest up to 20% of its net assets in foreign securities in the SAI does not permit the Fund to change its principal investment strategy regarding investments in foreign securities without first filing an amendment to the Fund’s registration statement.
March 27, 2024
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Response No. 7:
While the Fund is permitted to invest up to 20% of its net assets in foreign securities, in accordance with its definition of equity securities, the Fund does not intend for such investments to be part of its principal investment strategies. Therefore, the Registrant believes disclosure regarding foreign securities is more appropriate in the Fund’s SAI and would be confusing to shareholders if it was included in the Fund’s Item 4 and Item 9 disclosure. The Registrant acknowledges the Staff’s position regarding the necessity of filing an amendment to the registration statement in the event that the Fund intends for foreign securities to become a part of its principal investment strategies.
Comment No. 8:
The Fund’s principal investment strategy includes a paragraph regarding the Fund’s industry concentration policy and separately includes a paragraph regarding investing a significant portion of its assets in particular sectors. Please clarify the difference between sectors and industries and include disclosure regarding this difference.
Response No. 8:
The Fund currently relies on the Global Industry Classification Standards (“GICS”) for categorizing companies into sectors and industries; sectors are a broader category than industries under GICS. Because the Fund’s concentration policy relates only to investments in a particular group of related industries, the Registrant believes it is appropriate to also include strategy and risk disclosure regarding investing significantly in particular sectors. The Registrant included disclosure in the Amendment explaining that sectors are a broader category than industries and that industries comprise sectors.
Comment No. 9:
The last paragraph of the Fund’s principal investment strategies states that the Fund invests in cash and cash equivalents. If the Fund intends to invest in certain cash equivalents, such as repurchase agreements, consider disclosing such cash equivalents and adding corresponding risk disclosure. If the Fund does not intend to invest in such cash equivalents, please supplementally explain this to the Staff.
Response No. 9:
The Registrant confirms for the Staff that the Fund does not intend to use cash equivalents such as repurchase agreements as part of its principal investment strategies. However, disclosure regarding such cash equivalents is included in the Fund’s SAI.
CE Fund—Prospectus Summary—Principal Risks
Comment No. 10:
The Fund’s principal risks include “Small Number of Holdings Risk” and “Non-Diversification Risk.” Because the risks are substantially similar, please consider grouping them together or removing one risk.
Response No. 10:
The Registrant removed “Small Number of Holdings Risk” from the Fund’s principal risks in the Amendment.
AI Fund—Prospectus Summary—Fund Fees and Expenses
Comment No. 11:
Please confirm supplementally to the Staff that the fee waiver disclosed in the footnote to the Fund Fees and Expenses table will remain in effect for one year from the effective date of the prospectus.
March 27, 2024
Page
Response No. 11:
The Registrant confirms that the fee waiver disclosed in the footnote to the Fund Fees and Expenses table will remain in effect for one year from the effective date of the prospectus, in accordance with instruction 3(e) to Item 3 of Form N-1A.
AI Fund—Prospectus Summary—Principal Investment Strategy
Comment No. 12:
The first paragraph of the Fund’s principal investment strategy discusses the Manager’s growth philosophy but is not tied to the second paragraph of the Fund’s principal investment strategy and uses different terminology. Please either remove the discussion of the Manager’s growth philosophy from the Fund’s Item 4 disclosure, since it is also discussed in the Fund’s Item 9 disclosure, or revise the disclosure to align it with the Fund’s investment strategy.
Response No. 12:
The Registrant revised the disclosure to align with the Fund’s investment strategy in the Amendment.
Comment No. 13:
Please disclose how the Fund defines companies focusing on the development, adoption or utilization of AI technologies for purposes of its 80% policy. The current definition of such companies is materially misleading as currently drafted because it is too broad and does not sufficiently explain the economic nexus between the Fund’s name and “artificial intelligence.” Additionally, please clarify in the disclosure how the Fund plans to identify and select such companies, using this economic nexus. Will the identification and selection be based on an asset/revenue test? If not, please explain why to the Staff.
Response No. 13:
The Registrant revised the Fund’s principal investment strategy in the Amendment as per the below. The Fund’s definition of companies that benefit from AI is not based on quantitative measures, and therefore, the identification and selection of such companies will not be based on an asset/revenue test.
The Manager believes companies undergoing Positive Dynamic Change offer the best opportunities and demonstrate promising growth potential. Positive Dynamic Change refers to companies realizing High Unit Volume Growth or companies undergoing Positive Lifecycle Change. High Unit Volume Growth companies are traditional growth companies experiencing, for example, rapidly growing demand or market dominance. Positive Lifecycle Change companies are, for example, companies benefitting from new regulations, a new product innovation or new management.
Under normal circumstances, the Fund invests at least 80% of its net assets, plus any borrowings for investment purposes, in equity securities of companies of any market capitalization that it believes will benefit from artificial intelligence (“AI”), demonstrate promising growth potential, and are companies where AI can play a material role in potentially driving stock price performance over the next twelve to thirty-six months. Equity securities include common or preferred stocks listed on U.S. or foreign exchanges.
In effecting the Fund’s investment strategy, the Manager initially employs its fundamental, proprietary investment research investment process to identify companies undergoing Positive Dynamic Change.
March 27, 2024
Page
Next, the Manager determines whether it believes such companies benefit from AI by classifying them into two categories: AI Enablers and AI Adopters. AI Enablers include companies developing the building block components for and investing in AI infrastructure such as machinery, hardware, software and services. AI Adopters include companies that integrate AI into their businesses to enhance their products or services or make their operations more productive. These categories may be adjusted from time to time to incorporate future developments as the area of AI evolves.
Lastly, the Manager determines whether AI can play a material role in potentially driving stock performance over the next twelve to thirty-six months through its fundamental research process. The Manager makes this determination using mainly qualitative assessments to reach its conclusions due to the Manager’s view that publicly traded companies, even those focused upon AI, are not universally transparent in sharing their exposure to AI. Specifically, the Manager makes assessments based upon its knowledge of each company’s creation, distribution and/or consumption of AI products and services, and to the extent available, upon quantitative factors including but not limited to a company’s revenue derived from, and/or resources devoted to, AI. In assessing what material role AI may play in potentially driving stock performance over the next twelve to thirty-six months, the Manager considers from among the following criteria with respect to AI Enablers, estimates of a company’s future market share in AI-related infrastructure services, product and/or service quality, acceleration of revenue growth and rate of adoption relative to peers, and, with respect to AI Adopters, estimates of the degree of AI integration into a company’s operations, the resulting impact on reducing a company’s costs, the increase in efficiency of the company’s operations, the potential enhancement to a company’s net earnings and revenue growth, improvement of product or service offerings, and the extent to which a company may gain a potential competitive advantage from AI within its industry.
The Fund will invest at least 25% of its total assets in companies focused in the following group of related industries: software, technology hardware storage and peripherals, semiconductors and semiconductor equipment, information technology services, electronic equipment instruments and components, communications equipment, broadline retail and interactive media and services, as classified by third party sources. From time to time, the Fund may have 25% or more of its total assets invested in any one of these industries.
Comment No. 13(a):
Please supplementally explain to the Staff the basis for the Fund’s definition of AI and how the Fund considers the distinction between AI and existing technology services applications.
Response No. 13(a):
Please refer to the response to Comment No. 13 regarding the Fund’s definition of companies benefitting from AI. A company may use both AI and other existing technology services applications and be considered an AI Enabler or AI Adopter. Additionally, a company may use existing technology services to develop AI infrastructure and be classified as an AI Enabler or to integrate AI into its business and be classified as an AI Adopter. A company solely using or adopting enhanced technologies not related to or based on AI will not be classified as an AI Enabler or Adopter. Additionally, AI will not play a material role in potentially driving the stock performance of such a company over the next twelve to thirty-six months.
March 27, 2024
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Comment No. 13(b):
The Staff believes that the Fund’s name should either contain modifiers that suggest the limited universe of AI companies in which the Fund will invest or should indicate the future-oriented focus of the Fund’s investments. Please revise the Fund’s name to address these concerns.
Response No. 13(b):
The Registrant has revised the Fund’s name to the “Alger AI Enablers & Adopters ETF.”
Comment No. 14:
The Fund’s principal investment strategy includes a paragraph regarding the Fund’s industry concentration policy and separately includes a paragraph regarding investing a significant portion of its assets in particular sectors. Please clarif
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CORRESP 1 filename1.htm Alger ETF Trust THE ALGER ETF TRUST 100 Pearl Street, 27th Floor New York, New York 10004 March 27, 2024 VIA EDGAR Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Attn: Eileen Smiley Re: Alger Concentrated Equity ETF and Alger AI Enablers and Adopters ETF, each, a series of The Alger ETF Trust (File Nos.: 333-248085, 23603) Dear Ms. Smiley: On behalf of Alger Concentrated Equity ETF (the “CE Fund”) and Alger AI Enablers & Adopters ETF (formerly the Alger Artificial Intelligence ETF) (the “AI Fund” and together with the CE Fund, the “Funds” and each, a “Fund”), each a series of The Alger ETF Trust (the “Registrant”), this letter responds to the comments provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “Commission”) to the undersigned and Mia G. Pillinger by telephone on February 8, 2024, March 12, 2024, March 20, 2024, March 21, 2024, March 25, 2024 and March 26, 2024, regarding Post-Effective Amendment No. 5 to the Registrant’s Registration Statement on Form N-1A under the Securities Act of 1933, as amended, and the Investment Company Act of 1940, as amended (the “1940 Act”), which was filed with the Commission on December 26, 2023 (the “Registration Statement”) in order to launch the Funds. The Staff’s comments have been restated below in italicized text. The Registrant’s responses to the Staff’s comments are set out immediately under the restated comment. The Registrant plans to file an amendment to the Registration Statement (the “Amendment”) on or about March 28, 2024, in order to (i) reflect changes made in response to the Staff’s comments, (ii) file certain exhibits, and (iii) make certain other non-material revisions. Unless otherwise indicated, defined terms used herein have the meanings set forth in the Registration Statement. General Comments Comment No. 1: The Staff notes that the comments apply to similar disclosures throughout the Registration Statement, as applicable. Response No. 1: The Registrant acknowledges this statement and has responded accordingly. Comment No. 2: Please confirm that the Amendment will be complete (i.e., all bracketed/blank information will be completed). Response No. 2: The Registrant confirms that the Amendment is complete. March 27, 2024 Page 2 CE Fund—Prospectus Summary—Fund Fees and Expenses Comment No. 3: Please confirm supplementally to the Staff that the fee waiver disclosed in the footnote to the Fund Fees and Expenses table will remain in effect for one year from the effective date of the prospectus. Response No. 3: The Registrant confirms that the fee waiver disclosed in the footnote to the Fund Fees and Expenses table will remain in effect for one year from the effective date of the prospectus, in accordance with instruction 3(e) to Item 3 of Form N-1A. CE Fund—Prospectus Summary—Principal Investment Strategy Comment No. 4: The first paragraph of the Fund’s principal investment strategy discusses the Manager’s growth philosophy but is not tied to the second paragraph of the Fund’s principal investment strategy and uses different terminology. Please either remove the discussion of the Manager’s growth philosophy from the Fund’s Item 4 disclosure, since it is also discussed in the Fund’s Item 9 disclosure, or revise the disclosure to align it with the Fund’s investment strategy. Response No. 4: The Registrant removed the paragraph from the Fund’s Item 4 disclosure in the Amendment. Comment No. 5: The Staff notes that the Fund’s name represents a focus in “equity” securities and that the Fund must therefore comply with the requirements Rule 35d-1 under the 1940 Act (the “Names Rule”). Please revise the Fund’s principal investment strategy to incorporate an 80% policy in accordance with the Names Rule. Response No. 5: In the Amendment, the Registrant revised the Fund’s principal investment strategy to invest, under normal circumstances, at least 80% of the Fund’s net assets, plus any borrowings for investment purposes, in equity securities of large-cap companies that the Manager believes demonstrate promising growth potential. Comment No. 6: The Fund defines equity securities to include securities convertible into or exchangeable for equity securities. Please explain supplementally to the Staff whether such convertible securities will count towards the Fund’s 80% policy. Response No. 6: The Fund does not intend for convertible securities to be part of its principal investment strategies. Therefore, the Registrant has revised the definition of equity securities in the Amendment to remove references to convertible securities. Comment No. 7: The SAI states that the Fund can invest up to 20% of its net assets in foreign securities, but foreign securities are not included in the Fund’s Item 4 or Item 9 disclosure. Please reconcile the disclosure regarding foreign investments between the SAI and the Fund’s Item 4 and Item 9 disclosure. The Staff notes that reserving the right to invest up to 20% of its net assets in foreign securities in the SAI does not permit the Fund to change its principal investment strategy regarding investments in foreign securities without first filing an amendment to the Fund’s registration statement. March 27, 2024 Page 3 Response No. 7: While the Fund is permitted to invest up to 20% of its net assets in foreign securities, in accordance with its definition of equity securities, the Fund does not intend for such investments to be part of its principal investment strategies. Therefore, the Registrant believes disclosure regarding foreign securities is more appropriate in the Fund’s SAI and would be confusing to shareholders if it was included in the Fund’s Item 4 and Item 9 disclosure. The Registrant acknowledges the Staff’s position regarding the necessity of filing an amendment to the registration statement in the event that the Fund intends for foreign securities to become a part of its principal investment strategies. Comment No. 8: The Fund’s principal investment strategy includes a paragraph regarding the Fund’s industry concentration policy and separately includes a paragraph regarding investing a significant portion of its assets in particular sectors. Please clarify the difference between sectors and industries and include disclosure regarding this difference. Response No. 8: The Fund currently relies on the Global Industry Classification Standards (“GICS”) for categorizing companies into sectors and industries; sectors are a broader category than industries under GICS. Because the Fund’s concentration policy relates only to investments in a particular group of related industries, the Registrant believes it is appropriate to also include strategy and risk disclosure regarding investing significantly in particular sectors. The Registrant included disclosure in the Amendment explaining that sectors are a broader category than industries and that industries comprise sectors. Comment No. 9: The last paragraph of the Fund’s principal investment strategies states that the Fund invests in cash and cash equivalents. If the Fund intends to invest in certain cash equivalents, such as repurchase agreements, consider disclosing such cash equivalents and adding corresponding risk disclosure. If the Fund does not intend to invest in such cash equivalents, please supplementally explain this to the Staff. Response No. 9: The Registrant confirms for the Staff that the Fund does not intend to use cash equivalents such as repurchase agreements as part of its principal investment strategies. However, disclosure regarding such cash equivalents is included in the Fund’s SAI. CE Fund—Prospectus Summary—Principal Risks Comment No. 10: The Fund’s principal risks include “Small Number of Holdings Risk” and “Non-Diversification Risk.” Because the risks are substantially similar, please consider grouping them together or removing one risk. Response No. 10: The Registrant removed “Small Number of Holdings Risk” from the Fund’s principal risks in the Amendment. AI Fund—Prospectus Summary—Fund Fees and Expenses Comment No. 11: Please confirm supplementally to the Staff that the fee waiver disclosed in the footnote to the Fund Fees and Expenses table will remain in effect for one year from the effective date of the prospectus. March 27, 2024 Page 4 Response No. 11: The Registrant confirms that the fee waiver disclosed in the footnote to the Fund Fees and Expenses table will remain in effect for one year from the effective date of the prospectus, in accordance with instruction 3(e) to Item 3 of Form N-1A. AI Fund—Prospectus Summary—Principal Investment Strategy Comment No. 12: The first paragraph of the Fund’s principal investment strategy discusses the Manager’s growth philosophy but is not tied to the second paragraph of the Fund’s principal investment strategy and uses different terminology. Please either remove the discussion of the Manager’s growth philosophy from the Fund’s Item 4 disclosure, since it is also discussed in the Fund’s Item 9 disclosure, or revise the disclosure to align it with the Fund’s investment strategy. Response No. 12: The Registrant revised the disclosure to align with the Fund’s investment strategy in the Amendment. Comment No. 13: Please disclose how the Fund defines companies focusing on the development, adoption or utilization of AI technologies for purposes of its 80% policy. The current definition of such companies is materially misleading as currently drafted because it is too broad and does not sufficiently explain the economic nexus between the Fund’s name and “artificial intelligence.” Additionally, please clarify in the disclosure how the Fund plans to identify and select such companies, using this economic nexus. Will the identification and selection be based on an asset/revenue test? If not, please explain why to the Staff. Response No. 13: The Registrant revised the Fund’s principal investment strategy in the Amendment as per the below. The Fund’s definition of companies that benefit from AI is not based on quantitative measures, and therefore, the identification and selection of such companies will not be based on an asset/revenue test. The Manager believes companies undergoing Positive Dynamic Change offer the best opportunities and demonstrate promising growth potential. Positive Dynamic Change refers to companies realizing High Unit Volume Growth or companies undergoing Positive Lifecycle Change. High Unit Volume Growth companies are traditional growth companies experiencing, for example, rapidly growing demand or market dominance. Positive Lifecycle Change companies are, for example, companies benefitting from new regulations, a new product innovation or new management. Under normal circumstances, the Fund invests at least 80% of its net assets, plus any borrowings for investment purposes, in equity securities of companies of any market capitalization that it believes will benefit from artificial intelligence (“AI”), demonstrate promising growth potential, and are companies where AI can play a material role in potentially driving stock price performance over the next twelve to thirty-six months. Equity securities include common or preferred stocks listed on U.S. or foreign exchanges. In effecting the Fund’s investment strategy, the Manager initially employs its fundamental, proprietary investment research investment process to identify companies undergoing Positive Dynamic Change. March 27, 2024 Page 5 Next, the Manager determines whether it believes such companies benefit from AI by classifying them into two categories: AI Enablers and AI Adopters. AI Enablers include companies developing the building block components for and investing in AI infrastructure such as machinery, hardware, software and services. AI Adopters include companies that integrate AI into their businesses to enhance their products or services or make their operations more productive. These categories may be adjusted from time to time to incorporate future developments as the area of AI evolves. Lastly, the Manager determines whether AI can play a material role in potentially driving stock performance over the next twelve to thirty-six months through its fundamental research process. The Manager makes this determination using mainly qualitative assessments to reach its conclusions due to the Manager’s view that publicly traded companies, even those focused upon AI, are not universally transparent in sharing their exposure to AI. Specifically, the Manager makes assessments based upon its knowledge of each company’s creation, distribution and/or consumption of AI products and services, and to the extent available, upon quantitative factors including but not limited to a company’s revenue derived from, and/or resources devoted to, AI. In assessing what material role AI may play in potentially driving stock performance over the next twelve to thirty-six months, the Manager considers from among the following criteria with respect to AI Enablers, estimates of a company’s future market share in AI-related infrastructure services, product and/or service quality, acceleration of revenue growth and rate of adoption relative to peers, and, with respect to AI Adopters, estimates of the degree of AI integration into a company’s operations, the resulting impact on reducing a company’s costs, the increase in efficiency of the company’s operations, the potential enhancement to a company’s net earnings and revenue growth, improvement of product or service offerings, and the extent to which a company may gain a potential competitive advantage from AI within its industry. The Fund will invest at least 25% of its total assets in companies focused in the following group of related industries: software, technology hardware storage and peripherals, semiconductors and semiconductor equipment, information technology services, electronic equipment instruments and components, communications equipment, broadline retail and interactive media and services, as classified by third party sources. From time to time, the Fund may have 25% or more of its total assets invested in any one of these industries. Comment No. 13(a): Please supplementally explain to the Staff the basis for the Fund’s definition of AI and how the Fund considers the distinction between AI and existing technology services applications. Response No. 13(a): Please refer to the response to Comment No. 13 regarding the Fund’s definition of companies benefitting from AI. A company may use both AI and other existing technology services applications and be considered an AI Enabler or AI Adopter. Additionally, a company may use existing technology services to develop AI infrastructure and be classified as an AI Enabler or to integrate AI into its business and be classified as an AI Adopter. A company solely using or adopting enhanced technologies not related to or based on AI will not be classified as an AI Enabler or Adopter. Additionally, AI will not play a material role in potentially driving the stock performance of such a company over the next twelve to thirty-six months. March 27, 2024 Page 6 Comment No. 13(b): The Staff believes that the Fund’s name should either contain modifiers that suggest the limited universe of AI companies in which the Fund will invest or should indicate the future-oriented focus of the Fund’s investments. Please revise the Fund’s name to address these concerns. Response No. 13(b): The Registrant has revised the Fund’s name to the “Alger AI Enablers & Adopters ETF.” Comment No. 14: The Fund’s principal investment strategy includes a paragraph regarding the Fund’s industry concentration policy and separately includes a paragraph regarding investing a significant portion of its assets in particular sectors. Please clarif