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CORRESP

 ROPES & GRAY LLP

1211 AVENUE OF THE AMERICAS

NEW YORK, NY 10036-8704

WWW.ROPESGRAY.COM

January 23, 2024

 Nicholas M. Coppola

 T +1 212 596 9490

nicholas.coppola@ropesgray.com

 VIA EDGAR

Division of Investment Management

 Securities and Exchange
Commission

 100 F Street, NE

 Washington, DC 20549

Attn: Ms. Kimberly Browning

Re:
 DoubleLine ETF Trust (the “Registrant”) with respect to DoubleLine Commodity Strategy ETF and
DoubleLine Fortune 500 Equal Weight ETF (each a “Fund” and together the “Funds”), File Nos 333-260030 and 811-23746

Dear Ms. Browning:

 This
letter is being filed to respond to the comments provided by telephone on January 19, 2024, by the Staff (the “Staff”) of the U.S. Securities and Exchange Commission, regarding the Registrant’s Post-Effective Amendment
(“PEA”) No. 5 to its registration statement and the Registrant’s responses to comments made by the Staff on January 11, 2024 (the “Prior Response Letter”). PEA No. 5 was filed pursuant to Rule 485(a) under the
Securities Act of 1933, as amended, on Form N-1A on October 25, 2023, to register shares of the Funds, each a new series of the Registrant. The Registrant is filing PEA No. 8 pursuant to Rule 485(b) (the “485(b) Filing”) to
(i) reflect the revisions discussed herein in response to your comments; (ii) make certain non-material changes as appropriate; and (iii) file exhibits to the registration statement. Capitalized terms used and not defined herein have
the meanings given to them in PEA No. 5.

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

1.
 PROSPECTUS

a.
 DoubleLine Commodity Strategy ETF

1.
 Comment: The Staff re-issues comment number 2 in the Prior Response Letter which states: “The
Fund’s name includes the term “Commodity,” which implicates 35d-1 under the Investment Company Act of 1940, as amended (the “40 Act”). Please either revise the Fund’s name or include an 80% policy.”

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January 23, 2024

 Response: The Registrant will change the name of the Fund to:
“DoubleLine Commodity Strategy ETF.”

2.
 Comment: The Fund’s investment objective, as revised, states that the Fund will seek total
return over a “full market cycle.” Define the term “full market cycle” in plain English.

Response: The Registrant will revise the referenced disclosure in the 485(b) Filing as follows:

Fund’s investment objective is to seek long-term total return (capital appreciation and current income) over, in the Adviser’s view, a full market cycle.

3.
 Comment: In reference to the Registrant’s response to comment number 5 in the Prior Response
Letter, if the Fund does not currently intend to borrow securities for the purpose of engaging in short sales within one year of the effective date of its registration statement, please remove disclosure regarding short sales in the principal
investment strategies sections of the Fund’s prospectus.

 Response: The Registrant confirms
that the Fund will not borrow to engage in short sales within one year of the effective date of the 485(b) filing. The Registrant also notes that the added disclosure in the preamble regarding expenses on securities sold short aligns to the language
of the Fund’s advisory agreement regarding the exceptions to the Fund’s unitary fee and is not intended to reflect the Fund’s principal investment strategies. The Registrant nonetheless agrees to make the requested change to the
preamble of the Fund’s fee table.

4.
 Comment: Please revise the Fund’s prospectus disclosure to more specifically describe the types
of investments in which the Fund will invest as part of its principal investment strategies. The Staff notes the use of “e.g.,” in the Fund’s disclosure suggests that the examples provided are a non-exhaustive list of the types of
investments that the Fund will invest in.

 Response: The Registrant confirms that all principal
investment strategies and expected instruments that will be used principally have been described expressly in the Fund’s Prospectus. The Registrant respectfully declines to remove uses of “e.g.,” from the Fund’s investment
strategies. The use of “e.g.,” is used in the Prospectus not to define or disclose the Fund’s investments directly, but instead to disclose the universe of commodities to which the Barclays Index may provide exposure, which may change
over time and over which the Fund has no control.

5.
 Comment: Delete the phrase “from time to time” from the first paragraph of the Fund’s
principal investment strategies as this phrase suggests that such investments are not a principal investment strategy of the Fund.

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January 23, 2024

 Response: The Registrant will revise the referenced disclosure in the
485(b) Filing as follows:

 The commodities to which the Fund expects to have investment exposure principally from time to time include, without limitation, industrial metals (e.g., aluminum, copper, lead, nickel, zinc);
precious metals (e.g., gold and silver); oil, gas and other energy commodities (e.g., crude oil, brent oil, gasoil, RBOB (reformulated blendstock for oxygenate blending) gasoline, and heating oil); agricultural products (e.g., coffee, corn,
soybeans, sugar, cotton, wheat); and livestock (e.g., lean hogs, live cattle).

 ***

The Fund does not expect to invest more than 25% of its total assets in a subsidiary as of the end of each
quarter of the Fund’s taxable year, though its investments in the Subsidiary may exceed 25% of its assets at times
other than the end of each quarter of the Fund’s taxable year from time to time.

6.
 Comment: The Staff notes that the Fund’s commodity-related investments, as revised in the Prior
Comment Letter, may include “operating companies” with direct or indirect exposure to commodities. Please explain in plain English what is meant by “invest in operating companies” and include attendant risk disclosure.

 Response: The Registrant will remove the referenced disclosure as marked below in the 485(b)
Filing:

Commodity-related
investments may include investments in commodities, investments in instruments based on one or more commodities or commodity-related indices or investments in operating companies with direct or indirect exposure to commodities (e.g., an investment
in an oil production company or a mining company). The Fund expects to gain commodity-related investment exposure primarily through instruments the investment performance of which is based on
one or more commodities, commodity baskets or commodities-related indices that, in aggregate, are generally representative of broad commodity exposures consistent with the Barclays Backwardation Tilt Multi-Strategy Index (the “Barclays
Index”).

7.
 Comment: Please disclose how the Fund will determine if an operating company is commodity-related.

 Response: As discussed above in Registrant’s response to Comment 6, the referenced
disclosure will be removed.

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January 23, 2024

8.
 Comment: Please disclose whether the private investment vehicles in which the Fund may invest include
companies exempt from registration under Sections 3(c)(1) or 3(c)(7) of the 40 Act. In addition, disclose the extent of the Fund’s investments in such vehicles as a percentage of the Fund’s assets.

Response: The Registrant will remove references to private investment vehicles and will revise the referenced
disclosure in the 485(b) Filing as follows:

 The Fund is not an index fund; the Fund makes investments other than in an index, and the Fund’s investment objective is
not to seek to approximate the performance of any index. The Fund may pursue its investment objective and obtain exposures to some or all of the asset classes described in this Prospectus by
investing in other investment companies, including, for example, other registered open-end or
closed-end investment companies, including ETFs, and investment vehicles exempt from registration under the Investment Company Act of 1940, as amended (“other pooled investment vehicles”), including investment companies or other pooled investment vehicles
sponsored or managed by the Adviser or its related parties.

9.
 Comment: The Staff notes the disclosure, as revised in the Prior Comment Letter, states “Within
its broad commodity universe, the Barclays Index, through a rules-based algorithm generally favors maintaining...” (Emphasis added) Please also make clear in the Fund’s prospectus that the Fund is not an index Fund and does not track the
Barclays Index.

 Response: The Registrant will revise the Fund’s disclosure in the 485(b)
Filing as follows:

 Within its broad commodity universe, the Barclays Index, which consists of futures
contracts, through a rules-based algorithm, generally favors maintaining higher weightings to
commodities that exhibit backwardation in the term structures of their futures contracts (i.e., where prices of the contracts with shorter-term expirations will be higher than for contracts with longer-term expirations).

In addition, the Registrant will revise the Fund’s disclosure in the 485(b) Filing as reflected in Comment 8 above to
state that the Fund is not an index fund.

10.
 Comment: Please revise the Fund’s disclosure to make the description of the Barclays Index
included in response to Item 4 of Form N-1A less prominent.

 Response: The Registrant will
revise the disclosure in the Fund’s prospectus to move the referenced disclosure later within Item 4 of Form N-1A.

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January 23, 2024

11.
 Comment: In reference to the paragraph following “[Item 9 Only]” in comment 9 of the Prior
Response Letter, please delete “for example” so the disclosure contains a complete list of the Fund’s investments. Please also clarify what “other pooled investment vehicles” means and add any attendant risks.

 Response: Please see the Registrant’s response to Comment 8 above which reflects that the
Registrant will make the requested change in the 485(b) Filing. The Registrant believes the only remaining “e.g.” or “for example” references within the descriptions of the Fund’s principal investment strategy in the
Prospectus are used in the description of the Barclay’s Index.

12.
 Comment: The Fund’s disclosure should reflect the aggregate operations of the Fund and the
Subsidiary and disclose the investment strategies and principal risks of the Subsidiary that are strategies or risks of the Fund.

Response: The Registrant will revise the Fund’s disclosure in the 485(b) Filing as follows:

The
 Subsidiary will make the swap, futures, option and/or forward investments that give the Fund exposure to the Barclays Index When the Fund invests in commodities through swaps, the Subsidiary typically will engage in the swap transactions and the Fund will obtain commodities exposure
indirectly.

 Please also see the Registrant’s
response to Comment 15 below.

13.
 Comment: The Staff reissues Comment 23 from the Prior Response Letter regarding an 80% investment
policy pursuant to Rule 35d-1 under the 40 Act.

 Response: Please see the Registrant’s
response to Comment 1 above.

14.
 Comment: The Staff reissues Comment 24 from the Prior Response Letter. The Staff also notes that the
term “other derivatives” does not specifically describe the Fund’s principal investment strategies. If there will be no other forms of leverage, then the Fund should make that representation.

Response: The Registrant will revise the Fund’s disclosure in the 485(b) Filing as follows:

Because the Fund expects to obtain its commodities exposures through total and excess return swaps, futures contracts, options on futures, and/or forward contracts swap contracts, futures contracts and/or other derivatives that
do not require significant up front investment of the Fund’s cash, the Fund expects to have cash
available to invest in other assets.

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January 23, 2024

15.
 Comment: The principal investment strategies and risk disclosures of a Fund that invests in a
subsidiary should reflect the aggregate operations of the Fund and the Subsidiary.

 Response: The
Registrant will add the following disclosure to the 485(b) Filing:

 When used in this Prospectus the term “Fund” includes the Subsidiary and the term “invest” includes
investments that the Fund makes through the Subsidiary.

16.
 Comment: The Staff reissues Comment 30 from the Prior Response Letter.

Response: The Registrant will add the following disclosure to the Fund’s Item 9 principal investment
strategies:

The
 Fund will treat the Subsidiary’s assets as assets of the Fund for purposes of determining compliance with various provisions of the 1940 Act applicable to the Fund, including those relating to investment policies (Section 8), borrowing
(Section 18) and affiliated transactions and custody (Section 17). In addition, the Adviser and the Fund’s Board of Trustees will comply with the provisions of Section 15 of the 1940 Act with respect to the Subsidiary’s investment
advisory contract.

17.
 Comment: Confirm that the Subsidiary’s financial statements will be consolidated with the
Fund’s financial statements.

 Response: The Registrant confirms that the Subsidiary’s
financial statements will be consolidated with the Fund’s financial statements.

18.
 Comment: Confirm that the Subsidiary and its board of directors will agree to inspection of its books
and records by the Staff and will agree to designate an agent for service of process in the United States.

Response: The Registrant confirms that the Subsidiary and its board of directors will make the Subsidiary’s books
and records available for inspection by the Staff upon request. The Registrant also confirms that the Subsidiary will designate an agent for service of process in the United States.

19.
 Comment: The Staff requests to see the Fee Waiver letter prior to the effective date of the
Registration Statement and related disclosure in the Fund’s prospectus. In reference to Item 3 (and the related instructions) to Form N1-A, if a fee waiver is disclosed in the fee table; any such fee waiver must be contractual; must extend
for only a year; must be active; must disclose if there is recoupment.

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January 23, 2024

 Response: The Registrant confirms that it has provided the Fee Waiver
Letter for review with this Response Letter. The Registrant will also add the following disclosure as a footnote to the management fee line item of the Fund’s fee table:

The
 Fund’s Subsidiary (as defined below) also pays the Adviser a management fee of 0.65% of the Subsidiary’s average daily net assets. The Adviser has contractually agreed that any management fees paid to it by the Subsidiary will reduce the
management fees payable to it by the Fund.

20.
 Comment: In the paragraph following the sub-heading “Fixed Income Investments” please
specify the type of debt securities that the Fund will invest in.

 Response: The Registrant
respectfully declines to modify this disclosure. The Registrant submits that the Fund’s disclosure, as revised in the Prior Comment Letter, under the heading “Fixed Income Investments” specifically describes the type of debt
instruments in which the Fund will invest in principally.

21.
 Comment: Disclose if the Fund has a downgrading policy with respect to the credit quality of the
Fund’s investments. Clarify if debt credit quality is only assessed at time of purchase and what happens if the rating falls?

Response: The Registrant believes the Fund’s disclosure, as revised in the Prior Comment Letter, and reproduced
below, addresses the Staff’s comment as to when credit quality is assessed by the Adviser.

 (ii)
investment-grade debt securities (i.e., those rated above Ba1 by Moody’s Investors Service, Inc. or above BB+ by S&P Global Ratings or Fitch Ratings, Inc.) or unrated debt securities that the Adviser determines to be of similar credit
quality, as rated or determined at the time of investment…

 In addition, the Registrant will add the following
disclosure to the 485(