SecProbe.io

CORRESP
 1
 filename1.htm

 July 29, 2025

 Christopher Bellacicco
 Division of Investment Management
 Disclosure Review & Accounting Office
 100 F Street, N.E.
 Washington, D.C. 20549

 Re:
 Themes ETF Trust (the " Trust ")

 Post-Effective
Amendment No. 31 to the Registration Statement on Form N-1A (the " Amendment ")
 File Nos.: 333-271700 and 811-23872

 Dear Mr. Bellacicco:

 This correspondence responds to comments received by the undersigned from the staff
 of the U.S. Securities and Exchange Commission (the " Staff " of the " Commission ") with respect to the Amendments relating to the Leverage Shares 2X Long HIMS Daily ETF, Leverage Shares 2X Long BBAI Daily ETF, Leverage
 Shares 2X Long SOUN Daily ETF, Leverage Shares 2X Long RGTI Daily ETF, Leverage Shares
 2X Long COST Daily ETF, Leverage Shares 2X Long VST Daily ETF, Leverage Shares 2X
 Long RKLB Daily ETF, Leverage Shares 2X Long AFRM Daily ETF, Leverage Shares 2X Long GOLD Daily ETF, Leverage Shares 2X Long NEM Daily ETF, Leverage Shares 2X Long OKLO Daily ETF, Leverage Shares 2X Long FUTU Daily ETF, Leverage Shares 2X Long PDD Daily ETF, Leverage Shares 2X Long JD Daily ETF, and Leverage Shares 2X Long ABNB Daily ETF (each a " Fund " and collectively, the " Funds "), a proposed new series of the Trust. For your convenience, your comments have been summarized with responses following each comment. Capitalized terms not otherwise
 defined have the same meaning as in the Amendments.

 1.
 Comment : On page 42, in the final paragraph, please include a plain English description of full stack quantum computing company.

 Response: The Registrant has amended the first sentence of the paragraph as follows:

 Rigetti Computing was founded in 2013 and is a full-stack quantum computing company, which aims to offer a complete end-to-end solution, from the physical hardware to
 the user-facing software and applications .

 2.
 Comment : On page 167, under JD.com, Inc. Investing Risk., please consider adding risk disclosure relating to Chinese companies that have ties
 to the military.

 Response : The following disclosure has been added as a Principal Investment Risk:

 KAREN A. ASPINALL ● PARTNER

 11300 Tomahawk Creek Pkwy,
Suite 310 ● Leawood, KS 66211 ● p: 949.629.3928

 Practus, LLP ●
 Karen.Aspinall@Practus.com ● Practus.com

 Item 4 :

 China
Investing Risks. The Chinese economy is generally considered an emerging market and can be significantly affected by economic and
political conditions and policy in China and surrounding Asian countries. A relatively small number of Chinese companies represent a
large portion of China's total market and thus may be more sensitive to adverse political or economic circumstances and market
movements. The economy of China differs, often unfavorably, from the U.S. economy in such respects as structure, general development,
government involvement, wealth distribution, rate of inflation, growth rate, allocation of resources and capital reinvestment, among
others. The Public Company Accounting Oversight Board ("PCAOB"), which regulates auditors of U.S. public companies, has warned
that it lacks the ability to inspect audit work and practices of PCAOB-registered accounting firms in China and Hong Kong. The PCAOB's
limited ability to oversee the operations of accounting firms in China and Hong Kong means that inaccurate or incomplete financial records
of an issuer's operations may not be detected, which could negatively impact the Fund's investments in such companies. Under
China's political and economic system, the central government has historically exercised substantial control over virtually every
sector of the Chinese economy through administrative regulation and/or state ownership. In addition, expropriation, including nationalization,
confiscatory taxation, political, economic or social instability or other developments could adversely affect and significantly diminish
the values of the Chinese companies in which the Fund invests. International trade tensions may arise from time to time which can result
in trade tariffs, embargoes, trade limitations, trade wars and other negative consequences. These consequences may trigger a reduction
in international trade, the oversupply of certain manufactured goods, substantial price reductions of goods and possible failure of individual
companies and/or large segments of China's export industry with a potentially severe negative impact to the Fund. Additionally,
the U.S. has added certain foreign technology companies to the U.S. Department of Commerce's Bureau of Industry and Security's
"Entity List," which is a list of companies believed to pose a national security risk to the U.S. U.S. investors may also
be barred by U.S. authorities from investing in certain companies, including those with ties to the military, intelligence, and security
services in China. Actions like these may have unanticipated and disruptive effects on the Chinese economy. Any such response that targets
Chinese financial markets or securities exchanges could interfere with orderly trading, delay settlement or cause market disruptions.

 Item 9 :

 China Investing Risk. The Fund is subject to risks associated with investing in China. The Chinese economy is generally considered an emerging market and can be significantly
 affected by economic and political conditions in China and surrounding Asian countries.
 In addition, the Chinese economy is export-driven and highly reliant on trade. A downturn
 in the economies of China ' s primary trading partners could slow or eliminate the growth of the Chinese economy
 and adversely impact the Fund ' s investments. The Chinese government strictly regulates the payment of foreign currency
 denominated obligations and sets monetary policy. The Chinese government may introduce
 new laws and regulations that could have an adverse effect on the Fund. Although China
 has begun the process of privatizing certain sectors of its economy, privatized entities
 may lose money and/or be re-nationalized.

 The Chinese securities markets are subject to more frequent trading halts, low trading
 volume and price volatility. Further, the Chinese economy is heavily dependent upon
 trading with key partners. Recent developments in relations between the United States
 and China have heightened concerns of increased tariffs and restrictions on trade
 between the two countries. An increase in tariffs or trade restrictions, or even the
 threat of such developments, could lead to a significant reduction in international trade, which could have a negative impact on China ' s export industry and a commensurately negative impact on the Fund.

 2

 In recent years, Chinese entities have incurred significant levels of debt and Chinese
 financial institutions currently hold relatively large amounts of non-performing debt.
 Thus, there exists a possibility that widespread defaults could occur, which could
 trigger a financial crisis, freeze Chinese debt and finance markets and make Chinese
 securities illiquid , which could have a negative impact on the Fund .

 In addition, trade relations between the U.S. and China have recently been strained. Worsening trade relations between the two countries could adversely impact the Fund,
 particularly to the extent that the Chinese government restricts foreign investments
 in on-shore Chinese companies or the U.S. government restricts investments by U.S.
 investors in China. Worsening trade relations may also result in market volatility and volatility in the
 price of Fund shares.

 The Fund is subject to considerable risks stemming from the fluctuating state of U.S.-China
 relations. Periodic tensions, trade wars, and disagreements over intellectual property,
 human rights, and other issues can lead to economic and regulatory retaliations that
 may disrupt business operations, supply chains, and market access. Additionally, the
 long-standing territorial dispute over Taiwan remains a flashpoint, with both nations
 having vested interests in the outcome. An escalation of tensions or direct conflict
 regarding Taiwan could severely destabilize regional markets, disrupt international
 trade, and pose significant challenges for investors with exposures in the Asia-Pacific
 region.

 Investing in China is subject to various social, demographic, political, and economic
 risks. Socially and demographically, China faces challenges such as an aging population,
 urban-rural disparities, and social unrest stemming from income inequality. Politically,
 the centralized system may experience unforeseen shifts in policies, regulatory environments,
 and governance. The government ' s tight control over the media, internet, and freedom of speech may also create unpredictabilities.
 Economically, China ' s growth, while impressive, has raised concerns about potential asset bubbles, mounting
 debts, and over-reliance on certain sectors. Any of these factors could lead to volatility
 or losses for the Fund, and it is crucial for investors to understand and regularly
 review the extent and nature of their exposure to these risks.

 If you have any questions regarding the above responses, please do not hesitate to
 contact me at (949) 629-3928 or Karen.Aspinall@practus.com.

 Sincerely,

 /s/ Karen Aspinall

 Karen Aspinall
 Trust Counsel

 3