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        Chapman and Cutler LLP

320 South Canal Street, 27th Floor

Chicago, Illinois 60606

T 312.845.3000

F 312.701.2361

www.chapman.com

March 7, 2025

Mark Cowan

U.S. Securities and Exchange Commission

Division of Investment Management

Disclosure Review Office

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    FT 11642

    UBS AI Enablers and Adopters Portfolio, Series 1

    (the “Trust”)

    CIK No. 2024511 File No. 333-280555

Dear Mr. Cowan:

We received your comments
regarding the Amended Registration Statement filed on February 4, 2025, for the above captioned Trust. This letter serves to respond to
your comments.

Comments

Portfolio

1.The
Staff notes the name of the Trust has been revised to “UBS AI Enabler and Adopters Portfolio, Series 1” (previously the “UBS
IB AI & Technology Opportunity Portfolio, Series 1”). The modifier “Enablers and Adopters” satisfies any issue the
Staff originally had with the term “AI” in the Trust’s name. However, as the Staff previously noted, if UBS is not affiliated
and First Trust is responsible for the final security selections, then just using UBS in the name may be misleading by conveying the idea
that the Trust is sponsored or affiliated with UBS. The Staff notes, however, this concern is alleviated if the name is modified to also
refer to First Trust (e.g., First Trust UBS AI Enablers and Adopters Portfolio, Series 1).

Response:The
Trust has thoughtfully considered the Staff’s comment and respectfully declines to add “First Trust” to the name of
the Trust. We believe the use of “UBS” in the name of the Trust is not misleading in conveying the Trust’s affiliation
with UBS, as the Sponsor is creating the Trust for UBS, at UBS’s request, to exclusively sell to UBS customers. UBS will not be
compensated for the use of its name by the Trust.

2.In
the “Objective” section and elsewhere, please use “common stocks” or the defined term “Securities.”

Response:The
disclosure has been revised in accordance with the Staff’s comment.

3.To
help with the logical flow of the disclosure in the “Portfolio Selection Process” section, the Staff believes the current
third paragraph (setting the initial universe) should come before the current second paragraph (defining AI Enablers and AI Adopters).

Response:In
accordance with the Staff’s comment, the disclosure has been revised as follows:

“The initial universe of the
list begins with common stocks listed on a U.S. stock exchange that have a market capitalization greater than $1 billion and an average
daily trading volume of more than $2.5 million per day. In order for a common stock to be selected for the Team’s list of AI Enablers
and/or Adopters, the common stock must be considered, at minimum, a “buy,” “hold,” or “bellwether”
from either UBS Global Research or UBS Chief Investment Office’s Global Wealth Management. If the common stock is not rated by either
of these two rating groups, the Team may look to a third-party research firm that UBS Sec LLC or UBS FSI (collectively, “UBS”)
is approved to obtain ratings from. In order to be eligible for inclusion in its list of AI Enablers and/or Adopters, the Team must determine
that artificial intelligence (“AI”) is among the most significant factors that may potentially drive a company’s stock
price performance over the next twenty-four months. The Team bases this determination on factors including a company’s strategic
focus on AI, including investments in AI research and development, the AI products and services offered by a company, the actual or projected
impact of AI on a company’s financial performance, and investor sentiment, as demonstrated by analyst reports and media coverage.

The Team defines AI Enablers as companies
responsible for creating the ecosystem by which AI technologies are advanced. These AI Enabler companies are found in, but not limited
to, the Energy, Utility and Information Technology sectors and the Semiconductors and Software industries. The Team defines
AI Adopters as companies that are utilizing and applying AI into their business practice, including companies creating or utilizing AI
applications, platforms, and software tools that facilitate data management, process optimization, and task automation, and creating physical
devices and technology products.”

4.The
Staff notes the following disclosure in the last sentence of the current second paragraph of the “Portfolio Selection Process”
section, “In order to be eligible for inclusion in its list of AI Enablers and/or Adopters, the Team must reasonably believe that
AI is among the most significant factors that may potentially drive a company’s stock price performance over the next twenty-four
months.”

 (a) Please move this sentence to follow as either the last sentence of the new second paragraph (the current
third paragraph) or as a stand-alone paragraph.

 (b) In the Staff’s view, the eligibility criteria could be read as lacking any objective eligibility
standards (in particular, “…must reasonably believe”). Please revise to reflect a more objective eligibility criteria.
For example, consider rephrasing as follows: “In order to be eligible for inclusion in its list of AI Enablers and/or Adopters,
AI must be viewed by the Team as a significant potential driver of a company’s stock price over the next 24 months.” Then
add disclosure explaining how the Team determines whether AI is a significant potential driver of a company’s stock price over the
next 24 months (e.g., “The Team bases this on…”).

Response:Please
refer to the Trust’s responses below:

 (a) The disclosure has been revised in accordance with the Staff’s comment. Please refer to the Trust’s
response to comment no. 3.

 (b) In accordance with the Staff’s comment, the disclosure has been revised as follows:

“In order to be eligible for inclusion
in its list of AI Enablers and/or Adopters, the Team must determine that AI is among the most significant factors that may potentially
drive a company’s stock price performance over the next twenty-four months. The Team bases this determination on factors including
a company’s strategic focus on AI, including investments in AI research and development, the AI products and services offered by
a company, the actual or projected impact of AI on a company’s financial performance, and investor sentiment, as demonstrated by
analyst reports and media coverage.”

5.The
Staff notes the following disclosure in the first sentence of the current second paragraph of the “Portfolio Selection Process”
section, “AI Enablers are companies responsible for creating the ecosystem by which AI technologies are advanced.” Please
revise the beginning of the above referenced disclosure to read, “The Team defines AI Enablers as companies…”. Likewise,
please revise the beginning of the third sentence of the current second paragraph of the “Portfolio Selection Process” section
to read, “The Team defines AI Adopters as companies…”.

Response:The
disclosure has been revised in accordance with the Staff’s comment. Please refer to the Trust’s response to comment no. 3.

6.The
Staff notes the disclosure in the first sentence of the current third paragraph of the “Portfolio Selection Process” section,
“The initial universe begins with common stocks listed on a U.S. stock exchange that have a market capitalization greater than $1
billion and an average daily trading volume of more than $2.5 million per day.” Please revise the disclosure as follows, “The
initial universe of the list begins with common stocks listed on a U.S. stock exchange…”.

Response:The
disclosure has been revised in accordance with the Staff’s comment. Please refer to the Trust’s response to comment no. 3.

7.At
the end of the last sentence of the current third paragraph of the “Portfolio Selection Process” section, please list the
third-party research firms that UBS is approved to obtain ratings from.

Response:The
Trust has thoughtfully considered the Staff’s comment and respectfully declines to list the third-party research firms that UBS
is approved to obtain ratings from. The Trust submits that ratings information from the third-party research firms is only used if a common
stock in the initial universe is not rated by either of UBS’ research departments, UBS Global Research or UBS Chief Investment Office’s
Global Wealth Management. Furthermore, while the Trust may use third-party ratings to screen out ineligible investments, the UBS Global
Markets America’s Knowledge Network Macro Thematic team (the “Team”) will primarily rely on its own methodology, research
and analysis in selecting the final Trust portfolio. As such, the Trust believes that naming specific third-party research firms overemphasizes
their importance in the Trust’s portfolio selection process. In addition, the third-party research firms that UBS is approved to
obtain ratings from may change over time.

8.For
clarity, please revise the first sentence of the current fourth paragraph of the “Portfolio Selection Process” section as
follows (new language underlined for reference): “In determining whether a company is an AI Adopter and/or Enabler, the Team analyzed
companies who met the initial criteria above to determine if a company is involved in creating, distributing and/or the consumption
of AI products or the AI ecosystem, if a company’s revenue is derived from AI and if a company devotes resources to AI.”

Response:The
disclosure has been revised in accordance with the Staff’s comment.

9.The
Staff notes the disclosure in the second sentence of the current fourth paragraph of the “Portfolio Selection Process” section,
“The Team utilized UBS research ratings, company reports and other publicly available information when performing such analyses.”
Is the disclosure stating that UBS research ratings are a publicly available source? If not, please clarify this sentence.

Response:In
accordance with the Staff’s comment, the above referenced disclosure has been revised as follows:

“The Team utilized UBS research ratings
and publicly available information, including company reports, when performing such analyses.”

10.In
the current sixth paragraph of the “Portfolio Selection Process” section, please specify how many securities are included
in the final list, presumably as of the date the UIT deposits.

Response:The
Trust respectfully declines to add the requested disclosure, as the Sponsor is unable to predict the number of common stocks that the
Team may identify for inclusion in the final list of AI Enablers and/or Adopters for the current series or any future series of the Trust.
However, the Trust notes that the final portfolio holdings will be listed in the Schedule of Investments. The Trust further refers the
Staff to the “Securities Selection” risk which will identify the date of the Team’s list of AI Enablers and/or Adopters
that the final portfolio is selected from.

11.The
Staff notes the disclosure in the last two sentences of the current sixth paragraph of the “Portfolio Selection Process” section,
“To ensure adequate liquidity, the Sponsor only selected those stocks from the Team’s list of AI Enablers and/or Adopters
that have enough daily liquidity to adequately support the buying and selling of the anticipated number of shares on any given day to
meet the Trust’s purchases and/or redemption requirements. The final Trust portfolio is approximately equally weighted.” As
this is ultimately how the Sponsor selects the common stocks for the final portfolio, please clarify this point and break out into a separate
paragraph (e.g., The final portfolio is selected by the Sponsor. To ensure adequate liquidity…). The Staff notes that everything
else preceding this sentence describes how the list was put together.

Response:In
accordance with the Staff’s comment, the above referenced disclosure has been removed from the current sixth paragraph. The following
disclosure has been added as the new seventh paragraph:

“The final portfolio is selected by
the Sponsor from the Team’s list of AI Enablers and/or Adopters and the common stocks are approximately equally weighted. To ensure
adequate liquidity, the Sponsor only selects those common stocks from the Team’s list of AI Enablers and/or Adopters that have enough
daily liquidity to adequately support the buying and selling of the anticipated number of shares on any given day to meet the Trust’s
purchases and/or redemption requirements.”

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 Brian D. Free at (312) 845-3017 or the undersigned at (312) 845-3721.

    Very truly yours,

    Chapman and Cutler llp

    By:
    /s/ Daniel J. Fallon

    Daniel J. Fallon