SecProbe.io

CORRESP
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filename1.htm

    The
    Capital Group Companies, Inc.

    333 South Hope Street

    Los Angeles, California 90071-1406

May 29, 2025

Soo Im-Tang

U.S. Securities
and Exchange Commission

Division of Investment
Management

Disclosure Review
Office

100 F Street, N.E.

Washington, D.C.
20549-3628

                  Re:
  Capital Group U.S. Large Growth ETF (“CGGG”)

  Capital Group U.S. Large Value ETF (“CGVV”)

  Initial
Registration Statement on Form N-1A

  File
Nos. 333-281924, 811-24000

Dear Ms. Im-Tang:

In response to
your comments provided on April 30, 2025 to the Post-Effective Amendment No. 1 to the registration statement on Form N-1A (the “Registration
Statement”) of Capital Group Equity ETF Trust I, which includes the series CGGG and CGVV (each a “Fund”, and together,
the “Funds”), we hereby file Post-Effective Amendment No. 2 to the Registration Statement under the Investment Company Act
of 1940 (the “1940 Act”) (such amendment, the “Amendment”) pursuant to Rule 472 of the 1933 Act. We appreciate
your prompt response to the filing.

Our
responses to your comments are set forth below. We will incorporate any changes to the Registration Statement in a subsequent filing
pursuant to Rule 485(b) under the 1933 Act to be immediately effective on May 30, 2025.

General

 1. Please complete
                                            the fee tables and expense examples in the registration statement.

Response:
We have updated the Registration Statement to address this comment.

 2. Unless otherwise
                                            indicated, a comment made with respect to one portion of the Registration Statement is applicable
                                            to all similar disclosures appearing elsewhere in the Registration Statement, including with
                                            respect to each Fund.

Response:
We understand that, unless otherwise stated, when a comment is made with respect to disclosure in one portion of the Registration Statement,
that comment is applicable to all similar disclosures appearing elsewhere in the Registration Statement. Accordingly,

where
applicable, responses to your comments below with respect to CGGG apply equally to CGVV with similar disclosures.

 3. The prospectus
                                            indicates that the Fund may invest in Central Funds (certain other funds managed by the investment
                                            adviser or its affiliates). If acquired fund fees and expenses (“AFFEs”) from
                                            such investments will exceed 0.01% of the average net assets of the Fund, please disclose
                                            these fees and expenses as a separate line item in the fee table. See Item 3, Instruction
                                            3(f)(i) of Form N-1A.

Response:
We confirm that, if AFFE exceed 0.01% of the average net assets of the Fund, the Fund will include a separate line item in the fee table
for AFFE. The Fund's AFFE is not expected to exceed 0.01% of the average net assets of the Fund at this time, and as a result, any such
expenses will be reflected in "Other Expenses”.

Prospectus

Principal
Investment Strategies, Page 1

 4. The first
                                            sentence of the first paragraph under the heading “Principal investment strategies”
                                            states that the Fund invests at least 80% of its assets in common stocks and other equity-type
                                            securities. Please ensure that, with respect to the 80% test, references to a Fund’s
                                            assets are references to the Fund’s net assets.

Response:
We believe the current disclosure is sufficient and refers to the Fund’s net assets for purposes of each Fund’s 80% test.

 5. The information
                                            for the market capitalization of the largest companies included in the Russell 1000 Index
                                            is as of July 1, 2024. To the extent practicable, please provide the information for the
                                            market capitalization of the largest companies included in such indices as of a more recent
                                            date, or confirm that it will be updated in the future

Response:
The Russell indices are reconstituted annually in June. Accordingly, the information for the market capitalization of the largest companies
is accurate as of the proposed effective date of the Registration Statement. We supplementally confirm that we will update the information
in the future following the next reconstitution.

Principal
Risks, Page 2

6.    Please include a large cap risk factor in the “Principal risks” section or, in the alternative, supplementally explain why
the investment risk is adequately covered in existing disclosure.

Response:
We believe that this investment risk is adequately covered by each Fund’s risk factors entitled “Market conditions”
and “Issuer risks” in the “Principal risks” section. In particular, large capitalization companies are typically
well-known, established companies and sector leaders. Large capitalization companies are recognized for their substantial market presence
and financial strength. Because of their size and financial strength, large capitalization companies are generally viewed as offering
steady growth, stability and lower volatility compared to smaller capitalization companies. Large capitalization companies represent
companies that have already reached maturity and typically have established business models that allow them to better withstand market
pressures than smaller capitalization companies. With that being said, large capitalization companies face similar risks presenting every
company, including the risks described in the risk factors entitled “Market

conditions”
and “Issuer risks” in the “Principal risks” section. Accordingly, we believe the investment risk for large capitalization
companies is adequately covered in existing disclosure.

Tax Information,
Page 3

 7. In the sentence
                                            under the heading “Tax Information”, please end the sentence with “in which
                                            case you may be subject to taxes upon withdrawal from such account” or similar language.

Response:
We have updated the Registration Statement as follows:

Dividends
and capital gain distributions you receive from the fund are subject to federal income taxes and may also be subject to state and local
taxes, unless you are tax-exempt or your account is tax-favored (in which case you may be taxed later,
upon withdrawal of your investment from such account).

Principal
Risks, Page 5

 8. For CGVV,
                                            please include the risk of investing in value companies in the “Principal risks”
                                            section.

Response:
We have updated the Registration Statement as follows:

Investing
in income value-oriented stocks
— The prices of, and the value of the fund’s
securities and income provided by, the fund’s
value-oriented common stocks and other equity-type securities (such as preferred stocks) may be reduced by changes in the
dividend policies of, and the capital resources available for dividend payments at, the companies in which the fund invests.

Investment
Objective, Strategies and Risks, Page 7

 9. On page 7,
                                            the disclosure states, “The investment adviser may consider environmental, social and
                                            governance (“ESG”) factors that, depending on the facts and circumstances, are
                                            material to the value of an issuer or instrument. ESG factors may include, but are not limited
                                            to, environmental issues (e.g., water use, emission levels, waste, environmental remediation),
                                            social issues (e.g., human capital, health and safety, changing customer behavior) or governance
                                            issues (e.g., board composition, executive compensation, shareholder dilution).”

 a. Please disclose
                                            whether the investment adviser applies the criteria it uses with respect to environmental,
                                            social or governance factors with respect to every investment it makes or only to some of
                                            its investments.

Response:
We believe the analysis of material ESG issues as part of our fundamental research can help us understand long-term risks and opportunities
of an investment. As indicated in the disclosure, “The investment adviser may consider environmental, social and governance (‘ESG’)
factors that, depending on the facts and circumstances, are material to the value of an issuer or instrument.” We believe the current
disclosure is clear that ESG factors may be considered where such factors are material to the value of an investment.

 b. Explain whether
                                            an investment could be made in a company that scores poorly on ESG if it scores strongly
                                            on other non-ESG factors.

Response:
We do not exclude investments solely based on ESG considerations to the extent we believe it represents a relatively attractive investment
opportunity.

 c. Consider whether
                                            an ESG specific risk disclosure may be appropriate or explain supplementally why such a risk
                                            factor is not appropriate.

Response:
Because ESG considerations do not constitute a principal investment strategy of the Fund, and for the reasons noted above, we do not
believe an ESG specific risk disclosure would be necessary or appropriate.

Statement of
Additional Information

Fund Policies,
Page 22

 10. Regarding
                                            the Fund’s concentration policies, please note that a fund and its adviser may not
                                            ignore the investments of affiliated and unaffiliated underlying investment companies when
                                            determining whether the fund is in compliance with its concentration policies. Please confirm
                                            that the Fund will consider the investments of its underlying investment companies when determining
                                            the Fund’s compliance with its concentration policies.

Response:
We are not aware of any requirement to disclose this practice under Form N-1A, but acknowledge that to the extent the Fund determines
that its investment in an underlying investment company exposes the Fund to a material risk, including significant exposure to a particular
industry or group of industries, the Fund would include appropriate risk disclosure in the Registration Statement.

Management
of the Trust

 11. In the section
                                            regarding the Board of Trustees starting on page 26 of the Fund’s statement of additional
                                            information, key information regarding the trustees and officers has not yet been included.
                                            Please provide that information to the staff for review as soon as practicable.

Response:
We have updated the Registration Statement to address this comment and provided the information to the staff.

Thank you
for your consideration of our responses to your comments. If you have any questions, please do not hesitate to contact us.

Sincerely,

/s/
Joshua R. Diggs

Joshua
R. Diggs

Counsel

(213) 615-0047

josh.diggs@capgroup.com