SecProbe.io

May 2, 2025
VIA E-mailJoshua B. Deringer, Esq.
Faegre Drinker Biddle & Reath LLPOne Logan Square, Ste. 2000Philadelphia, PA 19103
Re:Calamos Aksia Hedged Strategies Fund
Initial Registration Statement on Form N-2File Nos. 333-286336, 811-24073
Dear Mr. Deringer:
On April 2, 2025, you filed an initial reg istration statemen t on Form N-2 on behalf of
the Calamos Aksia Hedged Strategies Fund (the “F und”), under the Securities Act of 1933 (the
“Securities Act”) and the I nvestment Company Act of 1940 (the “1940 Act”). We have
reviewed the registration statement a nd have provided our comments below.  All capitalized
terms not otherwise defined herein  have the meaning given to them  in the registration statement.
General
1. Where a comment is made with regard to disc losure in one location, it is applicable to all
similar disclosure appearing elsewh ere in the regist ration statement.
2. We note that many portions of th e filing are incomple te or to be updated by amendment. We
may have additional comments on such portions  when you complete th em in pre-effective
amendments, on disclosures made in response to this letter, on information supplied
supplementally, or on exhibits a dded in any pre-effective amendment, such as the Fund’s
organizational documents.
3. Please supplementally advise us if you have  submitted or expect to submit any exemptive
applications or no-action request s in connection with your regi stration statement, including
with respect to multi-class and co-investment relief.
4. Please consider specifically including disclosures required by Rule 6-11(d)(1) of Regulation
S-X (“Reg S-X”), including if there are any mate rial differences in the accounting policies of
the Predecessor Fund when compared to the Fund.

Joshua B. Deringer, Esq.
Calamos Aksia Hedged Strategies Fund Page 2

Cover Page

Pages i-iv

5. The disclosure on page i references the reorganization of the Predecessor Fund with and into
the Fund.  In correspondence, please provide  additional information related to the
reorganization, including inform ation about when and why the Predecessor Fund was created
and whether any exemptive relief is required in order to effect the re organization. If you are
relying on the GuideStone  no-action letter, please explain any differences and similarities
between the facts underlying th e reorganization of the Predec essor Fund into the Fund and
those in the Guidestone  no-action letter.  Please explain why the Predecessor Fund did not
itself register as a fund and instead intends to reorganize into the Fund.

In addition, please describe supplementally whether the Predecessor Fund made any
investment strategy changes w ithin a one-year period prior to  the date the registration
statement was filed and whether such changes we re made in anticipati on of the conversion to
a registered investment compa ny.  In addition, please discuss any variation in the level of
assets ( e.g., via redemptions, transfers of assets to another person or fund, cash infusions) of
the Predecessor Fund within a one-year period prio r to the date the registration statement was
filed. If any investors in the Pr edecessor Fund redeemed out of the Predecessor Fund within a
one-year period of this date, please describe whethe r such investors were able to invest in an
account with substantially similar investment strategies to that of the Predecessor Fund.

6. The Predecessor Fund is referred to as “Calamos  Aksia Hedge Fund Access Core Alpha LP”
on pages i, 7 and 21 and “Calamos Aksia Hedge  Fund Core Access, LP” on page 73.  Please
reconcile.
7. Footnote (1) on page i states that an initial  investment by an accredited investor below
$25,000 may be permitted as part of a registered investment adviser or broker’s allocation of
clients’ fee-based advisory assets. Please conf irm whether this is also accurate for Class I
Shares, which have an initial investme nt minimum of $1,000,000 (rather than $25,000).
 8. On page ii, please clarify, if tr ue, that “Alternative Funds” ar e commingled asset pools that
typically offer their securiti es privately, without register ing such securities under the
Securities Act.

Prospectus

Summary of Fees and Expenses; Pages 15-17

9. Please include a copy of the completed fees and expenses table wi th your response.

10. Please include a copy of the completed expense example with your response.

11. Please modify the format of the fees and expenses table to pr esent Other Expenses as a sub-
caption directly above the sub-caption titled “Total Annual Fund Expenses.”

Joshua B. Deringer, Esq.
Calamos Aksia Hedged Strategies Fund Page 3

12. Please clarify and amend, if applicable, the disclo sure in footnote (8) st ating “the Lesser of
the Expense Limitation or any other releva nt expense limit then in effect…” ( i.e., should it
refer to “the Lesser of the Expe nse Limitation or any other expe nse limitation in effect when
the fees were waived or  expenses reimbursed”?).

13. Please explain why a sub-category for Acquire d Fund Fees and Expenses is not needed.

The Fund; Page 21

14. Staff notes the disclosure on page 21 desc ribing the reorganizati on and transfer of
substantially all of the asse ts of Calamos Aksia Hedge F und Access Core Alpha LP (the
“Private Fund”) into the Fund simultaneous w ith its commencement of  operations.  Please
confirm if this formation tran saction is being undertaken to seed the fund.  If so, please
provide an analysis addressing th e applicability of Ru le 6-11 of Reg S-X to this transaction
and address the following:
a. Whether the transaction meet s the definition of a fund acquisition as defined in
Rule 6-11(a)(2) of Reg S-X.
b. Confirm if Calamos Advisors LLC continue s to serve as the Investment Manager
and General Partner to the Private Fund a nd if the Private Fund has any LPs that
will be transferring into the Fund.

c. What are the future operating plans of th e Private Fund and its retained assets?
Will the Private Fund continue its operat ions? Will it be windi ng down?  Will it
be changing its strategy?
 If the Fund is being seeded in advance of the reorganization and the ef fectiveness of this
prospectus, please include audite d seed financial statements for the Fund and the Private
Fund including Schedules of Investments prepar ed in accordance with Rules 12-12 through
14 of Reg S-X and accompanied by a consen t from the Fund's and Private Fund’s
independent registered public accountant.  Alternatively, please include audited financial
statements for the Fund post reorganization.  Staff may have additional commen ts based on the Fund’s responses.

Types of Investments and Related Risks; Pages 28-66

15. Consider whether LIBOR Discontinuation Risk and SOFR Risk  on page 61 is still applicable
or should be updated.

Joshua B. Deringer, Esq.
Calamos Aksia Hedged Strategies Fund Page 4

Subsidiaries; Page 67
 16. The Subsidiaries section states that “[t] he Fund may make investments through wholly-
owned subsidiaries (‘Subsidiaries’).”  In the ap propriate section of the registration statement,
or in your response, please:

a. Disclose any of a Subsidiary’s principal investment strategies or principal risks
that constitute principal i nvestment strategies or risks of the Fund.  The principal
investment strategies and pr incipal risk disclosures of  a fund that invests in a
subsidiary should reflect aggregate oper ations of the fund and the subsidiary.

b. Explain in correspondence whether the fina ncial statements of a Subsidiary will
be consolidated with those of the Fu nd.  If not, please explain why not, citing
applicable U.S. GAAP or other accounting guidance.

c. Confirm in correspondence that  a Subsidiary and its board  of directors will agree
to inspection by the Staff of the Subsidiary’s books and records, which will be maintained in accordance with Sec tion 31 of the 1940 Act and the rules
thereunder.
d. To the extent a Subsidiary will be a foreign entity, confirm that the Subsidiary and
its board of directors will agree to design ate an agent for service of process in the
United States.
e. Confirm that a Subsidiary’s management fee (including any pe rformance fee), if
any, will be included in “Management Fees ,” and the Subsidiary’s expenses will
be included in “Other Expens es” in the Fund’s fee table.

Calamos Aksia Hedge Fund Core Access, LP’s Performance; Page 73

17. Because the performance is being adjusted to reflect the Fund’s estimated expenses, please
represent supplementally that the use of adju sted fees and expens es does not result in
performance that is higher than what would have been achieved using the actual fees and
expenses of the Predecessor Fund.

Determination of Net Asset Value; Pages 74-76

18. Please explain how the adjustment to a priv ate fund’s periodic net asset value between
periodic valuation measurement dates, as described in the pe nultimate paragraph on page 75,
is consistent with U.S. GAAP and regulatory requirements absent c onsideration of other
relevant information such as, wh ere determinable, the estimated to tal return that the valuation
agent expects the private market fund to ge nerate on a daily basis for the purposes of
calculating the Fund’s daily NAV.

Joshua B. Deringer, Esq.
Calamos Aksia Hedged Strategies Fund Page 5

19. In the same section, please consider elabor ating on the general frequency of third-party
managers’ net asset value measurements and esti mates and any delays in their receipt by the
Adviser.

20. Please consider modifying the va luation related disclo sure contained in the first paragraph,
first sentence of page 76 to reference “may  not” instead of “will not” to recognize the
Adviser’s valuation oblig ations pursuant to Rule 2a-5 under the 1940 Act.
 Statement of Additional Information (SAI)
 Investment Restrictions; Pages 18-20
21. Fundamental Policy (5) states that the Fund’ s investment restriction with regards to
concentration does not apply to investments by the Fund in Alternative Funds (or other
comparable investments pools), and that the Fund may invest in such funds that may
concentrate their assets in one or  more industries.  Please disclo se that the Fund will consider
the investments of underlying funds, to the ex tent reasonably practi cable, in determining
compliance with the Fund’s own concentration policy.
Certain Provisions of the Agreement and Declaration of Trust
22. We note the exclusive st ate forum provisions of the Fund’ s Agreement and Declaration of
Trust (Article 12.4).  Please disclose in an appropriate location in the prospectus the
corresponding risks of such provisions even as to non-federal securities law claims ( e.g., that
shareholders may have to bring suit in an  inconvenient and less favorable forum).
  Closing

A response to this letter should be in th e form of a pre-effective amendment filed
pursuant to Rule 472 under the Securities Act.   The pre-effective amendment should be
accompanied by a supplemental letter that includes your responses to each of these comments.
Where no change will be made in the filing in res ponse to a comment, please indicate this fact in
your supplemental letter and briefly state the basis for your position.
 We remind you that the Fund and its management are responsib le for the accuracy and
adequacy of their disclosures, notwithstandi ng any review, comments, action, or absence of
action by the staff.

Joshua B. Deringer, Esq.
Calamos Aksia Hedged Strategies Fund Page 6

Should you have any questions regarding this letter, please contac t me at (202) 551-8645.

       S i n c e r e l y ,          / s /  E m i l y  R o w l a n d          Emily Rowland   cc:  Matthew Williams, Branch Chief   Michael Kosoff, Senior Special Counsel