SecProbe.io

VIA E-MAIL
September 15, 2025 Allison Fumai, Esq.
Dechert LLP1095 Avenue of the Americas New York, N Y 10036-6797
Re: Baron ETF Trust
File Nos. 333-289683 and 811-24115
Dear Ms. Fumai:
On August 18, 2025, you filed an initial registration statement on Form N-1A with respect to the
following: Baron First Principles ETF, Baron Global  Durable Advantage ETF, Baron SMID Cap ETF,
Baron Financials ETF, and Bar on Technology ETF (each, a “Fund,” and collectively, “Funds”). We
have reviewed the registration statement and our comments are set forth below. Where a comment is
made with respect to disclosure in one location of the filing, it app lies to all similar disclosures found
elsewhere. Capitalized terms not otherwise defined have the same meaning as in the registration
statement.
GENERAL 1. We note that portions of the regi stration statement are incomplete. A full financial review (e.g., seed
financial statements, auditor's repor t, consent) must be performed pr ior to declaring the registration
statement effective. We may have  additional comments on such portions when you complete them in
a pre-effective amendment, on disc losures made in response to this  letter, on information supplied
supplementally, or on exhibits added in any amendment.
2. Please inform the staff if a part y other than the Fund’s sponsor or an affiliate is providing the Fund
with initial seed capital.  If so, supplementally identify the party providing the seed capital and
describe its relationship with the Fund.
3. Please confirm the Fund will file  a fidelity bond under Form 40-17G.
4. Please apply any comments on a particular Fund gl obally to each of the Funds, if applicable.

Ms. Allison Fumai
September 15, 2025
Page 2
FOR ALL FUNDS - PROSPECTUS
Expense Example
5. Please provide updated figures in the expense example for each Fund.
BARON FIRST PRINCIPLES ETF
Investments, Risks, and Performance, pages 1-4
6. Please consider explaining the term  “Principles First” and how it re lates to the Fund’s objectives and
strategies.
7. Under principal investment stra tegies of the Fund, the first para graph states that the Fund may
borrow money from banks (leverage) in an amount up to one-third of its to tal assets. Please confirm
whether the Fund will employ leverage within the fi rst 12 months of operations. If so, please add a
line item for interest expense to the fee table.
8. On page 2, the staff notes principal risk fa ctors, “Industry Concentration” and “Risks of
Emphasizing a Sector or Industry. ” Please identify the specific i ndustry or sectors the Fund may
concentrate in and include related disclosures in the principal investment strategies section.
9. The staff notes there is a “Co mmon CEO Risk” for this Fund. Please include this discussion in the
principal investment strate gies section, as there is no reference to Fund’s investment in companies
with certain persons in common (including chief ex ecutive officers or others fundamental to the
success of the company).
10. Under “ETF Structure Risks,” please also disc lose that, where all or a portion of the ETF’s
underlying securities trade in a market  that is closed when the market in which the ETF’s shares are
listed and trading in that market is open, there ma y be changes between the last quote from its closed
foreign market and the value of such security during the ETF’s domestic trading day. In addition,
please note that this in turn could lead to differences between the market price of the ETF’s sharesand the underlying value of those shares.
BARON GLOBAL DURABLE ADVANTAGE ETF Investments, Risks, and Performance, pages 5-9
11. Please supplementally explain wh at is meant by “durable advantage” in the Fund’s name with
respect to the Fund’s investment strategy, and how it is measured.
12. Please disclose that this Fund is classified as a “diversi fied” investment company, consistent with the
disclosure on page 1 of the Statemen t of Additional Information (“SAI”).

Ms. Allison Fumai
September 15, 2025
Page 3
13. The first paragraph states, “The Fund seeks to  achieve its investment objective by investing
primarily in equity securities in the form of common stock of established and emerging markets
companies located throughout the world, with capita lizations within the range  of companies included
in the MSCI ACWI Index Net USD.”
(a) In the disclosure, please define “emerging markets companies,” and the criteria used to
determine how the Fund determines a co mpany is an emerging markets company.
(b) Please identify the market capitalization range for the MSCI ACWI Index Net USD in the
disclosure. You can note that the range provided is as of a particular date, and that it may
fluctuate over time.
14. The second paragraph states in part, “The Adviser seeks to invest primarily  in what it believes are
unique, well-managed, competitively advantaged businesses…” Please provide examples or explainwhat is meant by “unique” in the disclosure.
15. On page 6, the staff notes principal risk fact ors, “Concentration” (tha t the Fund may hold large
positions in a “relatively limited number of issuer s, investments or indus tries”) and “Risks of
Emphasizing a Region, Sector or I ndustry.” Please identify the speci fic types of issuers, region,
sector or industry that the Fund may concentrat e/emphasize and update th e principal investment
strategy disclosure accordingly.
16. The staff notes “Technology” risk which describes the risk of investing in technology companies. If
investments in technology companies are a principal investment strategy of the Fund, please include
related disclosure in the principal investment strategy section.
17. The staff notes “Emerging Markets and Developing  Countries Risk” (page 7) . Please clarify in the
disclosure whether the term “developing c ountries” is synonymous with “emerging markets”
(referenced in the principal investment strategies  discussion). If they are investments in different
regions, to the extent they are pr incipal investment strategies, please include related disclosures for
both in the principal investment strate gies and the principal risks sections.
18. On pages 7-8, the staff notes the following princi pal risk factors with extensive discussions under
each risk: “Risks Associated with China and H ong Kong,” “Risks Associated with Investing in
Chinese Companies through Variable Interest Ent ities” and “Risks relate d to Variable Interest
Entities.” To the extent investments in China (and through Variable Inte rest Entities) and Hong
Kong are principal investment stra tegies of the Fund, please update th e principal investment strategy
disclosures accordingly.
19. Under “ETF Structure Risks,” please also disc lose that, where all or a portion of the ETF’s
underlying securities trade in a market  that is closed when the market in which the ETF’s shares are
listed and trading in that market is open, there ma y be changes between the last quote from its closed
foreign market and the value of such security during the ETF’s domestic trading day. In addition,
please note that this in turn could lead to differences between the market price of the ETF’s sharesand the underlying value of those shares.

Ms. Allison Fumai
September 15, 2025
Page 4
BARON SMID CAP ETF
Investments, Risks, and Performance, pages 11-14
20. The first sentence of this section states that the Fund will invest at least 80% of its net assets in
securities of small- and mid-sized companies. Please disclose the specific types of securities inwhich the Fund intends to invest ( e.g., equity securities).
21. Please include the dollar range of the market capitalization of the securities in the Russell Midcap
Growth Index that is referenced in the principal investment strategies section. You can note that the
range provided is as of a particular date, and that it may fluctuate over time.
22. Please include any policy to concentrate in securiti es or issuers in a par ticular industry or group of
industries, or any geogr aphic concentrations.
23. On page 12, the staff notes “Technology” and “H ealth Care Sector Ri sk.” If investments in
technology or health care companies are principal investment strategies of  the Fund, please include
related disclosures in the principal investment strategy section.
BARON FINANCIALS ETF Investments, Risks, and Performance, pages 15-19
24. On page 16, the staff notes the following principal risk factors: “FinTech Companies,” “Information
Technology Sector” and “IT Services Industry.” Pl ease clarify in the disclosure whether the
companies described in each of these risk factors are part of the Financials and Financials-related
companies that constitute the Fund’s 80% policy. If  not, please include related disclosures in the
investment strategy section.
25. The staff notes “Developi ng Countries” as a principa l risk. Please clarify in the disclosure whether
the term “developing countries” is synonymous with “emerging markets” (referenced in the principal
investment strategies disc ussion). If they are investments in diffe rent regions, to the extent they are
principal investment stra tegies, please include related disclosure s for both in the principal investment
strategies and the principal risks sections.
26. Under “ETF Structure Risks,” please also disc lose that, where all or a portion of the ETF’s
underlying securities trade in a market  that is closed when the market in which the ETF’s shares are
listed and trading in that market is open, there ma y be changes between the last quote from its closed
foreign market and the value of such security during the ETF’s domestic trading day. In addition,
please note that this in turn could lead to differences between the market price of the ETF’s sharesand the underlying value of those shares.
27. In the “Performance” section (page 18), the disclosure indicates the Fund has adopted the
performance of the “Predecessor Fund” as a result of a would-be reor ganization (the transfer of the

Ms. Allison Fumai
September 15, 2025
Page 5
Predecessor Fund’s assets and lia bilities to the Fund). Please supplementally provide the timing of
the reorganization, and also confirm that the F und will not sell shares using this registration
statement until the reorganization is consummated.
BARON TECHNOLOGY ETF Investments, Risks, and Performance, pages 21-25
28. On the same page, the staff notes “Consumer Di scretionary Sector” risk. If investments in the
consumer discretionary sector is a principal inve stment strategy of the Fu nd, please include related
disclosure in the inve stment strategy section.
29. Under “ETF Structure Risks,” please also disc lose that, where all or a portion of the ETF’s
underlying securities trade in a market  that is closed when the market in which the ETF’s shares are
listed and trading in that market is open, there ma y be changes between the last quote from its closed
foreign market and the value of such security during the ETF’s domestic trading day. In addition,
please note that this in turn could lead to differences between the market price of the ETF’s sharesand the underlying value of those shares.
30. In the “Performance” section (page 24), the disclosure indicates the Fund has adopted the
performance of the “Predecessor Fund” as a result of a would-be reor ganization (the transfer of the
Predecessor Fund’s assets and liabilities to the Fund). Please s upplementally provide the timing of
the reorganization, and also confirm that the F und will not sell shares using this registration
statement until the reorganization is consummated.
Information about the Funds, pages 27-28
31. On page 27, the disclosure states that the Bar on First Principles ETF, Baron SMID Cap ETF, Baron
Financials ETF and Baron Technology ETF  may invest in American Depository Receipts, Global
Depository Receipts, European Depository Receipts or  directly in the securities of non-U.S. issuers,
provided that the aggregate amount of such invest ments does not exceed 35% of a Fund’s respective
total assets at the time of purchase.  Please include this information in Item 4 for each Fund since the
current disclosure only has general references to investments in “securities” or “equity securities.”
32. The disclosure under the heading, “Baron Global Durable Advantage ETF,” states, “The Fund may
also invest up to a maximum of 25% in Chin ese companies through Variable Interest Entities
(‘VIEs’) and directly via Stock Connect.” Please include this di sclosure in Item 4 as well.
33. On page 28, the disclosure states, “The Funds may invest in debt securities that have a rating of, or
equivalent to, at least ‘BBB’ by S&P Global Ratings or ‘Baa’ by M oody’s Investors Services, Inc.,
or if unrated, are judged by the Adviser to be of comparable quality.” Please add here that each Fund
may invest up to 35% of its total assets in such securities, consistent with the disclosure on page 9 ofthe SAI.

Ms. Allison Fumai
September 15, 2025
Page 6
Investment Criteria an d Process, page 29
34. The second and third full paragraphs  describe the Adviser’s applicati on of environmental, social, and
governance (“ESG”) factors. In the second paragra ph, the disclosures states, “The Adviser applies an
exclusionary screen for investments for all of its investment strategies  and Funds which prohibits the
set-up of potential investments in companies in the adult entertainment, civilian firearms, clustermunitions, and tobacco indus tries.” (emphasis added)
(a) Please specify the factors applied by this exclusionary screen, including any quantitative
thresholds (e.g., revenue) or qualitative factors used to determine a company's industry
classification or whether a company is engaged in the excluded activity.
(b) The third paragraph discloses, “Because the Funds are not ESG-focused funds, these
considerations may not be conclusive or employed in the analysis of all companies , and
securities of companies may be purchased and/or retained by the Funds for reasons other than
ESG factors.” (emphasis added) Pl ease reconcile this statement with  the one above that states the
adviser applies an exclusionary  screen for all investments.
(c) The staff notes there is a “Sustainability Risk” (page 37). Please consider incorporating the risk
of relying on third-party ESG ratings and research (discussed on page 29).
35. The staff notes the risk factor, “Special S ituations” (page 37), that discusses equity swap
transactions. Please confirm the accuracy of this h eading. Please note there is a “Special Situations”
risk under the Baron SMID Cap ETF (page 15) with a different disclosure de scribing events such as
the development of new products, ma nagement change, acquisitions, etc.
STATEMENT OF ADDITIONAL INFORMATION Fund Policies, pages 12-13
36. With respect to the Baron Global Durable A dvantage ETF, Baron SMID Cap ETF and Baron
Financials ETF, please disclose the )und’s diversification policy.
Investment Advisory and Ot her Services, pages 28-31
37. On page 28, under the heading, “Investment Advisory  and Other Services,” the disclosure states,
“Mr. Baron is the controlling st ockholder of BCG.” Plea se specify which Baron this references by
including the first name.
38. In the same section, the disclosure indicates that  the Adviser may waive receipt of its fees. Please
confirm whether the Adviser can recoup such waived  fees and, if so, please disclose the terms of
recoupment.

Ms. Allison Fumai
September 15, 2025
Page 7

Financial Statements, pages 41-43
39. Page 42 of the SAI, under the heading, “Offering and Organizational Costs”:
 (a) Please explain if the offering cost s may be recouped by the Adviser.
(b) Provide estimated organizational costs.
(c) Explain if the Adviser will also absorb the organizational costs.
 DECLARATION OF TRUST OF BARON ETF TRUST (“Declaration of Trust”)  40. Article VIII, Section 8.9 (Derivative Actions) states in relevant part, that shareholders may not bring
a derivative action unless the complainin