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K&L GATES LLP
1601 K STREET, N.W.
WASHINGTON, DC 20006
T +1 202 778 9000 F +1 202 778 9100 klgates.com |
February 24, 2023
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: | Direxion Shares ETF Trust |
File Nos. 333-150525; 811-22201
Post-Effective Amendment No. 387
Ladies and Gentlemen:
We have acted as counsel to Direxion Shares ETF Trust (the Trust) in connection with the preparation of Post-Effective Amendment No. 387 to the Trusts Registration Statement on Form N-1A (the Amendment), and we have reviewed a copy of the Amendment being filed with the U.S. Securities and Exchange Commission.
Pursuant to paragraph (b)(4) of Rule 485 under the Securities Act of 1933, we represent that, based on our review and our assessment of the disclosure changes being effected by the Amendment, the Amendment does not contain disclosures that would render it ineligible to become effective pursuant to paragraph (b) of Rule 485.
Very truly yours, |
/s/ K&L Gates LLP |