Cybersecurity disclosure

While respectfully noting that it may update the disclosure further in the ordinary course, the Fund confirms that it will revise the disclosure, as follows, in response to the Staff’s comment to revise this disclosure to be in plain English: 6 Securities and Exchange Commission June 25, 2024 The preferred partnership program also assists smaller and medium sized companies in gaining access to enterprise level sales teams which that can be more attentive in addressing service issues they these companies may experience. One of the biggest differentiators within the program is our access to the Blackstone Sourcing Center, which is a team of 13 + procurement professionals, who run eRFPs and eAuctions for companies at no cost. This team has run over 280 projects and tensioned over $750 million worth of RFPs and eAuctions for Blackstone Credit companies. As of June 30 As of December 31 ,…

The Trust has incorporated this comment and the following disclosure will be added: Liquid staking applications pose risks associated with concentration of control. Validators must deposit 32 ether to activate a unique validator key pair that is used to sign block proposals and attestations on behalf of its stake (i.e., vote on its view of the chain). For every 32 ether deposit that is staked, a unique validator key pair is generated. An application built on the Ethereum network, or a single node operator, can manage many validator key pairs. For example, Lido, an application that provides a so-called “liquid staking” solution which permits holders of ether to deposit them with Lido, which stakes the ether while issuing the holder a transferrable token, is reported by some sources to have or have had up to 275,000 validator key pairs (each representing 32 staked ether) divided across…

We filed disclosure regarding the Cybersecurity Incident under Item 1.05 of Form 8-K for the following reasons, notwithstanding our determination that the Cybersecurity Incident had not had a material impact on our operations and was not reasonably likely to materially impact our financial condition or results of operations: 1. At the time of our initial filing, the Commission’s cybersecurity incident disclosure rule pursuant to Item 1.05 of Form 8-K (the “New Rule”) had been in effect less than two months, and only a small number of issuers had disclosed cybersecurity incidents pursuant to the New Rule. Moreover, there was limited staff guidance regarding compliance with the New Rule. Therefore, it was highly uncertain how companies should approach compliance during the course of a potentially significant cybersecurity incident, what investor and other market participant expectations…

The Company respectfully acknowledges the Staff’s comment. In response to the Staff’s comment, the Company determined to file the Initial Form 8-K under Item 1.05 of Form 8-K because the Company determined that it had experienced a material cybersecurity incident. In reaching its determination of materiality, the Company took into consideration the directives of the Commission in Release Nos. 33-11216; 34-97989; 88 FR 51896 (Cybersecurity Risk Management, Strategy, Governance and Incident Disclosure) (hereafter, the “Final Rule Release”) as highlighted below: The Final Rule Release states, in relevant respect, as follows: “The rule’s inclusion of ‘financial condition and results of operations’ is not exclusive; companies should consider qualitative factors alongside quantitative factors in assessing the material impact of an incident. By way of illustration, harm to a company’s…

We respectfully acknowledge the Staff’s comment. First, our interpretation of Item 1.05(a) is that the disclosure trigger for Item 1.05(a) is the registrant’s determination that a cybersecurity incident is “material” – as the adopting release states, “[t]he obligation to file the Item 1.05 disclosure is triggered once a company has developed information regarding an incident sufficient to make a materiality determination….” (emphasis added). 1 The adopting release explains this trigger as follows: In the majority of cases, the registrant will likely be unable to determine materiality the same day the incident is discovered. The registrant will develop information after discovery until it is sufficient to facilitate a materiality analysis. At that point, we believe investors are best served knowing, within four business days after the materiality determination, that the incident occurred…

Out of an abundance of caution based on the fluidity of a materiality determination while a cybersecurity incident investigation is ongoing and review of the disclosures from other issuers being filed under Item 1.05 of Form 8-K, we felt that it was appropriate to disclose our cybersecurity incident promptly with the information we had at the time. Based on the Statement from the Director of the Division of Corporation Finance of the Commission released on May 21, 2024 (Disclosure of Cybersecurity Incidents Determined to be Material and Other Cybersecurity Incidents) and the ultimate results of our cybersecurity incident investigation, in retrospect it appears that a filing under Item 8.01 of Form 8-K would have been more appropriate. In the event of any future cybersecurity incidents, we understand the materiality requirement for disclosure under Item 1.05 of Form 8-K. Thank you for…

The Registrant respectfully directs the Staff’s attention to disclosure in the Fund’s registration statement, which reads: Cybersecurity Risk. Investment companies, such as the Fund, and their service providers are exposed to operational and information security risks resulting from cyberattacks, which may result in financial losses to the Fund and its shareholders. Cyber-attacks include, among other behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on websites, “ransomware” that renders systems inoperable until ransom is paid, the unauthorized release of confidential information, or various other forms of cybersecurity breaches. Cyber-attacks affecting the Fund, Calamos Advisors, custodian, transfer agent, distributor, market maker, authorized participants, administrator, intermediaries, trading counterparties, and other third-party…

The Registrant respectfully directs the Staff’s attention to disclosure in the Fund’s registration statement, which reads: Cybersecurity Risk. Investment companies, such as the Fund, and their service providers are exposed to operational and information security risks resulting from cyberattacks, which may result in financial losses to the Fund and its shareholders. Cyber-attacks include, among other behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on websites, “ransomware” that renders systems inoperable until ransom is paid, the unauthorized release of confidential information, or various other forms of cybersecurity breaches. Cyber-attacks affecting the Fund, Calamos Advisors, custodian, transfer agent, distributor, market maker, authorized participants, administrator, intermediaries, trading counterparties, and other third-party…

Upon detecting that a third party had gained unauthorized access to portions of the Company’s information technology environment, the Company expeditiously assessed the impact of the incident with third-party advisors pursuant to the Company’s previously established cyber incident response protocols. In light of the containment measures, which included shutting down certain of the Company’s systems, and understanding the importance of prompt disclosure, the Company determined that it was appropriate to file a Current Report on Form 8-K to disclose the incident under Item 1.05. The Company is aware of the statement issued by Erik Gerding, Director, Division of Corporation Finance of the Commission, on May 21, 2024, which was subsequent to the filing of the Company’s Current Report on Form 8-K, clarifying the Staff’s position with respect to the use of Item 1.05 and Item 8.01 to report…

On March 10, 2024, MarineMax determined that it had experienced a cybersecurity incident. More specifically, MarineMax was the victim of a ransomware attack. Upon detection, MarineMax immediately took containment actions and initiated its business continuity protocols. Although the containment action resulted in some disruption to a portion of its business, MarineMax’s business and retail operations were not disrupted for an extended period of time, and the company’s operation was able to continue in all material respects. As such, as of March 12, 2024, the incident and containment efforts did not have a material impact on the company’s operations. Nevertheless, the Supreme Court has held that a fact is material if there is “a substantial likelihood that the . . . fact would have been viewed by the reasonable investor as having significantly altered the ‘total mix’ of information made…

The Company respectfully acknowledges the Staff’s comment and hereby provides the following explanation. OraSure Technologies, Inc. 220 East First Street Bethlehem, PA 18015 Upon becoming aware of a cybersecurity incident (“Incident”), the Company took steps to contain the Incident and secure its networks and data. Concurrently with these efforts, the Company initiated a process to assess whether the Incident had, or would have, a material impact on the Company’s financial condition or results of operations. As a result of this assessment, the Company concluded that the Incident did not have a material impact on the Company’s operations, financial systems, or its financial condition. However, in accordance with SEC guidance, the Company also considered qualitative factors, such as potential reputational harm and impact on customer and vendor relationships, and the possibility of…

The Company respectfully acknowledges the Staff’s comment and notes that as of February 9, 2024, the date of the original Form 8-K, the Company’s investigation into the facts, circumstances and the impact of the cybersecurity incident remained ongoing. As a result, the Company was balancing the need for prompt disclosure for the benefit of investors and the Company’s other stakeholders against the dynamic and ongoing fact-finding process, and ultimately elected to file the Form 8-K under Item 1.05 out of an abundance of caution given the Company was unable at the time to assess materiality conclusively. Subsequent to the Company’s original Form 8-K filed on February 9, 2024 and the Company’s amended Form 8-K filed on March 29, 2024, the Commission released the statement of the director of the Division of Corporation Finance dated May 21, 2024 containing guidance for public companies…

We have revised this accordingly in the amended filing.

The Registrant has moved the referenced disclosure to Currency Risk. * * * * * * * * * * * * Please feel free to contact me at (617) 235-4636 to discuss any questions or comments you may have regarding the foregoing responses. Thank you for your assistance. Sincerely, /s/ Jessica Reece Jessica Reece, Esq. cc: Andrew Lawson, Esq. Barbara Nelligan 4 APPENDIX A FEE AND EXPENSE TABLE AND EXPENSE EXAMPLE Shareholder Fees (Fees paid directly from your investment) Maximum Sales Charge (Load) Imposed on Purchases (as a percentage of offering price) None Maximum Deferred Sales Charge (Load) (as a percentage of amount redeemed) None Redemption Fee (as a percentage of amount redeemed) None Annual Fund Operating Expenses (Expenses that you pay each year as a percentage of the value of your investment) Management Fees 1.00 % Distribution (12b-1) Fees None Other Expenses 3.01 % Total Annual Fund…

In response to the Staff’s comment, we note the following: The SEALCOIN project is currently in the R&D stage – that is, as noted above, research of the technical feasibility and analysis of the development of potential service applications. As such, we are not in a position to meaningfully assess the risks that would be associated with the SEALCOIN project once implemented, and the materiality of some or all of such risks from the perspective of our shareholders. For example, at the present time we do not know if we will choose to issue a new cryptocurrency or build out the project implementation with pre-existing cryptocurrency to tokenize access to the SEALCOIN Service Platform, or if we will decide to create a new entity to issue the tokens, or line up a third party to issue the tokens. It is only when the SEALCOIN project is further along in its development that the assessment of…

In response to the Staff’s comment, we note the following: The SEALCOIN project is currently in the R&D stage – that is, as noted above, research of the technical feasibility and analysis of the development of potential service applications. As such, we are not in a position to meaningfully assess the risks that would be associated with the SEALCOIN project once implemented, and the materiality of some or all of such risks from the perspective of our shareholders. For example, at the present time we do not know if we will choose to issue a new cryptocurrency or build out the project implementation with pre-existing cryptocurrency to tokenize access to the SEALCOIN Service Platform, or if we will decide to create a new entity to issue the tokens, or line up a third party to issue the tokens. It is only when the SEALCOIN project is further along in its development that the assessment of…

The Registrant believes the cybersecurity risk disclosure included in Item 9 under the “Principal Investment Risks” heading is sufficient. * * * * * If you have any questions or additional comments, please call the undersigned at 614-469-3353. Very truly yours, /s/ Andrew Davalla Andrew Davalla

The Trust acknowledges the Staff’s comment; however, it does not believe that cybersecurity is a principal risk for the Fund. The Trust believes that the “ Special Risks Related to Cyber Security ” language contained in the Fund’s SAI Part B of Form N-1A adequately discloses any associated cyber security risks inherent to each ETF’s investment strategy. Accordingly, the Trust respectfully declines to make any changes in response to this comment.

In response to the Staff’s comment, we respectfully advise the Staff that we will revise our disclosure as follows: Pursuant to the Basic Law, which is a national law of the PRC and the constitutional document for Hong Kong, national laws of the PRC shall not be applied in Hong Kong except for those listed in Annex III of the Basic Law and applied locally by promulgation or local legislation. The Basic Law expressly provides that the national laws of the PRC which may be listed in Annex III of the Basic Law shall be confined to those relating to defense and foreign affairs as well as other matters outside the autonomy of Hong Kong. The basic policies of the PRC regarding Hong Kong as a special administrative region of the PRC are reflected in the Basic Law, providing Hong Kong with a high degree of autonomy and executive, legislative and independent judicial powers, including that of…

The Registrant respectfully directs the Staff’s attention to disclosure in the Fund’s registration statement, which reads: Cybersecurity Risk. Investment companies, such as the Fund, and their service providers are exposed to operational and information security risks resulting from cyberattacks, which may result in financial losses to the Fund and its shareholders. Cyber-attacks include, among other behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on websites, “ransomware” that renders systems inoperable until ransom is paid, the unauthorized release of confidential information, or various other forms of cybersecurity breaches. Cyber-attacks affecting the Fund, Calamos Advisors, custodian, transfer agent, distributor, market maker, authorized participants, administrator, intermediaries, trading counterparties, and other third-party…

The Trust confirms that it does not consider cybersecurity risk to be a principal risk for the Fund.

The Trust confirms that it does not consider Cybersecurity Risk to be a Principal Risk for the Fund.

The Registrant has revised the Registration Statement in response to the Staff’s comment to remove the reference to generally, harmonize the disclosure in the summary and statutory prospectuses, and specify that the “substantial portions of their revenue” means greater than 50%. 19.

In response to the Staff’s comment, the Company has revised the disclosure on page 68 of the Registration Statement. Background of the Business Combination, page 115

In response to the Staff’s comment, we have revised our disclosures on the cover page, Prospectus Summary, Risk Factor and elsewhere of the Amendment No.2. We respectfully advise the Staff that we have made disclosures of our completion of the cybersecurity review in Amendment No.1. (2) Ordinary shares issued to Shanghai Xinhui Investment Consulting Co., Ltd. (“Shanghai Xinhui”), page F-22

In response to this comment, the Company has revised the risk factor under the heading “ Improper activities by third parties, exploitation of encryption technology, new data-hacking tools and discoveries and other events or developments may result in future intrusions into or compromise of our networks and technology systems. ” on page 16 of the Registration Statement. Capitalization, page 25

Drawing on ASC 606-10-25-19 through 22. Cycurion’s management provides the following analysis of its MSSP service offering that should be accounted for as a single performance obligation. >> Distinct Goods or Services 25-19 - A good or service that is promised to a customer is distinct if both of the following criteria are met: a. The customer can benefit from the good or service either on its own or together with other resources that are readily available to the customer (that is, the good or service is capable of being distinct). Cycurion does not sell monitoring time, security software-tools, and breach resolution as stand-alone services as the customer would Not receive the benefits of these items if they were not sold as an integrated package. The cybersecurity needs to regularly monitor the customer cybersecurity environment, stay up to date on cyberthreats and solutions, maintain…

Cycurion’s SaaS is delivered continuously over time; it is a subscription service where Cycurion provisions a suite of security software tools to its customers accessed via the internet that allows a customer to protect itself from cyber attack using multiple tools within the suite. This subscription service is recognized to revenue on a monthly basis.

The Company respectfully acknowledges the Staff’s comment and has addressed the Staff’s comment revising the risk factors at pages 44-45 of the Amended DRS. 7 Risk Factors Relating to the Business Combination, page 57

The Trust has moved the noted risks to the Additional Risks section. 24.

Pursuant to the comment, we have revised the disclosure on page 37 of the Registration Statement. Cover Page

The Company respectfully advises the Staff that a new risk factor entitled “Our cybersecurity measures may not protect us from system failures or interruptions.” has been added on page 44 of the Registration Statement, which includes a description of the role of the board of directors in overseeing cybersecurity risks. Any disruption in the supply chain of raw materials and our products could adversely impact our ability to produce and deliver products., page 34

In accordance with the Staff’s comment, the above referenced disclosure has been deleted in its entirety and replaced with the following: The Fund was reorganized on or about ___, 2024 from the ETFMG Prime Mobile Payments ETF (the “Predecessor Fund”), a series of the ETF Managers Trust, a Delaware statutory trust, into Amplify ETF Trust, a Massachusetts business trust. The Fund is a continuation of the Predecessor Fund and, therefore adopts the performance information of the Predecessor Fund (as shown below), which was managed by ETF Managers Group LLC. The Predecessor Fund commenced operations on July 15, 2015.

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

In accordance with the Staff’s comment, the above-referenced disclosure has been revised as follows: “To be included in the Index, companies from the Parent Index must derive at least 90% of their revenues from cyber security and must have a Revenue Contribution score of at least 1.25%.”

The Registrant respectfully declines to include cybersecurity risk as a principal risk for the Fund in the Fund’s summary prospectus but notes the following text is included as a non-principal risk for the Fund in response to Item 9 of Form N-1A. Cybersecurity Risk. Investment companies, such as the Fund, and their service providers are exposed to operational and information security risks resulting from cyberattacks, which may result in financial losses to the Fund and its shareholders. Cyber- attacks include, among other behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on websites, “ransomware” that renders systems inoperable until ransom is paid, the unauthorized release of confidential information, or various other forms of cybersecurity breaches. Cyber-attacks affecting the Fund, Calamos Advisors, custodian, transfer agent,…

In response to the Staff’s comment, the Company notes that GCT has not experienced any cybersecurity incidents or risks in its supply chain based on third party products that had a significant impact on its business operation and financial performance. In addition, GCT has not identified any material trend or uncertainties in cybersecurity risk in the supply chain that will affect its financial performance in the foreseeable future. Therefore, the Company does not believe that a discussion on this topic in the MD&A will be warranted. Nevertheless, in response to the Staff’s comment, the Company has enhanced the risk factor disclosure on page 37 of the Amended Registration Statement to provide additional discussion on this topic.

The Company has revised the disclosure on the cover page and on pages [34, 84, and 110] of the Amended Registration Statement in response to the Staff’s comment. Financial Statements Unaudited Financial Statements of JVSPAC Acquisition Corp., page F-1

We have revised the document to disclose the nature of the oversight role of the board of directors to note that while our board of directors will oversee the management of our cybersecurity risk, our management will be responsible for the implementation and monitoring of day-to-day risk management policies, procedures and processes. Our board of directors has tasked our Chief Technology Officer and other appropriate management with the responsibility to manage our cybersecurity initiatives, including with respect to our customer data and game suppliers databases. Our board of directors will receive regular reports from management, including our Chief Technology Officer at least quarterly, on material cybersecurity risks and the degree of our Company’s exposure to those risks, and the development and implementation of appropriate policies and procedures to mitigate those risks.…

Comment complied with. The following has been added to the “Principal Risks” section: Cybersecurity Risk: Cybersecurity incidents may allow an unauthorized party to gain access to Fund assets, customer data, (including private shareholder information), or proprietary information, or cause the Funds, the Adviser, and/or other service providers (including custodians, sub-custodians, transfer agents and financial intermediaries) to suffer data breaches, data corruption or loss of operational functionality. A cybersecurity incident may disrupt the processing of shareholder transactions, impact a Fund’s ability to calculate its net asset values, and prevent shareholders from redeeming their shares. 9. Staff

The Registrant believes the cybersecurity risk disclosure included in Item 9 under the “Principal Investment Risks” heading is sufficient.

The Company respectfully advises the Staff that during China Glory’s operations from December 2020 to February 2022, the Company had not generated any revenue from, and had only incurred nominal expenses for, the operations of China Glory. In 2020, 2021 and 2022, the expenses incurred relating to China Glory were RMB1.6 million, RMB3.8 million and RMB1.5 million (US$224 thousand), respectively. These expenses were included in the “operating costs and expenses” of the Company’s consolidated statements of operations for each year, and consist primarily of payroll and related expenses. U.S. Securities and Exchange Commission Page 10 In response to the Staff’s comment, the Company respectfully proposes to revise the referenced disclosure on page 76 under “Item

The Company has revised the disclosure on the cover page and on pages 10 and 110 of the Registration Statement in response to the Staff’s comment. Summary, page 2

Management of Cycurion has determined that its managed security service practice is a bundle of cybersecurity software tools, and expert “24x7x365” monitoring and breach resolution services that are accounted for as a single performance obligation of Cycurion that is delivered over time (typically one month). The components of the bundle have individual commercial value; however, management believes that assigning a stand-alone value to each component would be impractical because, individually, each component could not be fully implemented or utilized unless packaged with the other components. Therefore, management concluded that the MSSP can only be sold as a bundle over time. At the time that Cycurion recognizes revenue, it has either already received funds in advance from its customer or is reasonably assured that it will collect funds from its customer. Funds that are received in…

Please see revised description of the business addressing business pages 17, 18 and 19. Principal Shareholders, page 21

As noted in the response to Comment 8, the Registrant has removed the references to each of the sub-industries, including those noted in the comment, for clarity and to be consistent with the Index Methodology White Paper. The Registrant has inserted “security” so that the disclosure now reads as follows: “In order to be classified in the digital security software category, RBICS requires that a company generate at least 50% of its revenue from digital security software.” Themes European Luxury ETF

We have included a risk factor stating that we are subject to material cybersecurity risks in our supply chain. We have addressed the measures taken to mitigate the cybersecurity risks in our supply chain.

The Company has revised the disclosure on the cover page and on pages 10, 76, 109, 110 and 111 of the Amended Registration Statement in response to the Staff’s comment. Summary, page 2 2. We reissue comment

The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has revised the disclosure on page 76 of the Amended Registration Statement as requested. 2 Forward Purchase Agreement, page 119

The Registrant notes that certain risks are not considered Principal Risks, but the Registrant believes such risks are appropriately included in the “More on Risks of Investing in the Fund” section of the prospectus. Please direct any comments or questions concerning this filing to the undersigned at (727) 299-1821. Very truly yours, /s/ Dennis P. Gallagher Dennis P. Gallagher Chief Legal Officer and Secretary Transamerica Funds

In response to the Staff’s comment, the Company undertakes to refrain from using terms such as “we” or “our” when describing activities or functions of the VIE and implying that the historical contractual agreements were equivalent to equity ownership in the VIE in its future Form 20-F filings. The Company also undertakes to revise the relevant disclosure in its future Form 20-F filings as follows (with deletions shown in strikethrough and additions in underline showing the changes against the disclosure in the 2022 Form 20-F), subject to such updates and adjustments to be made in connection with any material developments of the subject matter being disclosed. “ INTRODUCTION … ● “VIE” refers to Long-Spring Education Holding Group Limited , the variable interest entity, whose financial results have been consolidated into our consolidated financial statements based solely on contractual…

In response to the Staff’s comment, the Company respectfully advises the Staff to refer to the Company’s response to comment #4 above. October 18, 2023 Page 31

We acknowledge the Staff’s comment, and will revise the risk factor as follows in future filings: The disclosures in our reports and other filings with the SEC and our other public pronouncements may be subject to the scrutiny of regulatory bodies in the PRC. Our reports and other filings with the SEC are subject to SEC review in accordance with the rules and regulations promulgated by the SEC under the Securities Act and the Exchange Act. Our SEC reports and other disclosures and public pronouncements are currently not subject to the review or scrutiny of any PRC regulatory authority, except as described herein below. For example, the disclosure in our SEC reports and other filings are not subject to the review by the CSRC, a PRC regulator that is responsible for oversight of the capital markets in China. On February 17, 2023, with the approval of the State Council, the CSRC released…

In response to the Staff’s comment, we have included the following risk factor on pages 50 – 51 of the Registration Statement, which includes a disclosure of Bancorp 34’s board of directors’ role in overseeing cybersecurity risk management and the manner in which the board administers this oversight function. The board of directors’ role in overseeing cybersecurity risk management will not have an effect on the board’s leadership structure. Additional Risk Factor on pages 50 – 51: Our board and its committees oversee our cybersecurity, disaster recovery and business continuity risk management framework. Our governance oversight of cybersecurity, disaster recovery and business continuity risk management framework may not be effective in mitigating risks and/or losses. Our board of directors oversees our cybersecurity, disaster recovery and business continuity risk management framework.…

The Company respectfully advises the Staff that the Company’s former Executive Vice President and Chief Risk Officer, Lynn Sullivan, retired from these positions effective as of December 31, 2022. Ms. Sullivan remained an employee of the Company as an Advisor until June 30, 2023 to assist with the transition of her previous roles. Olivia Lindsay, then Deputy Chief Risk Officer, was promoted to Chief Risk Officer of the Company effective as of January 1, 2023. Furthermore, the Company respectfully advises the Staff that the Company intends to maintain the current risk oversight structure of the board of directors (the “Board”) that is currently in place; however, no decision has been made and the structure may change post-consummation once the combined company’s board of directors meets. Please see the description of the current risk oversight of the Board below, excerpted from the…

As noted in the response to Comment 8, the Registrant has removed the references to each of the sub-industries, including those noted in the comment, for clarity and to be consistent with the Index Methodology White Paper. Themes European Luxury ETF

The Registrant respectfully declines to include cybersecurity risk as a principal risk for the Fund in the Fund’s summary prospectus but notes the following is included as a principal risk for the Fund in response to Item 9 of Form N-1A. 6 Cybersecurity Risk. Investment companies, such as the Fund, and their service providers are exposed to operational and information security risks resulting from cyberattacks, which may result in financial losses to the Fund and its shareholders. Cyber-attacks include, among other behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on websites, “ransomware” that renders systems inoperable until ransom is paid, the unauthorized release of confidential information, or various other forms of cybersecurity breaches. Cyber-attacks affecting the Fund or Calamos Advisors, custodian, transfer agent, distributor,…

We have updated the Registration Statement as requested.

As a preliminary matter, we note that the Company mistakenly included two references in the 2022 Form 20-F to the “CRSC,” when it intended to refer to the “CSRC,” which is the acronym typically used for the China Securities Regulatory Commission. The Company used the correct acronym in several other places where it referenced the CSRC in the 2022 Form 20-F. To avoid any continuing confusion, we have also inserted the corrected acronym into our transcription of the Staff’s comment above. The Company wishes to advise the Staff that the Company (i) has not been required by the CSRC to obtain approval of or complete any filing with the CSRC with respect to any offering of the Company’s securities (collectively, the “ Prior Offerings ”), including the initial public offering of the Company’s predecessor Sohu.com Inc. on Nasdaq, which was completed before the Overseas Listing Laws (as defined…

The Registrant respectfully declines to include cybersecurity risk as a principal risk for the Fund in the Fund’s summary prospectus but notes the following text is included as a non-principal risk for the Fund in response to Item 9 of Form N-1A. Cybersecurity Risk. Investment companies, such as the Fund, and their service providers are exposed to operational and information security risks resulting from cyberattacks, which may result in financial losses to the Fund and its shareholders. Cyber- attacks include, among other behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on websites, “ransomware” that renders systems inoperable until ransom is paid, the unauthorized release of confidential information, or various other forms of cybersecurity breaches. Cyber-attacks affecting the Fund, Calamos Advisors, custodian, transfer agent,…