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                                                            March 25, 2020

John Love
Chief Executive Officer
United States 12 Month Oil Fund, LP
1850 Mt. Diablo Boulevard, Suite 640
Walnut Creek, California 94596

       Re: United States 12 Month Oil Fund, LP
           Registration Statement on Form S-3
           Filed March 13, 2020
           File No. 333-237183

Dear Mr. Love:

       We have limited our review of your registration statement to those
issues we have
addressed in our comments. In some of our comments, we may ask you to provide
us with
information so we may better understand your disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Form S-3 filed March 13, 2020

General

1.     We note that you do not appear to be eligible to conduct a primary
offering pursuant to
       General Instruction I.B.1. on Form S-3. Please advise whether you
believe you are eligible
       to conduct a primary offering on Form S-3 pursuant to General
Instruction I.B.1. To the
       extent you do not meet the public float requirement in General
Instruction I.B.1., and
       instead intend to rely upon General Instruction I.B.6., please revise to
include the
       information required by Instruction 7 to General Instruction I.B.6. on
the prospectus cover
       page.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
 John Love
United States 12 Month Oil Fund, LP
March 25, 2020
Page 2

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Susan Block at 202-551-3210 or Dietrich King at
202-551-8071 with
any questions.



FirstName LastNameJohn Love                                Sincerely,
Comapany NameUnited States 12 Month Oil Fund, LP
                                                           Division of
Corporation Finance
March 25, 2020 Page 2                                      Office of Finance
FirstName LastName
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