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abrdn ETFs Sponsor LLC

1900 Market Street, Suite 200

Philadelphia, PA 19103

September 26, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Attn:	Jessica Livingston
	John Dana Brown

	Re:	abrdn Palladium ETF Trust
		Registration Statement on Form S-3 (File No. 333-272037)
		Request for Acceleration of Effectiveness

Ladies and Gentlemen:

In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Securities Act”), abrdn Palladium ETF Trust (the “Trust”) respectfully requests that the effective date of the Registration Statement on Form S-3 (File No. 333-272037) (the “Registration Statement”) of the Trust be accelerated so that the Registration Statement shall become effective at 4:00 p.m. Eastern time on September 27, 2023, or as soon thereafter as practicable.

The undersigned, in making this request for acceleration, hereby states that it is aware of its obligations under Rule 461 and the other applicable provisions of the Securities Act.

The Trust requests that notification of such effectiveness be made by telephone call to Stephanie Capistron of Dechert LLP, legal counsel to abrdn ETFs Sponsor LLC, at 617-728-7127.

	Very truly yours,
	abrdn ETFs Sponsor LLC
	By:	/s/ Brian Kordeck
		Brian Kordeck
		Treasurer and Chief Financial Officer