Staff Comment: The Staff requested a completed fee table and expense example for the Fund at least a week prior to the effective date of the registration statement.

Response: The Registrant has provided completed fee tables and expense examples for the Fund in Appendix A to this letter.

Staff Comment: The Staff asked the Registrant to confirm if any acquired fund fees and expenses (“AFFE”) will exceed 0.01% of the average net assets of the Fund. If so, the Registrant should include these fees and expenses as a separate line item in the fee table.

Response: The Registrant confirms that AFFE will not exceed 0.01% of the average net assets of the Fund.

Staff Comment: The Staff stated that, to disclose a fee waiver in the fee and expense table, it must be in place for at least one year.

Response: The Registrant acknowledges the Staff’s comment and confirms that the fee waiver for the Fund will be in place for at least one year.

Staff Comment: The Staff asked the Registrant to confirm that Janus Henderson Investors US LLC (the “Adviser”) will only be able to recoup previously waived expenses so long as such recoupment will not result in the Fund exceeding the lesser of the expense limit in effect at the time of the waiver or the expense limit at the time of recoupment.

Staff Comment: The Staff noted that, pursuant to Rule 35d-1 under the Investment Company Act of 1940, as amended, the Fund should adopt an 80% investment policy that encompasses investments in U.S. dividend-paying securities.

Staff Comment: As it relates to the Fund’s investments in real estate investment trusts (“REITs”), the Staff asked the Registrant to disclose that dividends from REITs may not be qualified dividends for tax purposes.

Abigail Murray, Esq.

Since the Fund is new, Other Expenses are based on the estimated expenses that the Fund expects to incur in its initial fiscal period.

The Adviser has contractually agreed to waive its investment advisory fee and/or reimburse operating expenses to the extent that the Fund’s total annual fund operating expenses (excluding shareholder servicing fees, such as transfer agency fees (including out-of-pocket costs), administrative services fees and any networking/omnibus fees payable by any share class, brokerage commissions, interest, dividends, taxes. acquired fund fees and expenses, and extraordinary expenses) exceed 0.75% until at least January 31 , 2024. The contractual waiver may be terminated or modified prior to this date only at the discretion of the Board of Trustees. For a period beginning with the Fund’s commencement of operations (December 20, 2022) and expiring on the third anniversary of the commencement of operations, or until the Fund’s assets meet the first breakpoint in the investment advisory fee schedule (0.60% of the first $2 billion of the average daily closing net asset value of the Fund), whichever occurs first, the Adviser may recover from the Fund fees and expenses previously waived or reimbursed if the Fund’s expense ratio, including recovered expenses, falls below the expense limit. There is no guarantee that the Fund’s assets will reach this asset level.

Since the Fund is new, Other Expenses are based on the estimated expenses that the Fund expects to incur in its initial fiscal period.

The Adviser has contractually agreed to waive its investment advisory fee and/or reimburse operating expenses to the extent that the Fund’s total annual fund operating expenses (excluding shareholder servicing fees, such as transfer agency fees (including out-of-pocket costs), administrative services fees, brokerage commissions, interest, dividends, taxes, acquired fund fees and expenses, and extraordinary expenses) exceed 0.75% until at least January 31, 2024. The contractual waiver may be terminated or modified prior to this date only at the discretion of the Board of Trustees. For a period beginning with the Fund’s commencement of operations (December 20, 2022) and expiring on the third anniversary of the commencement of operations, or until the Fund’s assets meet the first breakpoint in the investment advisory fee schedule (0.60% of the first $2 billion of the average daily closing net asset value of the Fund), whichever occurs first, the Adviser may recover from the Fund fees and expenses previously waived or reimbursed if the Fund’s expense ratio, including recovered expenses, falls below the expense limit. There is no guarantee that the Fund’s assets will reach this asset level.