SecProbe.io

CORRESP
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      The RBB Fund, Inc.

      615 East Michigan Street

      Milwaukee, Wisconsin 53202

      February 20, 2024

      VIA EDGAR TRANSMISSION

      Valerie Lithotomos

      Securities and Exchange Commission

      100 F Street, N.E.

      Washington, DC 20549

                Re:

                The RBB Fund, Inc. (the “Company”)

                File Nos.: 033-20827 and 811-05518

      Dear Ms. Lithotomos:

      The purpose of this letter is to respond to an oral comment provided to U.S. Bank Global Fund Services regarding the Company’s Post-Effective Amendment
        (“PEA”) No. 312 to its Registration Statement on Form N-1A. PEA No. 312 was filed with the Securities and Exchange Commission (the “Commission”) pursuant to Rule 485(a)(2) under the Securities Act of 1933, as amended, on Form N-1A on November 22,
        2023. The sole purpose of PEA No. 312 was to register two new series of the Company, the SGI Enhanced Cash ETF and the SGI Global Enhanced Income ETF (each, a “Fund” and together, the “Funds”). This letter responds to the Staff’s comment regarding the SGI Enhanced Cash ETF.

      The Registrant notes that the name of each Fund is proposed to be redesignated as follows:

              Prior Name:

              Redesignated Name:

              SGI Enhanced Cash ETF

              SGI Enhanced Core ETF

              SGI Global Enhanced Income ETF

              SGI Enhanced Global Income ETF

      The Company will file a subsequent PEA under Rule 485(b) to update any missing information, respond to Staff comments, and file updated exhibits to the
        Registration Statement.

      For your convenience, the applicable comment made by the Staff has been reproduced in bold typeface immediately followed by the Company’s response.
        Capitalized but undefined terms used herein have the meanings assigned to them in PEA 312.

      SGI Enhanced Cash ETF

      Comment: Please consider whether the term “Cash” should be removed from the name of the SGI Enhanced Cash ETF, given that this fund is
        not structured as a money market fund, in accordance with Rule 2a-7(b)(3) under the Investment Company Act of 1940, as amended.

      Response: The Company acknowledges the Staff’s comment and, as noted above, will redesignate the name of the applicable Fund as the SGI Enhanced Core
        ETF.

      * * * * *

      If you have any questions or comments regarding this filing, please do not hesitate to contact Hannah Hathaway of U.S. Bank Global Fund Services at (414)
        516-1557 or hannah.hathaway@usbank.com.

      Very truly yours,

      /s/ James G. Shaw

      James G. Shaw

      Secretary

                cc:

                David Harden, Summit Global Investments, LLC

                Steven Plump, The RBB Fund, Inc.

                  Jillian Bosmann, Faegre Drinker Biddle & Reath LLP