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      The RBB Fund, Inc.

      615 East Michigan Street

      Milwaukee, Wisconsin 53202

      December 31, 2025

      VIA EDGAR TRANSMISSION

      Daniel Greenspan

      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 Mr. Greenspan:

      The purpose of this amended letter is to respond to the oral comments provided to U.S. Bank Global Fund Services on June 12, 2025 and December 30, 2025 by the staff (the “Staff”) of the Securities and Exchange
        Commission (the “Commission”) regarding the Company’s post-effective amendment (“PEA”) No. 346 to its registration statement on Form N-1A that was filed with the Commission pursuant to Rule 485(a)(1) under the Securities Act of 1933, as amended, on
        Form N-1A on April 16, 2025. The sole purpose of PEA No. 346 was to change the investment objective and investment strategy of the US Treasury 30 Year Bond ETF, US Treasury 20 Year Bond ETF, US Treasury 10 Year Note
          ETF, US Treasury 7 Year Note ETF, US Treasury 5 Year Note ETF, US Treasury 3 Year Note ETF, US Treasury 2 Year Note ETF, US Treasury 12 Month Bill ETF, US Treasury 6 Month Bill ETF, and US Treasury 3 Month Bill ETF (together, the “US Treasury
          ETFs”), and F/m 6-Month Investment Grade Corporate Bond ETF, F/m 9-18 Month Investment Grade Corporate Bond ETF, F/m 2-Year Investment Grade Corporate Bond ETF, F/m 3-Year Investment Grade Corporate Bond ETF, F/m 5-Year Investment Grade Corporate
          Bond ETF, F/m 7-Year Investment Grade Corporate Bond ETF, F/m 10-Year Investment Grade Corporate Bond ETF, F/m 20-Year Investment Grade Corporate Bond ETF, F/m 30-Year Investment Grade Corporate Bond ETF, and F/m 15+ Year Investment Grade
          Corporate Bond ETF (together, the “Corporate Bond ETFs”) (each US Treasury ETF and Corporate Bond ETF a “Fund” and together, the “Funds”) in connection with the determination of F/m Investments LLC, the investment adviser to the Funds, to change
          each Fund’s underlying index from a suite of indices offered by ICE Data Services to a new suite of indices offered by Bloomberg Index Services Limited. Each of the Funds is passively managed and tracks the performance of an underlying index, and
          accordingly the change in underlying index for each Fund necessitated a corresponding change in its investment objective and investment strategy.

      Furthermore, the Company notes that the names of the US Treasury ETFs are proposed to be redesignated as follows, by adding the word “F/m” to align with the naming convention of the other series of the Company
        managed by the Adviser:

              Current Name

              New Name

              US Treasury 30 Year Bond ETF

              F/m US Treasury 30 Year Bond ETF

              US Treasury 20 Year Bond ETF

              F/m US Treasury 20 Year Bond ETF

              US Treasury 10 Year Note ETF

              F/m US Treasury 10 Year Note ETF

              US Treasury 7 Year Note ETF

              F/m US Treasury 7 Year Note ETF

              US Treasury 5 Year Note ETF

              F/m US Treasury 5 Year Note ETF

              US Treasury 3 Year Note ETF

              F/m US Treasury 3 Year Note ETF

              US Treasury 2 Year Note ETF

              F/m US Treasury 2 Year Note ETF

              US Treasury 12 Month Bill ETF

              F/m US Treasury 12 Month Bill ETF

              US Treasury 6 Month Bill ETF

              F/m US Treasury 6 Month Bill ETF

              US Treasury 3 Month Bill ETF

              F/m US Treasury 3 Month Bill ETF

      For your convenience, each 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 No. 346. The Company confirms that the response to Staff comments provided in one section will be similarly updated in other parallel sections, except as noted by the Company.

      PROSPECTUS

      Corporate Bond ETFs

      US Treasury ETFs

      Summary Section – Principal Investment Strategies

      1. Comment: Please provide a
          supplemental response noting whether the change to the new benchmarks is anticipated to result in material costs to shareholders as a result of the repositioning of each Fund’s portfolio. If material costs are expected to be borne by the Funds,
          then please provide appropriate disclosure.

      Response: The Company confirms that the change to the new benchmarks is not expected to result in material costs to shareholders.

      Corporate Bond ETFs

      Summary Section – Principal Investment Strategies

      2. Comment: The fourth
          paragraph states that “The Fund may invest in securities of other affiliated and unaffiliated ETFs registered under the Investment Company Act of 1940, as amended, that invest primarily in Fund eligible investments (collectively, “Underlying
          Funds”) to the extent permitted by applicable law and subject to certain restrictions.” Please provide a supplemental response noting whether investing in other ETFs is consistent with a Corporate Bond ETF’s principal investment strategy to
          invest in investment grade corporate bonds.

      Response:  The Company confirms that investing in other affiliated and unaffiliated ETFs is consistent with the Corporate Bond ETFs’ principal investment
        strategy because the Corporate Bond ETFs invest in Underlying ETFs that invest primarily in Fund eligible investments, which are primarily investment grade corporate bonds, and in Underlying ETFs that invest in U.S. Treasury securities for cash
        management purposes.

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      Summary Section – Principal Investment Strategies – The Underlying Index and Parent Indices

      3. Comment: The F/m 6-Month Investment Grade Corporate Bond ETF and F/m 9-18 Month Investment Grade Corporate Bond ETF each state that “[t]here are two Parent Indices with respect to the Underlying Index” for such Fund.
          Please consider revising the disclosure to clarify the relationship between each Parent Index and the Underlying Index. In addition, please add
          disclosure about the types of “screening rules” used in selection securities under the 144A Parent Index.

      Response: The Company will clarify the relationship between each Parent Index and the Underlying Index and will add disclosure about the types of “screening rules” used in
        selecting securities as shown below (added text underlined and deleted text struck-through):

      The LCM Parent Index measures the performance of the most recent bond per issue across USD-denominated investment-grade corporate bonds with a specified maturity range. The LCM Parent Index is
        comprised of selected investment-grade corporate bonds of both U.S. and non-U.S. issuers that are (i) included in the 144A Parent Index and (ii) have at least $300 million face value amount outstanding. The Index Provider selects individual
        securities from the 144A Parent Index utilizing a rules-based approach that (i) screens individual securities for inclusion based on industry (industrial, utility and financial), investment grade (Baa3/BBB-/BBB- or higher), rate (fixed),
          taxability, denomination (U.S. dollar), domicile (no emerging markets), final maturity (at least three years), amount of shares outstanding ($750 million minimum par) and other factors and (ii) equally weighs by applying various
          screening rules and equally weighting the constituents. When selecting constituents, the determination occurs on the third-to-last business day of each month. For each specified maturity range, the eligible bonds must be at least the
        lower bound in years, but not including the upper bound, until final maturity, regardless of optionality, as of the end of the month. Enhanced Equipment Trust Certificate bonds are excluded from the LCM Parent Index. LCM Parent Index constituents
        are equally weighted and the securities included in the LCM Parent Index are updated by the Index Provider on the last business day of each month.

      US Treasury ETFs

      Summary Section – Principal Investment Strategies

      4. Comment: As none of the
          US Treasury ETFs have the word “Index” as part of such Fund’s name, please consider revising each Fund’s 80% test to reflect that the Fund invests at least 80% of its net assets in the type of investment suggested by
            its name, rather than investing at least 80% of its net assets in the component securities of the Underlying Index. Alternatively, consider changing the name of each US Treasury ETF so that there is a link between its name and its 80% test.

      Response: Respectfully, the Company notes that each US Treasury ETF normally invests at least 80% of its assets in securities that comprise the Underlying
        Index, which such securities are in each case solely the most recently issued US Treasury security of the maturity designated by the Underlying Index and the Fund’s 80% policy. Accordingly, each US Treasury ETF thereby normally invests at least 80%
        of its net assets in the type of investment suggested by its name, and as such no further disclosure is required.

      STATEMENT OF ADDITIONAL INFORMATION

      Corporate Bond ETFs

      US Treasury ETFs

      Investment Restrictions

      5. Comment: Please
          supplementally explain why the “concentration” investment restriction differs between the Corporate Bond ETFs and the US Treasury ETFs.

      Response: The  “concentration” investment restriction differs between the Corporate Bond ETFs and the US Treasury ETFs because the Corporate Bond ETFs invest in securities of issuers in various
        industries, while the US Treasury ETFs only invest in securities issued by the U.S. government.  Each Corporate Bond ETF will concentrate to approximately the same extent as  its Underlying Index concentrates in the
          securities of a particular industry or group of related industries.

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      * * * * *

      If you have any questions or comments regarding this filing, please do not hesitate to contact Edward Paz of U.S. Bank Global Fund Services at edward.paz@usbank.com.

      Very truly yours,

      /s/ James G. Shaw

      James G. Shaw

      Chief Financial Officer, Chief Operating Officer, and Secretary

      cc:          Alexander Morris, F/m Investments LLC

      Steven Plump, The RBB Fund, Inc.

      Jillian Bosmann, Faegre Drinker Biddle & Reath LLP

      Gwendolyn Williamson, Faegre Drinker Biddle & Reath LLP

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