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Faegre Drinker Biddle & Reath LLP

One Logan Square, Ste. 2000

Philadelphia, PA 19103-6996

(215) 988-2700 (Phone)

(215) 988-2757 (Facsimile)

www.faegredrinker.com

June 18, 2025

VIA EDGAR TRANSMISSION

Mr. Ken Ellington

Ms. Kim McManus

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: The RBB Fund, Inc.
                                            (the “Registrant” or “RBB”)

                                            Registration Statement on Form N-1A

                                            (File Nos.: 033-20827 and 811-05518)

Dear Mr. Ellington and Ms. McManus:

The purpose of this letter is
to respond to oral comments provided by the staff of the Securities and Exchange Commission (“Staff”) regarding RBB’s
Registration Statement on Form N-1A (the “Registration Statement”) filed on May 2, 2025, to register Emerald Banking &
Finance Evolution Fund, Emerald Growth Fund and F/m Emerald Special Situations ETF (each a “Fund,” together, the “Funds”).

For your convenience, each comment
has been reproduced in bold typeface immediately followed by the Registrant’s response. Capitalized but undefined terms used herein
have the meanings assigned to them in the Registration Statement. The Registrant confirms that, where applicable, the responses to the
comments provided in one section of the Registration Statement will be similarly updated in other parallel sections of the Registration
Statement, except as noted by the Registrant. The changes to the disclosures discussed below will be reflected in an amendment to the
Registration Statement.

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Accounting Comments:

 1. Comment: Please disclose in
                                            a footnote to the fee tables for the Emerald Banking & Finance Evolution Fund and the
                                            Emerald Growth Fund that “Other Expenses” are based on estimated amounts for
                                            the current fiscal year, according to Instruction 6(a) to Item 3 of Form N-1A.

Response: The Registrant will make the
requested changes in the amended Registration Statement.

 2. Comment: Total Annual Fund
                                            Operating Expense before/after Fee Waiver/Expense Reimbursement for Class A of the Emerald
                                            Growth Fund pro forma shares (10.20% instead of 1.05% and 0.99% instead of 1.02%) and for
                                            Investor Class of the Emerald Growth Fund (1.07% instead of 1.10% and 1.04% instead of 1.07%)
                                            appear to be incorrect. Please revise.

Response: The Registrant will make the
requested changes in the amended Registration Statement.

 3. Comment: The Staff notes that
                                            the Emerald Banking & Finance Evolution Fund will invest in collective investment vehicles
                                            such as mutual funds and exchange-traded funds. If the Fund expects the Acquired Fund Fees
                                            and Expenses (“AFFE”) to exceed 0.01%, please list AFFE as a separate line item
                                            in the fee table.

Response: The Fund does not expect to incur
Acquired Fund Fees and Expenses in an amount equal to or in excess of 0.01% of the Fund’s average net assets during its initial
year of investment operations. Therefore, AFFE is not listed as a separate line item in the Fees and Expenses table.

 4. Comment: Please incorporate
                                            by reference each Predecessor Fund’s annual report for the fiscal year ended 4/30/2025,
                                            according to Article 3-18 of Regulation S-X.

Response: The Registrant will make the
requested changes in the amended Registration Statement.

 5. Comment: Please include hyperlinks
                                            to the financial statements of each Predecessor Fund that are incorporated in the registration
                                            statement.

Response: The Registrant will make the
requested changes in the amended Registration Statement.

 6. Comment: Please include consent
                                            from the Predecessor Funds’ auditor.

Response: The Registrant will make the
requested changes in the amended Registration Statement.

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Disclosure Comments:

 1. Comment: Please comply with
                                            any applicable comments issued on the related N-14 filing.

Response: The Registrant so confirms.

 2. Comment: Please confirm that
                                            shares of the Funds will not be sold until the proposed re-organization is complete.

Response: The Registrant so confirms.

Summary Section for Emerald Banking & Finance
Evolution Fund

 3. Comment: Based on the minimum
                                            investment thresholds of 25% in the banking industry and 15% in the financial services industry,
                                            please explain how the Fund intends to allocate the remaining 40% in the Fund’s 80%
                                            basket.

Response: The Registrant notes that the
referenced 25% in the banking industry and 15% in the financial services industry are minimum investment thresholds, accordingly, there
is not a remaining 40% in the Fund’s 80% basket.

 4. Comment: The first sentence
                                            of the second paragraph under the “Principal Investment Strategies of the Fund”
                                            section states that “the Fund may invest in companies across a wide range of industries…”
                                            Please confirm whether this will be in the Fund’s 20% basket, otherwise, the Fund is
                                            not expected to invest in a wide range of industries.

Response: Registrant confirms that the
referenced language is in reference to the Fund’s 20% basket. The Registrant will revise the referenced language in the amended
Registration Statement as follows:

“When not investing in banking and/or
financial services securities, the Fund may invest up to 20% in companies across a wide range of industries and of various sizes but
will primarily focus on mid and small-size companies, at the time of purchase.”

 5. Comment: Please revise to identify
                                            the type of illiquid securities the Fund intends to invest in in the fifth paragraph under
                                            the “Principal Investment Strategies of the Fund” section.

Response: Any illiquid securities will
be common stocks or preferred stocks that cannot be disposed of within seven days in the ordinary course of business. No other type of
security meeting the definition of “illiquid” will be used by the Fund. Accordingly, the Registrant will revise the fifth
paragraph under the “Principal Investment Strategies of the Fund” section as follows:

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“The Fund may invest up to 15% of
the value of its net assets in illiquid securities. The illiquid securities the Fund expects to invest include common stocks or preferred
stocks that cannot be disposed of within seven days in the ordinary course of business.”

 6. Comment: The related Form N-14
                                            filing indicates that the Acquiring Fund would assume the performance history of the Predecessor
                                            Fund. In addition, the Form N-14 filing states that “each Acquiring Fund has substantially
                                            similar investment strategies as the Acquired Fund.”

Please remove conflicting disclosure
and ensure consistency between the Form N-14 filing and the 485(b) filing. In addition, please revise disclosures in the 485(b) filing
to include the Predecessor Fund’s performance information or explain why the Fund may omit such information.

Response: The Registrant respectfully
advises that the Emerald Growth Fund will assume the performance history of its Predecessor Fund. However, the Emerald Banking &
Finance Evolution Fund and the Emerald Insights Fund will not assume the performance history of their respective Predecessor Funds.
Although the Emerald Banking & Finance Evolution Fund’s investment objective is generally similar to that of its
Predecessor Fund, the Registrant has determined that there are meaningful differences in the principal investment strategies and
associated risk factors such that the historical performance of the Predecessor Fund would not be representative of the performance
investors should reasonably expect from the Acquiring Fund. The Emerald Insights Fund will be materially changing its principal
investment strategy such that the historical performance of the Predecessor Fund would be misleading to potential investors.
Accordingly, the Emerald Banking & Finance Evolution Fund and the Emerald Insights Fund will not include the respective
Predecessor Fund’s performance information in the amended Registration Statement and do not believe it is appropriate to do
so.

The Registrant will
revise the disclosure in the Form N-14 filing, as applicable, to ensure consistency with the 485(b) filing regarding the treatment
of the respective Predecessor Fund’s performance history.

Summary Section for Emerald Growth Fund

 7. Comment: Please indent or otherwise
                                            distinguish “Other Fund Expenses” and “Shareholder Services Fees”
                                            to clarify that “Other Fund Expenses” are components of “Total Other Expenses.”

Response: The Registrant will make the
requested changes in the amended Registration Statement.

Financial Highlights for Emerald Banking &
Finance Evolution Fund and Emerald Growth Fund

 8. Comment: Please revise the
                                            third sentence under the “Financial Highlights” section to clarify that each
                                            Predecessor Fund is the accounting and performance survivor.

Response: As noted in the response to Comment
No. 6 above, the Emerald Banking & Finance Evolution Fund will not assume the performance history of its Predecessor Fund, due to
the meaningful differences in the principal investment strategies and associated risk factors. Accordingly, the Registrant will revise
the third sentence under the “Financial Highlights” section to reflect that each Predecessor Fund is the accounting survivor.

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Summary Section for F/m Emerald Special Situations
ETF

 9. Comment: Under the “Principal
                                            Investment Strategies” section, please clarify what any additional situations are,
                                            which may be included within the definition of the Special Situations.

Response: The Registrant will remove the
phrase “but are not limited to” and the abbreviation “etc.,” and add the following two additional bullet points
in the definition of the Special Situations in the amended Registration Statement:

 · Macroeconomic
                                            and industry catalysts;

 · Positive
                                            or negative legislative or regulatory approvals or actions.

 10. Comment: The sixth paragraph
                                            under the “Principal Investment Strategies” section indicates that the Fund may
                                            invest in convertible securities. Please expand to identify what is, or isn’t included
                                            within the reference to convertible securities. Please also note that funds count convertible
                                            securities, so long as it is disclosed in the definition of “Equity Securities,”
                                            and they exclude convertible securities that are deep out of the money and unlikely to ever
                                            convert.

Response: Registrant will remove the phrase
“securities convertible into common or preferred stocks” and replace it with “convertible preferred stock” in
the amended Registration Statement.

Additional Information about the Fund for F/m
Emerald Special Situations ETF

 11. Comment: Please provide principal
                                            investment strategies information pursuant to Item 9(b) of Form N-1A.

Response: The Registrant will make the
requested changes in the amended Registration Statement.

Statement of Additional Information for F/m
Emerald Special Situations ETF

 12. Comment: The bullet point
                                            number 1 under the “Investment Restrictions” section references “short
                                            sales.” Short sales is not described in the Fund’s principal investment strategies.
                                            Please clarify whether the Fund intends to engage in short sales. If it does, please describe
                                            in the principal investment strategies and disclose related risk.

Response: The Registrant confirms that
the Fund does not intend to engage in short sales. Therefore, no changes have been made to the disclosure in response to this comment.

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Part C

 13. Comment: Please update Power
                                            of Attorney to a more recent date.

Response: The Registrant will make the
requested changes in the amended Registration Statement.

* * * * *

We trust that the foregoing is
responsive to your comments. Questions and further comments concerning this filing may be directed to the undersigned at (215)-988-8212.

    Sincerely,

    /s/ Ya Wang

    Ya Wang

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