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CORRESP
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        Chapman and Cutler LLP

320 South Canal Street, 27th Floor

Chicago, Illinois 60606

T 312.845.3000

F 312.701.2361

www.chapman.com

 October 20, 2025

VIA EDGAR CORRESPONDENCE

Mark Cowan

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    First Trust Exchange-Traded Fund II (the “Trust”)

File Nos. 333-143964; 811-21944

Dear Mr.  Cowan:

This letter responds
to your comments regarding the registration statement filed on Form N-1A for First Trust Exchange-Traded Fund II (the “Trust”)
with the Staff of the Securities and Exchange Commission (the “Staff”) on July 29, 2025 (the “Registration
Statement”). The Registration Statement relates to the First Trust Indxx Critical Metals ETF (the “Fund”),
a series of the Trust. Capitalized terms used herein, but not otherwise defined, have the meanings ascribed to them in the Registration
Statement.

Comment 1 – General

The Staff reminds
the Registrant and its management that they are responsible for the accuracy and adequacy of the disclosures, notwithstanding any review,
comments, action or absence of action by the Staff. Where a comment is made in one location, it is applicable to all similar disclosures
appearing elsewhere in the Registration Statement. Please ensure that corresponding changes are made to all similar disclosure.

Please provide responses
to all of the Staff’s comments on EDGAR at least five business days before the effective date of the Registration Statement.

Response to Comment 1

The Registrant confirms
that corresponding changes made in response to the Staff’s comments have been made to any similar disclosure throughout the Registration
Statement and that it will provide the Staff with a response letter in the form of correspondence at least five business days before
effectiveness.

Comment 2 – Principal Investment Strategies

The Staff notes the
following disclosure set forth in the second to last paragraph of the section entitled “Principal Investment Strategies”:

The Fund will be concentrated in an
industry or a group of industries to the extent that the Index is so concentrated. As of __________, 2025, the Fund had significant investments
in materials companies, although this may change from time to time.

Please state what
industry or group of industries the Index is currently concentrated in. Please also confirm whether the Fund or the Index “had significant
investments in materials companies…”

Response to Comment 2

In response to the
Staff’s comments, the referenced statement has been revised as follows:

The Fund will be concentrated in an
industry or a group of industries to the extent that the Index is so concentrated. As of __________, 2025, the Fund Index
had significant investments in materials companies, although this may change from time to time. (emphasis added)

Comment 3 – Principal Risks

The Staff notes “Index
Concentration Risk” set forth in the section entitled “Principal Risks.” Please add additional industry risk disclosures
with respect to the Index, if any.

Response to Comment 3

The Fund respectfully
points the Staff to the risk factor entitled “Materials Companies Risk” set forth in the section entitled “Principal
Risks” and confirms that it will add additional industry risk disclosure, if necessary.

********

Please call me at
(312) 845-3484 if you have any questions or issues you would like to discuss regarding these matters.

    Sincerely yours,

    Chapman and Cutler
    llp

    By:
    /s/ Morrison C. Warren

    Morrison C. Warren