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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

 March 14, 2024

VIA EDGAR CORRESPONDENCE

Brian Szilagyi

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    SOX Review of First Trust Exchange-Traded AlphaDEX Fund

    (File No. 811-22019)

Dear Mr. Szilagyi:

This letter responds
to comments provided by the staff of the Securities and Exchange Commission (the “Staff”) via telephone, pursuant to
Section 408 of the Sarbanes-Oxley Act of 2002, regarding the funds included within the First Trust Exchange-Traded AlphaDEX Fund (the
“Trust”) listed in Exhibit A attached hereto (each, a “Fund” and collectively, the “Funds”).
Capitalized terms used herein, but not otherwise defined, have the meanings ascribed to them in the Funds’ Annual Report for the
fiscal years ended July 31, 2023 (each, an “Annual Report” and collectively, the “Annual Reports”)
as filed on Form N-CSR with the Staff on October 6, 2023.

Comment
1

The Staff noted that
reviewing the “Notes to the Financial Statements,” both the management fee schedule for each Fund as well as certain terms
to the expense reimbursement, fee waiver and recovery agreement were updated effective November 1, 2022. During the Staff’s review
of the Post-Effective Amendment No. 44 on Form N-1A (file no. 333-140895) for the Registrant on November 28, 2022, the Staff did not see
updates to the advisory fee agreement and expense limitation agreement that were filed as exhibits. Please file amended agreements with
the Registrant’s next Post-Effective Amendment on Form N-1A.

Response
to Comment 1

The Registrant confirms
the Second Amended and Restated Expense Reimbursement and Fee Waiver Agreement, dated November 1, 2022, will be filed with the Registrant’s
next Post-Effective Amendment on Form N-1A.

Comment
2

Please explain whether
any of the creation and redemption fees charged by the Funds are retained by the Funds. If so, please disclose the accounting policy for
the fees and also explain and disclose whether any fees are paid to related parties.

Response
to Comment 2

The Registrant confirms
that the creation and redemption fees charged by the Funds are not retained by the Funds. The flat fee charged per order is retained by
the service provider for processing the order. As such, no fees are paid to related parties.

Comment
3

For First Trust Large
Cap Core AlphaDEX® Fund, the Fund reported in Item C.3(b)(ii)(1) and (2) of Form N-CEN that the annualized difference
between the Fund’s total return and the index’s return during the reporting period before and after taking account fees and
expenses was 0.01% and (0.64)%, respectively. Please confirm if the disclosure for Item C.3(b)(ii)(1) is accurate with an explanation
of the basis for the diversion, and if not, please explain how the issue will be corrected. The Staff notes this comment is applicable
to other Funds as well.

Response
to Comment 3

The Registrant confirms
it has reviewed the calculation for Item C.3(b)(ii)(1). The Registrant confirms the disclosure is accurate. For First Trust Large Cap
Core AlphaDEX® Fund the diversion between 0.01% and (0.64)% is a result of the Fund’s 7/31/23 fiscal year expense
ratio of 0.60% and the compounding effect of the expense ratio. The same is true for other Funds based on each Fund’s expense ratio
and the compounding effect of the expense ratio. Fund expenses are accrued daily, and over the course of a year, each day’s expenses
reduce a Fund’s net asset value. When calculating the response for Item C.3(b)(ii)(1) for First Trust Large Cap Core AlphaDEX®
Fund, the compounding effect of reducing the Fund’s net asset value each day equated to 0.05% when compared to the index’s
return which does not charge an expense ratio.

********

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

Exhibit A

First
Trust Exchange-Traded AlphaDEX Fund

    File Number
    Fund Name
    FYE Reviewed

    811-22019
    First Trust Consumer Discretionary AlphaDEX® Fund (FXD)
    7/31/2023

    811-22019
    First Trust Consumer Staples AlphaDEX® Fund (FXG)
    7/31/2023

    811-22019
    First Trust Energy AlphaDEX® Fund (FXN)
    7/31/2023

    811-22019
    First Trust Financials AlphaDEX® Fund (FXO)
    7/31/2023

    811-22019
    First Trust Health Care AlphaDEX® Fund (FXH)
    7/31/2023

    811-22019
    First Trust Industrials/Producer Durables AlphaDEX® Fund (FXR)
    7/31/2023

    811-22019
    First Trust Materials AlphaDEX® Fund (FXZ)
    7/31/2023

    811-22019
    First Trust Technology AlphaDEX® Fund (FXL)
    7/31/2023

    811-22019
    First Trust Utilities AlphaDEX® Fund (FXU)
    7/31/2023

    811-22019
    First Trust Large Cap Core AlphaDEX® Fund (FEX)
    7/31/2023

    811-22019
    First Trust Mid Cap Core AlphaDEX® Fund (FNX)
    7/31/2023

    811-22019
    First Trust Small Cap Core AlphaDEX® Fund (FYX)
    7/31/2023

    811-22019
    First Trust Large Cap Value AlphaDEX® Fund (FTA)
    7/31/2023

    811-22019
    First Trust Large Cap Growth AlphaDEX® Fund (FTC)
    7/31/2023

    811-22019
    First Trust Multi Cap Value AlphaDEX® Fund (FAB)
    7/31/2023

    811-22019
    First Trust Multi Cap Growth AlphaDEX® Fund (FAD)
    7/31/2023

    811-22019
    First Trust Mid Cap Value AlphaDEX® Fund (FNK)
    7/31/2023

    811-22019
    First Trust Mid Cap Growth AlphaDEX® Fund (FNY)
    7/31/2023

    811-22019
    First Trust Small Cap Value AlphaDEX® Fund (FYT)
    7/31/2023

    811-22019
    First Trust Small Cap Growth AlphaDEX® Fund (FYC)
    7/31/2023