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JOHN H. LIVELY, Managing Partner

john.lively@practus.com

11300 Tomahawk Creek Pkwy., Suite 310

Leawood, KS 66211

(913) 660-0778

March 8, 2024

Mr. David Matthews

 Attorney-Adviser

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re:

World Funds Trust (File Nos. 333-148723 and 811-22172)

T-Rex 1.5X Long Spot Bitcoin Daily Target ETF

T-Rex 1.5X Inverse Spot Bitcoin Daily Target
ETF

T-Rex 1.75X Long Spot Bitcoin Daily
Target ETF

T-Rex 1.75X Inverse Spot Bitcoin Daily Target
ETF

T-Rex 2X Long Spot Bitcoin Daily Target ETF

T-Rex 2X Inverse Spot Bitcoin Daily Target
ETF

Dear Mr. Matthews:

This letter provides the responses
of World Funds Trust (the “Trust”) to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange
Commission (the “Commission”) that you provided to Practus, LLP. The comments related to three Post-Effective Amendments (each,
a “PEA” and collectively, the “PEAs”) to the registration statement of the Trust, which were each filed on January
3, 2024, under Rule 485(a) of the Securities Act of 1933, as amended. Each PEA was filed to register shares of two new series of the Trust:
(i) PEA No. 431 was filed to register the T-Rex 1.5X Long Spot Bitcoin Daily Target ETF and T-Rex 1.5X Inverse Spot Bitcoin Daily Target
ETF; (ii) PEA No. 432 was filed to register the T-Rex 1.75X Long Spot Bitcoin Daily Target ETF and T-Rex 1.75X Inverse Spot Bitcoin Daily
Target ETF; and (iii) PEA No. 433 was filed to register the T-Rex 2X Long Spot Bitcoin Daily Target ETF and T-Rex 2X Inverse Spot Bitcoin
Daily Target ETF (each a “Fund”, and together the “Funds”). For your convenience, I have summarized the comments
in this letter and provided the Trust’s response below each comment. Capitalized terms not defined in this letter shall have the
same meaning ascribed to such term in the PEAs.

General Comments

 · The
Staff requests that the Trust be prepared to delay the effectiveness of the PEAs until all comments are resolved.

 · Please
file this comment response letter on EDGAR such that the Staff has at least ten days to review.

 · Please
also send via email to David Matthews, redlined or marked pages of revised disclosure.

    Mr. David Matthews

 Attorney-Adviser

Division of Investment Management

U.S. Securities and Exchange Commission

March 8, 2024

 · The
Staff notes that portions of the PEAs are incomplete. The Staff asks that any blanks or bracketed information be completed in the next
set of post-effective amendments.

 · Please
also apply any new or revised disclosure in one section to similar disclosure in other sections throughout the registration statements
for each Fund as well as throughout.

 · Please
inform the staff supplementally if the launch of one Fund is conditioned or contingent on the launch of the other Fund.

 · In
the Trust’s correspondence filing, please advise the Staff when it is anticipated that the Funds will commence operations.

Response: The Trust acknowledges
the points made above in the “General Comments.” With respect to the desired commencement of operations, the Trust is seeking
to commence operations as soon as practicable after its registration statement becomes effective, which is, absent the need to delay the
effectiveness of the PEAs, currently scheduled to go effective automatically on March 18, 2024. In light of this targeted commencement
of operations date, the Trust respectfully requests that the Staff attempt to accommodate its business objective.

 Prospectus

 1. Comment:	In light of each Fund's investment objective
and strategies, please explain supplementally why the name of each Fund is not misleading or deceptive. In particular, please explain
why the use of the term “spot” in each Fund's name is not materially misleading or deceptive. The staff believes the name
of each Fund suggests that the Fund provides direct exposure to Bitcoin. The staff also notes that each reference ETF does not include
the term “spot” in its name.

Response:	The Trust has revised
the name of each Fund to remove the term, “Spot.”

 2. Comment:	To avoid investor confusion, revise the initial
bulleted list in each prospectus to refer to Funds or each Fund as applicable. Also refer to long leveraged funds and inverse leveraged
funds in the same order throughout the document.

Response:	The Trust has revised
the disclosure to address your comment.

Fund Summary

 3. Comment:	In the section of the Fund Summary entitled “Important
Information about the Fund”, please clarify that the fees and expenses of the reference asset will cause the Fund’s performance
to be lower than the actual market performance of Bitcoin.

Response:	The Trust has revised
the disclosure to address your comment.

2

    Mr. David Matthews

 Attorney-Adviser

Division of Investment Management

U.S. Securities and Exchange Commission

March 8, 2024

 4. Comment:	Throughout the Funds’ prospectuses
                                                          and statements of additional information, there are various references to terms such as the “Reference ETF,” the “Underlying ETF” and the “Underlying
Securities.” If these defined terms are different, please explain in the disclosure. Otherwise please conform the disclosures to
use the same term when referring to the reference asset.

Response:	The Trust has revised
the disclosure to address your comment.

 5. Comment:	Please clarify in the disclosure whether the
Funds only intend to use reference assets that are traded on a US regulated exchange.

Response:	The Trust has revised
the disclosure to address your comment.

 6. Comment:	Please state prominently in bold face on the
cover page or in the section of the Fund Summary entitled “Important Information about the Fund” that each long leveraged
Fund will not invest directly in Bitcoin, and for each inverse Fund that the Fund will not invest directly in Bitcoin or directly short
Bitcoin.

Response:	The Trust has revised
the disclosure to address your comment.

 7. Comment:	Throughout the prospectuses and the statements
of additional information, please refer to the reference assets as “exchange traded products” or “ETPs,” rather
than as exchange traded funds or ETFs. Please add disclosure that any reference to an exchange traded product is not a registered
investment company, rather than stating that they may not be a registered investment company.

Response:	The Trust has revised
the disclosure to address your comment.

 8. Comment:	 Please provide the fee table and expense example
in the next post-effective amendment. Please confirm whether there will be any fee waivers, recapture capabilities or an expense limitation
agreement.

Response:	The Trust has revised
the disclosure to address your comment. The Trust confirms that there will not be any fee waivers or expense limitation arrangement, and
there will be no recapture capabilities, except that if the Adviser charges an investment advisory fee to the CFC that will be created
(as discussed in the response to comment 13 below), the Adviser will waive the investment advisory fee charged to the Funds to the extent
necessary to avoid the duplication of fees.

3

    Mr. David Matthews

 Attorney-Adviser

Division of Investment Management

U.S. Securities and Exchange Commission

March 8, 2024

Principal Investment
Strategies

 9. Comment: Please add a description of Bitcoin, the Bitcoin blockchain, the relationship of Bitcoin
to the Bitcoin blockchain and applications that Bitcoin and the Bitcoin blockchain are designed to support.

Response:	The Trust has revised
the disclosure to address your comment.

 10. Comment:	Please explain in correspondence how the Funds
intend to comply with Rule 18f-4 (“Rule 18f-4”) under the Investment Company Act of 1940, as amended (“1940 Act”),
including an overview of the key elements of the Funds’ derivatives risk management program. Provide supplementally hypothetical
VaR calculations demonstrating how the Fund anticipates being able to achieve its objective while remaining in compliance Rule 18f-4.
In responding to this comment, if the Fund will use relative VAR, and if so, identify the index to be used as the designated reference
portfolio (DRP) that the Fund plans to use, and (ii) how the DRP meets the definition of a designated reference portfolio and is in accordance
with the requirements under Rule 18f-4.

Response: 	Under separate cover,
the Registrant is providing the Staff with hypothetical VaR calculations based on each Fund’s anticipated portfolio construction.
The Fund will use the Coin Metrics’ CMBI Bitcoin Index (“Index”) as a designated reference portfolio (“DRP”)
for purposes of the relative VaR calculations. The Index is designed to measure the performance an investor would expect from purchasing
and holding Bitcoin (BTC). The Index aggregates data from BTC/USD markets to produce transparent and robust Bitcoin values. The closing
levels of the Index are produced at market close making it a widely used benchmark across financial products and financial media outlets
like CNBC.

The SEC Staff has indicated that overlapping
composition is a significant factor in determining whether a DRP reflects the markets and asset classes in which the Funds invest. In
this case, the Reference ETP (underlying benchmark) for the Funds and DRP both track spot Bitcoin.

Further, the Index: (1) is not actively
managed, (2) is not leveraged, and (3) was not constructed specifically for DRP purposes. In addition, the Index has historical market
data available for more than 3 years.

 11. Comment:	 Please explain in correspondence how the Funds
will value the swap positions.

Response:	The
Funds will value the swap positions using prices provided by a broker-deal.

 12. Comment:	Please clarify in the disclosure that the swap
agreements in which the Funds invest will be uncleared, non-exchange traded, and cash settled.

Response:	The Trust has revised
the disclosure to address your comment.

4

    Mr. David Matthews

 Attorney-Adviser

Division of Investment Management

U.S. Securities and Exchange Commission

March 8, 2024

 13. Comment:	The Staff notes that the disclosure
                                                           regarding tax risks of the Funds indicates that the Funds intend to qualify as a “regulated investment company” for purposes of Subchapter M of the Internal
Revenue Code (“Subchapter M”). In correspondence, please explain how, given the current structure of the Funds, the income
generated from swaps on a referenced exchange-traded product would qualify as “good income” for purposes of Subchapter M.
In this regard, the Staff notes that a swap based on a reference ETP would be considered a commodity-linked derivative.

Response:	The Trust agrees that
that income from the swaps that the Funds will use will not qualify as good income for the purposes of Subchapter M. The Trust has determined
that each Fund will utilize a controlled foreign corporation (“CFC”) in seeking to implement its investment strategies. The
Funds’ disclosures have been revised to reflect the utilization of the CFC structure. The Trust is of the view that this structure
will allow it to comply with Subchapter M.

 14. Comment:	If the Funds intend to use a CFC structure to
gain exposure to the reference ETP, please confirm in correspondence that: (a) the financial statements of each CFC will be consolidated
with those of each corresponding Fund (and if not, please explain why); (b) the CFCs and their board will agree to inspection by the Staff
of its books and records, that such books and records will be kept in accordance with Section 31 of the 1940 Act and the rules thereunder,
and (c) the CFC will designate an agent for service of process in the United States. Please also confirm that the management fees of CFC,
if any, will be included in the management fee in the prospectus fee table and the CFC’s expenses will be included in “other
expenses” in the prospectus fee table.

Response:	The Trust hereby confirms
with respect to each of the Funds that: (a) the financial statements of each CFC will be consolidated
with those of each corresponding Fund; (b) the CFCs and their board agree to inspection by the Staff of its books and records, such books
and records will be kept in accordance with Section 31 of the 1940 Act and the rules thereunder., and (c) the CFC will designate an agent
for service of process in the United States. The Trust also confirms that the management fees of the CFC, if any, will be included in
the management fee in the fee table and the CFC’s expenses will be included in “other expenses” in the fee table.

 15. Comment:	If a CFC will be utilized, disclose the risk
related to the size of a Fund’s investments in the subsidiary exceeding 25% of the Fund’s assets and any potential adverse
tax consequences.

Response:	The Trust has revised
the disclosure to address your comment.

5

    Mr. David Matthews

 Attorney-Adviser

Division of Investment Management

U.S. Securities and Exchange Commission

March 8, 2024

 16. Comment:	 If the Funds can enter into reverse repurchase
agreements or similar transactions, disclose the purposes of such transactions and whether such transactions are being invested in for
investment purposes. As appropriate, please disclose in the risks the applicable risk of such transactions.

Response:	The Trust does not intend
to invest in any of the types of transactions described in the Staff’s comments. Accordingly, no revisions to the disclosure have
been made. The Funds reserve the right to borrow money to the extent permitted by the Investment Company Act of 1940, as amended, but
do not expect to do so.

 17. Comment:	Please describe in correspondence:

 (a) approximately how many counterparties the Funds
expect to use and what percentage of each Fund’s assets and investment exposure are expected to be related to each of these counterparties.

 (b) whether there have been discussions with potential
swap counterparties and what sort of margin requirements are being considered. Include an analysis of any impact margin requirements are
expected to have on the ability of each Fund to implement its strategies.

 (c) Any discussions with swap counterparties related
to their willingness to scale the Funds’ exposure over time, including any anticipated exposure limit to the counterparty, reference
asset or Bitcoin. Please explain how any such limits may impact the Funds operationally.

Response:	The
Adviser intends to negotiate with at least six swap counterparties and initially expects to trade with at least three swap counterparties
for each Fund, each subject to the terms and conditions of an ISDA Master Agreement published by the International Swaps and Derivatives
Association and applicable Schedule and Credit Support Annex (“ISDA Agreement”).

The Adviser has been negotiating with potential
swap counterparties and has discussed, among other things, the margin requirements that will be required. As is standard under the Credit
Support Annex of ISDA Agreements, margin will be posted on a daily basis by the out of the money party, subject to certain rounding and
threshold amounts. The Adviser expects that each Fund could be required to post approximately [40]% of its total assets as margin, but
that amount could go higher depending on market conditions. In any event, the Adviser does not expect margin requirements to have a material
effect on each Fund’s ability to implement its strategy because a very high percentage of the Funds’ assets will be in highly
liquid investments.

The Adviser is in discussions with multiple
swap counterparties and does not believe that there will be any issues with scaling the Funds’ exposure over time and does not
anticipate any exposure limits to a particular counterparty will impact the Funds operationally. The Adviser has not enc