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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

October 4, 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 2X Long Ether Daily Target ETF

  T-Rex 2X Inverse Ether 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 the Post-Effective Amendments (a
“PEA”) to the registration statement of the Trust, which was filed on May 31, 2024, under Rule 485(a) of the Securities Act
of 1933, as amended. The PEA was filed to register shares of two new series of the Trust, the T-Rex 2X Long Ether Daily Target ETF and
T-Rex 2X Inverse Ether 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

    ·
    Due
    to the nature of the Fund investing primarily in swaps to gain exposure to spot Ether, please be prepared to delay scheduled effectiveness
    until all of these issues are resolved.

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

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

    ·
    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 expected to be on or about
October 18, 2024. In light of this targeted commencement of operations date, the Trust respectfully requests that the Staff attempt to
accommodate its business objective.

    Mr. David Matthews

Attorney-Adviser

Division of Investment Management

U.S. Securities and Exchange Commission

October 4, 2024

Prospectus

1. Comment:	The Staff notes throughout that the term Ether is
                                capitalized in some instances and lowercase in others. Please conform to industry usage.

  Response:	The Trust has revised the disclosure to address the Staff’s
               comment.

2. Comment:	The Staff notes that the name of one of the named
                                Reference ETPS, the ARK 21Shares Ethereum ETF, has changed its name. Please revised the disclosure to
                                reflect the new name.

  Response:	The Trust has revised the disclosure to address the Staff’s
               comment.

3. Comment:	In the last sentence before the Fund’s investment
                                objective, the prospectus states: “The Fund only intends to use reference assets that are traded
                                on a U.S. regulated exchange.” The Staff notes that the Funds may also use indexes as a reference
                                asset. Please revise this sentence to reflect that only Reference ETPs, and not indexes, trade on an
                                exchange.

  Response:	The Trust has revised the disclosure to address the Staff’s comment.

4. Comment:	Please provide the completed Fee Table and example
                                pre-effectively and confirm there will be no fee waiver or reimbursement arrangement or disclose any
                                such arrangement in a footnote to the Fee Table.

  Response:	The Trust has provided the information that addresses
                              the Staff’s comment. The Trust confirms that there will not be an expense limitation arrangement,
                              although the Adviser will be contractually obligated to pay each Fund’s expenses, subject to certain
                              exclusions as noted in the prospectus, and there will be no recapture capabilities. The Adviser will charge
                              an investment advisory fee to each Fund’s Cayman subsidiary (as discussed in the response to comment
                              11 below), but will waive the investment advisory fee charged to the Funds to the extent necessary to avoid
                              the duplication of fees. These arrangements are disclosed in a footnote to the Fee Table.

 2

    Mr. David Matthews

Attorney-Adviser

Division of Investment Management

U.S. Securities and Exchange Commission

October 4, 2024

5. Comment:	In supplemental correspondence, please describe how
                                the Funds anticipate complying with Rule 18f-4, including a preliminary overview of the key elements
                                of the derivatives risk management program and provide daily hypothetical rolling VaR calculations for
                                each Fund for the first two calendar quarters of 2024 demonstrating how each Fund expects to be able
                                to achieve its objective while remaining in compliance with Rule 18f-4. In responding to this comment,
                                please confirm whether the Funds will use relative VaR identify the index expected to be used as the
                                designated reference portfolio and discuss how such index meets the definition of a designated reference
                                portfolio under Rule 18f-4.

  Response:	In accordance with Rule 18f-4, the Funds will implement
                              a derivatives risk management program, including policies and procedures reasonably designed to manage
                              the Funds’ derivatives risks including risk guidelines, stress testing, and backtesting.

  Under separate cover, the Registrant is
providing the Staff with hypothetical VaR calculations based on each Fund’s anticipated portfolio construction. The hypothetical
VaR calculations use the CME CF Ether-Dollar Reference Rate - New York Variant as a proxy for the Fund’s performance. The Fund will
use the S&P Cryptocurrency BDM Ex-LargeCap Index (“SPCBXL” or “Index”) as a designated reference portfolio
(“DRP”) for purposes of the relative VaR calculations. The Index is designed to track the constituents of the S&P Cryptocurrency
BDM Index, excluding constituents of the S&P Cryptocurrency LargeCap Index. The Index is predominantly composed of tokens and coins
operating on the Ethereum network. The Adviser’s research indicates that seven out of the top ten constituents are ERC-20 tokens,
including all five in the top five. ERC-20, or Ethereum Request for Comment 20, is a technical standard for creating and implementing
assets on the Ethereum blockchain.

  While the exact weighting percentages for
each constituent are not publicly disclosed, the Adviser’s analysis shows that the top ten tokens account for 20.4% of the total
258 constituents in the Index. The Adviser estimates that ether tokens represent approximately 40-50% of the overall Index.

  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.

6. Comment:	In supplemental correspondence, please describe how
                                the Funds will value their swaps positions.

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

 3

    Mr. David Matthews

Attorney-Adviser

Division of Investment Management

U.S. Securities and Exchange Commission

October 4, 2024

7. Comment:	With regard to the swap counterparties, in correspondence
                                describe how many swap counterparties the Funds are expected to use and what percentage of fund assets
                                and investment exposure are expected to be related to each counterparty. Describe any discussions with
                                potential counterparties regarding: (a) swap collateral or margin requirements or (b) limits on exposure
                                to a counterparty, a reference asset or to ether, and the impact such requirements or limits may have
                                on the Funds’ ability to execute their strategy or on their operations. In Item 9, include disclosure
                                of the following regarding counterparties (if applicable): (a) if exposure to any counterparty is expected
                                to be material, identify the counterparty and file the applicable swap agreements as an exhibit; (b)
                                if notional exposure to any counterparty is expected to exceed 20% of a Fund’s assets, disclose
                                in the prospectus whether such counterparty is subject to Exchange Act filing and reporting requirements;
                                (c) identify any national exchanges on which the such counterparty’s securities are listed and
                                describe where those filings and reports can be obtained; (d) if a counterparty is a subsidiary of a
                                public company, disclose whether the Fund will have recourse to the parent company for the obligations
                                of the counterparty; and (e) disclose how counterparties will hedge their exposure.

  Response:	The Adviser initially expects to trade with at least three swap counterparties
               for each Fund, and is in negotiations with at least two other swap counterparties. The Funds will enter into an ISDA Master
               Agreement published by the International Swaps and Derivatives Association and applicable Schedule and Credit Support
               Annex (“ISDA Agreement”) with each swap counterparty.

  In its negotiations with potential swap
counterparties, the Adviser 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 encountered any counterparties
that have indicated that there would be any limitations on their willingness to enter into swap transactions with the Funds or with respect
to any reference asset or ether. In the event that the Funds encountered such a limitation with its then current counterparties, it would
add additional swap counterparties.

8. Comment:	The last sentence in the penultimate paragraph under
                                “Principal Investment Strategies” references the impact of a “fork” on ether
                                futures contracts in which the Fund invests. The Staff’s understanding is that the Funds’
                                do not trade in futures contracts. Please revise or remove this reference.

  Response:	The Trust has revised the disclosure to address the
                              Staff’s comment.

 4

    Mr. David Matthews

Attorney-Adviser

Division of Investment Management

U.S. Securities and Exchange Commission

October 4, 2024

9. Comment:	The last paragraph under “Principal Investment
                                Strategies” references an “Index” that is constructed and maintained by Bloomberg Index
                                Services Limited and published under the Bloomberg ticker symbol “ETHEREUM”.  This Index
                                is not disclosed as a Reference Asset in the prospectus. Please correct or delete this reference.

  Response:	The Trust has revised the disclosure to address the
                              Staff’s comment.

10. Comment:	If the Funds may enter into reverse repurchase agreements
                                 or similar transactions, please disclose the purpose of such transactions and add relevant risk disclosure
                                 related to the use of such instruments.

  Response:	The Funds do 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.

11. Comment:	Regarding each Fund’s Cayman subsidiary, please
                                 confirm in correspondence that each subsidiary will be engaged in securities investment activities and
                                 be wholly owned by the respective Fund, that each subsidiary’s financial statements will be consolidated
                                 with the respective Fund or, if not, explain why it is not. Please also confirm that each subsidiary
                                 and its board will agree to inspection by the Staff of its books and records, which will be maintained
                                 in accordance with Section 31 of the 1940 Act and the subsidiaries will designate an agent for service
                                 and process in the United States, and confirm each that each subsidiary’s management fee, if any,
                                 will be included in the Fund’s fee table as “other expenses.”

  Response:	The Trust hereby confirms that each subsidiary will be engaged in
               securities investment activities and will be wholly owned by the respective Fund. In addition, the financial statements
               of each subsidiary will be consolidated with those of the respective Fund. The Trust also confirms that each subsidiary
               and its board of directors will agree to inspection by the Staff of its books and records, which will be maintained in
               accordance with Section 31 of the 1940 Act and the rules thereunder, and will designate an agent for service of process
               in the United States. The Adviser will charge an investment advisory fee to each Fund’s Cayman subsidiary (as discussed
               in the response to comment 4 above), but will waive the investment advisory fee charged to the Funds to the extent necessary
               to avoid the dupl