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VIA EDGAR

March 27, 2020

ALPS ETF Trust

1290 Broadway

Suite 1000

Denver, Colorado 80203

March 27, 2020

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Attention: Samantha Brutlag, Division of Investment
Management

 RE: ALPS ETF Trust (the “Registrant”)

File Nos. 333-148826, 811-22175

Dear Ms. Brutlag:

Set forth in the numbered paragraphs below
are the Staff’s comments provided telephonically on March 4, 2020 to Registrant’s Post-Effective Amendment No. 298
filed on January 28, 2020 (“PEA 298”) which included a prospectus and statement of additional information pertaining
to the ALPS REIT Dividend Dogs ETF (the “Fund”), accompanied by the Registrant’s responses to each comment.
Capitalized terms not otherwise defined herein shall have the meanings given to them in PEA 298.

 1. Staff Comment: Please provide the Staff with the White Paper for the Underlying Index.

Registrant’s Response:
Please see the Rulebook for the Underlying Index in Appendix A attached hereto.

 2. Staff Comment: Please state the name of the Index Provider in the Principal Investment
Strategies section.

Registrant’s Response:
Comment complied with by providing the name of the Index Provider in the Principal Investment Strategies section. See response
to Staff Comment 3 below.

 3. Staff Comment: Please elaborate with what is meant by “segment by segment basis”
in the end of the first paragraph on page 2 of the Principal Investment Strategies.

Registrant’s Response:
Comment complied with by describing what is meant by “segment by segment basis” in the Principal Investment Strategies
section. The revised disclosure states: “The Underlying Index, like the S-Net U.S. REIT from which components of the Underlying
Index are selected, divides into nine segments, eight of which are based on Global Industry Classification Standard (“GICS”)
Sub-Industries (excluding Technology REITs involved in cell towers and/or data centers) and a separate Technology REIT segment
based on the research of the Underlying Index provider, S-Network® Global Indexes, Inc. (the “Index Provider”).”

 4. Staff Comment: In the Principal Investment Strategies section, please specify the
capitalization size of the companies in which the Fund will invest.

Registrant’s Response:
Comment complied with revising the disclosure to specify that the Fund may invest in companies with a market capitalization
of greater than $50 million as of the annual reconstitution date, which is the third Friday of December each year.

 5. Staff Comment: In the Principal Investment Strategies section, please explain the
rebalance process and the number of index components (a range is acceptable). If no rebalancing process throughout the year, please
supplementally respond that there is only the annual reconstitution.

Registrant’s Response:
Comment complied with by explaining the rebalance process and the number of index components. The revised disclosure in the
summary Principal Investment Strategy section states: “The Underlying Index is rebalanced quarterly.”

The revised disclosure in the statutory
Principal Investment Strategy section states: “The Underlying Index is rebalanced quarterly on the third Friday of the last
month of each calendar quarter. Underlying Index changes take place at each rebalancing date,  except in the event of certain corporate actions, such as mergers, acquisitions, and delistings.
In such cases, the change is applied on the effective date of the action, unless otherwise determined by the Index Provider. Share
increases and decreases are reflected on the rebalancing date. Additions and deletions to the Underlying Index are made 1) at the
close of trading on the annual reconstitution date, which is the third Friday of the December of each year and 2) in the event
of the deletion of a constituent stock due to a corporate action. When a stock is deleted, a replacement will be added on the next
rebalancing date.”

Registrant respectfully notes that
the number of index components has been disclosed previously as follows: “The Underlying Index generally consists of 45 REITs…”

 6. Staff Comment: Please elaborate with what is meant by “segment inclusion”
in the Principal Investment Strategies. If the disclosure in response to Staff Comment 3 is responsive, then no need to include
additional disclosure here.

Registrant’s Response: Please see
response to Staff Comment 3 above.

 7. Staff Comment: In the Principal Investment Strategies section, please disclose the
strategy used to track the index-- replication or sampling.

Registrant’s Response:
Comment complied with by including the strategy used to track the index. The revised disclosure states: “The Fund generally
will invest in all of the securities that comprise the Underlying Index in proportion to their weightings in the Underlying Index.”

* * *

If you have any questions or further comments, please contact me
at 720.917.0883.

    Sincerely,

    /s/ Cara Owen

    Cara Owen, Assistant Secretary

 cc: Adam Teufel

Dechert LLP

Appendix A

The S-Network

REIT Dividend Dogs Index

(RDOGX)

Official Rule Book

 I. General Description

RDOGX is a portfolio of stocks derived from
the S-Network US Composite REIT Index (SNREIT). The RDOGX methodology selects the five stocks in each of the nine segments that
make up SNREIT which offer the highest dividend yields as of the last trading day of November. The forty-five stocks that are selected
for inclusion in the portfolio are equally weighted.

The S-Network US Composite REIT Index is a
benchmark index for the Real Estate Investment Trust component of the US stock market. SNREIT provides the universe of stocks for
RDOGX.

RDOGX, like SNREIT, divides into nine segments,
eight of which are based on GICS Sub-Industries (excluding Technology REITs involved in cell towers and/or data centers) and a
separate Technology REIT segment based on S-Network’s research:

 • Diversified REITs,

 • Health Care REITs,

 • Industrial REITs,

 • Retail REITs,

 • Technology REITs

 • Office REITs,

 • Hotel & Resort REITs,

 • Residential REITs,

 • SpecializedREITs

The selection criteria for SNREIT include requirements
for sector inclusion, primary exchange listing, minimum market capitalization, minimum average daily trading volume, and other
factors. All constituents of RDOGX must be constituents of SNREIT. RDOGX excludes all operating companies within the Real Estate
sector (Sector 60) as well as Mortgage REITs.

Individual securities to be included in RDOGX
are selected based on a ranking system within each sector that selects the top five stocks in the sector by indicated dividend
yield as of the last trading day of November that have funds from operations per share greater than their trailing-12-month dividends
per share. Indicated dividend yield is computed based on the last regular cash dividend paid by the company multiplied by the payment
frequency, divided by the share price. (Special dividends are not included).

All stocks selected for inclusion in RDOGX
are then equally weighted.

 II. The Index Committee

The S-Network RDOGX Index Committee (“The
Committee”) will be composed of not less than three members. The Committee Chairman will have extensive experience with and
expertise in US equity markets. The other members will have experience in financial markets, indexes and/or financial products.

The Committee will be responsible for overseeing
the activities of the calculation agent and approving all changes to the index related to its annual reconstitution and quarterly
rebalancings.

The Committee meets quarterly, either in person
or via teleconference, to discuss index issues and organize the annual reconstitution and quarterly rebalancings.

The composition of the Committee may from time
to time be changed to reflect changes in market conditions.

All members of the index committee and their
advisors shall comply with the S-Network Global Indexes code of conduct and ethics with respect to the disclosure and use of material
non-public information.

 III. Index Value at Inception

The S-Network REIT Dividend Dogs Index (Ticker:
RDOGX) had a value at inception of 1000, on its inception date of June 30, 2006. RDOGX is calculated on both a Price Only and on
a Total Return basis.

 IV. Eligibility Criteria and Weighting.

Only stocks that are current constituents of
SNREIT as of the last trading day of the second month of each calendar quarter (“the snapshot date”) and have paid
at least one dividend during the previous 12 months are eligible for inclusion in the index. The five stocks in each of the nine
segments with the highest indicated dividend yields as of the last trading day of November and with funds from operations per share
greater than their trailing-12-month dividends per share are selected for inclusion.

If a company eligible for inclusion in the
index has cut or will cut its dividend within six months of the December reconstitution, the adjusted dividend yield will be used
as a substitute for the trailing 12-month yield in the December reconstitution.

GICS Sector and Sub-Industry classifications
are updated annually as of the last trading day of November.

All stocks selected for inclusion in RDOGX
must have a 90-day average daily trading value (ADTV) of greater than or equal to the minimum 90-day ADTV out of those of all the
constituents of SNREIT whose company market capitalizations comprise the top 95% of the total.

All stocks selected for inclusion in RDOGX
are equally weighted. Share weights will be based on prices as of the close of trading on the second Friday of the rebalancing
month (“The Record Date”).

If there are fewer than 5 eligible securities
represented in any GICS sector as of the snapshot date the index will include only those securities that qualify.

All constituents are equally weighted as of
the record date.

 V. Rules for Reconstitutions, Rebalances, and Index Changes

The RDOGX is calculated by S-Network Global
Indexes. (“The Calculation Agent”). The Calculation Agent is also responsible for index maintenance and price dissemination.
The calculation, maintenance and dissemination rules are as follows:

Index Changes. The RDOGX Index is rebalanced
quarterly on the third Friday of the last month of each calendar quarter. Index changes take place at each rebalancing date (the
third Friday of the last month of each calendar quarter), except in the event of certain corporate actions, such as mergers, acquisitions,
and delistings. In such cases, the change is applied on the effective date of the action, unless otherwise determined by the Index
Committee. Share increases and decreases are reflected on the rebalancing date. Whenever possible, changes will be announced at
least two business days prior to their implementation.

Index Reconstitutions. The RDOGX Index
is reconstituted annually on the third Friday of December.

Additions and Deletions. Additions and
Deletions to the Indexes are made 1) at the close of trading on the annual reconstitution date (third Friday of the December) and
2) in the event of the deletion of a constituent stock due to a corporate action. When a stock is deleted, a replacement will be
added on the next rebalancing date.

Deletions are made at any time, in the event a stock is liquidated,
de-listed, files for

bankruptcy, is acquired, or merges with another stock. Upon deletion,
the weight of the removed stock is reallocated proportionately to the remaining constituents. Additions are made only upon the
effective date of the quarterly rebalancing.

If a stock is deleted from SNREIT, the stock will be deleted from
RDOGX on the date of the next rebalancing.

If a stock is deleted from SNREIT after the snapshot date for additions
and deletions pursuant to quarterly rebalancings but before the rebalancing date, the stock will be deleted from the index and
a replacement stock will be chosen.

 VI. Roles of Parties in the Quarterly Rebalance.

 i) The Calculation Agent will screen the constituents of the RDOGX to validate each constituent is
a member of SNREIT Index.

 ii) If in any sector a current constituent has not paid a regular dividend during the previous 12 months,
the constituent will be deleted from RDOGX and the Calculation Agent will screen the constituents of SNREIT to identify the next
highest yielding non-component security in said sector based on closing prices and values as of the close of trading on the last
trading day of the second month of each calendar quarter (“the snapshot date”).

 iii) If a constituent is deleted from the index due to a corporate action, the Calculation Agent will
screen the constituents of SNREIT to identify the next highest yielding non-component security in said sector based on closing
prices and values as of the close of trading on the snapshot date.

 iv) On the first Friday of the rebalancing month, the Calculation Agent shall provide the Committee,
or its designee, with a list of constituents for the RDOGX Index.

 v) The Committee shall approve or reject the changes and notify the calculation agent of its decisions
not later than the Tuesday following the first Friday of the rebalancing month.

 vi) Not later than the Tuesday following the first Friday of the rebalancing month, the Index Committee
or its designee will issue a press release announcing additions and deletions to RDOGX. The press release will be posted on the
RDOGX web site.

 vii) The Calculation Agent will provide final share weights to the Committee or its designee on the
Monday following the second Friday of the rebalancing month. Share weights will be based on prices as of the close of trading on
the second Friday of the rebalancing month (“the record date”).

 viii) The RDOGX Index Committee or its designee will approve the final share weights prior to the close
of US markets on the next business day and will distribute this information to the Calculation Agent and all RDOGX licensees.

 ix) The effective date of the rebalancing will be on the close of business on the third Friday of the
last month of each calendar quarter. The Calculation Agent will post all final rebalancing data and information on its FTP server
prior to the open on the next business day following the rebalancing date.

 x) RDOGX will post all rebalancing data on its website prior to the open on the next business day
following the rebalancing date.

 VII. Roles of Parties in the Annual Reconstitution.

 i) The Calculation Agent will screen the constituents of SNREIT to identify the five stocks in each
sector with the highest dividend yield based on closing prices and values as of the close of trading the snapshot date.

 ii) On the first Friday of December, the Calculation Agent shall provide the Committee, or its designee,
with a list of constituents for the RDOGX.

 iii) The Committee shall approve or reject the changes and notify the calculation agent of its decisions
not later than the Tuesday following the first Friday of December.

 iv) Not later than the Wednesday following the first Friday of December, the Index Committee or its
designee will issue a press release announcing additions and deletions to RDOGX. The press release will be posted on the RDOGX
web site.

 v) The Calculation Agent will provide final share weights to the Committee or its designee on the
Monday following the second Friday of December. Share weights will be based on prices as of the close of trading on the second
Friday of December (“the record date”).

 vi) The RDOGX Index Committee or its designee will approve the final share weights prior to the close
of US markets on the next business day and will distribute this information to the Calculation Agent and all RDOGX licensees.

 vii) The effective date of the reconstitution will be on the close of business on the third Friday of
December. The Calculation Agent will post all final rebalancing data and information on it