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[Chapman
and Cutler LLP Letterhead]

July 31, 2024

VIA EDGAR CORRESPONDENCE

Kimberly Browning

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Innovator ETFs Trust

    File Nos. 333-146827; 811-22135

Dear Ms. Browning

This letter responds to your
comments, provided by telephone, regarding the registration statements filed on Form N-1A for Innovator ETFs Trust (the “Trust”)
with the Securities and Exchange Commission (the “Commission”) on May 22, 2024 (each, a “Registration Statement”
and collectively, the “Registration Statements”). The Registration Statements relates to Innovator Equity Defined
Protection ETF – 2 Yr to October 2027; Innovator Equity Defined Protection ETF – 2 Yr to April 2027; Innovator Equity Defined
Protection ETF – 2 Yr to January 2027; Innovator Equity Defined Protection ETF – 2 Yr to October 2026; Innovator Equity Defined
Protection ETF – 1 Yr September (formerly Innovator Equity Defined Protection ETF – 1 Yr April); Innovator Equity Defined
Protection ETF – 1 Yr August (formerly Innovator Equity Defined Protection ETF – 1 Yr January); Innovator Equity Defined
Protection ETF – 1 Yr October; and Innovator Equity Defined Protection ETF – 6 Mo Apr/Oct (each, a “Fund” and
collectively, the “Funds”), each a series of the Trust. Capitalized terms used herein, but not otherwise defined, have
the meanings ascribed to them in the applicable Registration Statement.

Comment 1 – Portfolio Manager Information

The staff of the Commission
(the “Staff”) notes comment 10 in the prior comment letter filed on or about July 18, 2024, (the “Prior Comment
Letter”) also asked the Funds to revise the disclosure with respect to Yin Bhuyan’s work experience to comply with the
requirements of Item 10(a)(2) of Form N-1A. The disclosure should specify each portfolio manager’s work experience over the past
5 years and for what firm. Please revise the biographical information in accordance with the requirements of Form N-1A.

Response to Comment 1

In light with recent personnel
changes at the sub-adviser of the Funds, Milliman Financial Risk Management LLC, Yin Bhuyan will no longer serve as a portfolio manager
of the Funds, and Jordan Rosenfeld will replace her. The Funds acknowledge the requirements of Item 10(a)(2) of Form N-1A, and the biographical
information for Jordan Rosenfeld will appear as below in the next post-effective amendment to each Fund’s Registration Statement:

Jordan B. Rosenfeld – Senior
Director and Portfolio Manager at Milliman.  Mr. Rosenfeld joined Milliman in 2018 as a trader and in 2021 was promoted
to ETF Portfolio Manager. Mr. Rosenfeld is responsible for implementing derivatives strategies in exchange-traded funds, mutual funds,
and unit investment trusts.  He has more than nine years of experience in capital markets with a focus on derivatives portfolio management
and multi-asset strategy.  Prior to joining the firm, Mr. Rosenfeld was a global macro portfolio manager at Gelber Group.

Comment 2 – Principal Risks

The Staff notes comment 12
in the Prior Comment Letter was to add concentration disclosure in the Item 4 disclosure and attendant risks. The Staff notes the Funds
added concentration disclosure to the information technology risk factor, instead of creating a separate concentration risk. Please explain
to the staff why this is appropriate or revise to create a separate concentration risk.

Response to Comment 2

The Funds have revised the
Principal Risks section to include a “Concentration Risk” as shown below:

Concentration Risk. Through its
usage of FLEX Options, the Fund will concentrate in the securities of a particular industry or group of industries to the same extent
as the U.S. Equity Index. To the extent the Fund has significant exposure in a single asset class or the securities of issuers within
the same country, state, region, industry or sector, an adverse economic, business or political development may affect the value of the
Fund’s investments more than if the Fund were more broadly diversified. A significant exposure makes the Fund more susceptible to
any single occurrence and may subject the Fund to greater market risk than a fund that is more broadly diversified.

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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

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