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    August 20, 2020

Ms. Kimberly Browning

Senior Counsel

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

 Re: AlphaMark Investment Trust File No. 333-152045

Dear Ms. Browning:

On June 25, 2020, AlphaMark Investment
Trust (the “Registrant” or the “Fund”) filed a post-effective amendment to its registration statement.
You provided comments last week via telephone to Cassandra Borchers. Those comments are summarized below. Following each comment
are the Registrant’s responses, which the Registrant has authorized Thompson Hine LLP to make on its behalf. Capitalized
terms used but not otherwise defined herein have the meaning ascribed to them in the Fund’s registration statement.

 1. Please acknowledge that Registrant has reviewed the SEC’s
public announcement from October 15, 2016 and that the Registrant is responsible for all disclosures in the Fund’s registration
statement.

RESPONSE: Registrant understands, in accordance with SEC’s
public announcement on October 5, 2016, that management and the Registrant are responsible for the accuracy of the disclosures
in the Fund’s registration statement.

 2. In Item 9 disclosure, Registrant references selling securities short. Please confirm the expenses that arise from short sales
are include in “Other Expenses” in the Fee Table. If these are material, consider including under a separate caption.

RESPONSE: The Fund does not currently engage in short selling
of securities and does not intend to do so as part of its principal investment strategy. The disclosure in Item 4 and Item 9 has
been revised accordingly.

 3. We further note that short sales against the box are reflected in the Item 9 disclosure. If short sales are a principal investment
strategy, please include a discussion in the Item 4 Summary. Also specify the types and extent of short sales (i.e. whether short
sales will be against the box or naked). If short sales are not against the box, confirm the Fund is segregating assets appropriately.

RESPONSE: The Fund does not currently engage in short selling
of securities and does not intend to do so as part of its principal investment strategy. The disclosure in Item 4 and Item 9 has
been revised accordingly.

    Cassandra.Borchers@ThompsonHine.com Fax: 513.241.4771 Phone: 513.352.6632

August 20, 2020

Page 2

 4. Please explain why the AFFE line is estimated per footnote 1. Review instruction 3.D(ii)(B) and include appropriate language
that the information is restated to reflect current fees.

RESPONSE: The AFFE expense has been restated and estimated
to reflect the revised investment strategy and increase of investments in ETFs. Registrant has revised the footnote to read:

 (1) Restated and estimated for the current fiscal year to reflect current fees due to the change in investment strategy. Acquired
Fund Fees and Expenses are the indirect costs of investing in other investment companies such as Underlying ETFs. The operating
expenses in this fee table will not correlate to the expense ratio in the Fund’s financial highlights because the financial
statements include only the direct operating expenses incurred by the Fund, not the indirect costs of investing in other investment
companies.

 5. In Footnote 2, please confirm the expiration date of the ELA.

RESPONSE: The term of the current expense limitation agreement
will expire on December 31, 2021. The Footnote has been revised as described in response to comment 6.

 6. Fee and Expenses. In footnote 2 to the Fund’s fee table, please revise the second sentence to disclose in a clearer
fashion, the circumstances under which the adviser may seek reimbursement of fees waived/reimbursed from the Fund. In this regard,
we note that fees waived/reimbursed may only be recouped within three years from the date of the waiver/reimbursement. Also, a
fund may only make repayments to the adviser if such repayment does not cause the fund’s expense ratio (after the repayment
is taken into account) to exceed both: (1) the expense cap in place at the time such amounts were waived; and (2) the fund’s
current expense cap.1, and the recapture amount must result in an expense ratio that is the lesser of: (a) the expense
limit in effect at the time of the waiver or reimbursement; and (b) the expense limit in effect at the time of recapture.

1.       See
AICPA Audit Risk Alert ARA-INV.73, available at https://www.aicpa.org/InterestAreas/FRC/IndustryInsights/DownloadableDocuments/INV/ARAI

NV_Industry%20Developments_SEC_Staff_Comments_and_Observations_2008_2014.pdf.

RESPONSE: The Footnote has been revised, as follows:

 (2) Management Fee waivers and expense reimbursements by the Advisor are subject to repayment by the Fund for a period of 3 years
after the date of such waiver or reimbursement, provided that the repayments do not cause the Fund’s expense ratio (after
the repayment is taken into account) to exceed both: 1) the expense cap in place at the time such amounts were waived or reimbursed;
and 2) the Fund’s current expense cap. The repayment amount must result in an expense ratio that is the lesser of: (a) the
expense limit in effect at the time of the waiver or reimbursement; and (b) the expense limit in effect at the time of the repayment.

August 20, 2020

Page 3

 7. We note the portfolio turnover rate of 273% is atypical. Per Item 16(e), please include an explanation for the differences
from the most recently completed fiscal years and/or expected variance from the last complete fiscal year in the SAI.

RESPONSE: The Registrant notes that the SAI discloses the
basis for the increase in the Fund’s portfolio turnover rate for the fiscal year ended August 31, 2019 relative to prior
years. The Portfolio Turnover section of the SAI discloses the following information in compliance with Item 16(e):

The increase in portfolio turnover
in 2019 was a result of the Fund trading more frequently to take advantage of market volatility and price swings with respect to
portfolio stocks in an effort to generate higher returns.

 8. We note the portfolio turnover from 2019 disclosure suggests the Fund is actively trading. If the Fund engages in active and
frequent trading, please enhance the Item 4 Summary to disclose this as part of the principal investment strategy.

RESPONSE: The Fund does not engage in active and frequent
trading as part of the Fund’s principal investment strategy and, therefore, the Registrant declines to revise Item 4. The
Registrant notes that the unusual trading activity of the Fund was during a period of high market volatility.

 9. Is the Fund investing in both domestic and foreign issuers? Please use Plain English to clarify what type of securities the
Fund may invest in—Common? Preferred? ETFs? Are there any specific ETFs to be included in the strategy disclosures?

RESPONSE: The Prospectus has been revised to clarify that
the Fund will invest in ETFs, individual large cap common stocks and securities issued by foreign companies that are listed on
a U.S. exchange, including sponsored American depositary receipts. The Fund may also hold preferred stocks from time to time that
it receives as part of a corporate action. There are no specific ETFs to disclose as part of the Fund’s principal investment
strategy.

 10. If the Fund is heavily invested in certain sectors currently then please disclose as part of the principal investment strategy.
We note as of 5/31 that the Fund had 17.2% in Healthcare for example. Consider whether you should include disclosures about specific
sectors. If not, explain to the Staff why these are not principal investment strategies in the supplemental correspondence.

RESPONSE: The Registrant notes that allocations to a particular
sector will not be part of the Fund’s principal investment strategy. The Fund’s investment strategy may take advantage
of undervalued and overvalued sectors from time to time; however, the Fund will not be excessively overweight or underweight any
particular sector. The Registrant confirms to the Staff that the Fund will not exceed +/- 50% exposure to any sectors represented
in the S&P 500 Index. Because sector concentration will not be part of the Fund’s principal investment strategy, Registrant
declines to include disclosure regarding any specific sector in the Prospectus. However, the SAI disclosure has been modified to
include risk factors for each sector of the S&P 500 Index as an overweight in a particular sector may occur.

August 20, 2020

Page 4

 11. Revise the second sentence of the second paragraph of Principal Investment Strategies for Plain English.

RESPONSE: The sentence has been
revised, as follows:

The Advisor seeks to invest in underlying
ETFs or individual equity securities that it believes represent the best risk-adjusted investment options.

 12. Will the Fund invest in any affiliated ETF’s? If so, will the Advisor waive its management fee with respect to such investments?

RESPONSE: The Fund will not invest
in the Advisor’s affiliated ETF.

 13. With respect to the Fund’s investments in ADR’s, indicate in the Item 4 Summary whether the Fund may invest in
both sponsored and unsponsored ADRs and indicate the risks of such investments.

RESPONSE: The Item 4 Summary has been revised to reflect
the fact that the Fund will invest in sponsored ADRs as part of its principal investment strategy.

 14. The Item 4 Summary disclosure includes, “…and may deploy an Options Strategy.” Please clarify and explain
in Plain English what the option strategy will be. Will this include writing options? Selling options?

RESPONSE: The disclosure has been
revised, as follows:

During periods of volatility, the
Fund may utilize the following option strategies: (i) buy puts to seek protection for a portion of the portfolio; (ii) write puts
to generate income while waiting for a stock price to become more reasonable; and (iii) write calls to generate income on stock
positions that the Advisor believes are becoming overvalued.

 15. In the discussion of options, Registrant uses the word “protection”. We object to the use of “protection”
because it is misleading and suggests a guaranteed outcome. Consider adding “seeking to” or use a different term to
explain as hedging (if this is appropriate).

RESPONSE: The requested revisions have been made and “to
seek” precedes any use of the word protection with respect to options strategies.

 16. Confirm to the Staff in your response that options are not used for speculative purposes and clarify whether options are part
of the Fund’s principal or non-principal investment strategy. If you do use for speculative purposes, add disclosure stating
as much.

RESPONSE: The Registrant does not use options for speculative
purposes and options are part of the Fund’s principal investment strategy. The disclosure has been updated accordingly.

August 20, 2020

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 17. In Item 9, to the extent necessary, revise to reflect comments and revisions to Item 4 Summary. For example, Item 9 states
there may be naked short sales and if that is correct and it is part of the Principal Investment Strategy, it should be clarified
in the Prospectus and appropriate risks added.

RESPONSE: The Item 9 disclosure
has been updated to remove any reference to short sales.

 18. Consider adding a sentence or two to the third paragraph of the Item 4 strategy disclosure to discuss considerations the Advisor
uses when deciding to sell a security.

RESPONSE: The third paragraph
of the Item 4 strategy disclosure has been updated, as follows:

The Advisor may sell an individual equity
from the Fund's portfolio under one or more of the following circumstances:

 • A material change in the company's structure or management;

 • A material change in the industry, sector, or economic factors affecting that industry;

 • A position has doubled in weight;

 • Analysts’ estimates of future earnings of the company have decreased by more than 5%;

 • The price has become overvalued by 20% or more based on the Advisor's proprietary cash flow models; or

 • To take advantage of price swings caused by market volatility or events due to the foregoing circumstances.

 19. In Item 9, indicate the types of ADRs that may be used and add more clarification.

RESPONSE: The disclosure has been
modified to reflect that the Fund may invest in sponsored American depositary receipts.

 20. We note there is a “Derivatives Risk”. Please harmonize risks disclosures to strategy and consider whether the
Options Risk is more appropriate.

RESPONSE: The Derivatives Risk
has been removed and the Options Risk has been revised.

 21. See Barry Miller Letter from July 30, 2010. Please address and properly summarize the Fund’s use of derivates. Please
confirm, revise accordingly, and acknowledge this Letter in your response.

RESPONSE: The Registrant confirms
that the Fund’s revised options disclosures in the Registration Statement are consistent with the SEC staff’s guidance
as articulated in the Barry Miller Letter.

 22. Again, please confirm if the Fund will invest in foreign securities as part of its principal investment strategy. Could this
be misleading? We note as of May 31, 2020 the Fund was invested 97.39% in US.

RESPONSE: See response to Comment 9 above. The disclosure
has been revised to reflect the fact that the Fund may invest in securities of foreign issuers that are listed on a U.S. exchange
as part of its principal investment strategy.

August 20, 2020

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 23. The Hedging Risk is jargon-laden. Re-evaluate if this risk is appropriate and if it is, re-write using Plain English. Clarify
also whether the Fund is segregating assets. Avoid generalizing in the risk factor, be specific as it relates to the Fund.

RESPONSE: The Hedging Risk has
been revised in Plain English, as follows:

Hedging is a strategy in which the
Fund uses an option to offset the risks associated with certain Fund holdings. There can be no assurance that the Fund’s
hedging strategy will reduce risk or that hedging transactions will be either available or cost effective. The Fund is not required
to use hedging and may choose not to do so.

 24. Please enhance the Options Risk to summarize the tax risks and all discussion of OTC risks per Item 9 disclosure. We note the
information is included in the Item 9 risk, provide a more fulsome summary for Item 4.

RESPONSE: The Options Risk has
been revised, as follows:

There are risks associated with the
sale and purchase of call and put options. In general, option prices are highly volatile and may fluctuate substantially during
a short period of time. As a seller (writer) of a put option, the Fund will tend to lose money if the value of the reference index
or security falls below the strike price. As the seller (writer) of a call option, the Fund will tend to lose money if the value
of the reference index or security rises above the strike price. As the buyer of a put or call option, the Fund risks losing the
entire premium invested in the option if the Fund does not exercise the option. Certain of the options in which the Fund may invest
may be traded (and privately negotiated) in the Over-the-Counter (“OTC”) market. The OTC market is largely unregulated.
As a result and similar to other privately negotiated contracts, the Fund is subject to counterparty credit risk with respect to
such option contracts.

Option premiums are treated as short-term capital gains
and when distributed to shareholders, are usually taxable as ordinary income, which may have a higher tax rate than long-term capital
gains for shareholders holding Fund shares in a taxable account.

 25. Global Market Risk. Please note, significant market events have occurred as a result of the COVID-19 pandemic since
this post-effective amendment. Please consider whether the Fund’s disclosures, including risk disclosures, should be revised
based on how these events may affect