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Magda El Guindi-Rosenbaum

+1.202.373.6091

mer@morganlewis.com

VIA EDGAR

August 29, 2023

Deborah O’Neal, Esq.

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

 Re: Exchange Traded Concepts Trust (File Nos. 333-156529 and
811-22263)

Dear Ms. O’Neal:

This letter responds to comments relating to Post-Effective Amendment
No. 425 (“PEA No. 425”) to the registration statement on Form N-1A of Exchange Traded Concepts Trust (“Registrant”).
PEA No. 425 was filed on June 30, 2023, to reflect revisions to the principal investment strategy disclosure for Registrant’s ROBO
Global® Robotics and Automation Index ETF, ROBO Global® Healthcare Technology and Innovation ETF, and ROBO
Global® Artificial Intelligence ETF (the “Funds”) in connection with index methodology changes. For ease of
reference, set forth below are the staff’s comments followed by Registrant’s responses. Unless otherwise noted, capitalized
terms have the same meaning as those contained in PEA No. 425.

 1. Comment. Please provide the Funds’ completed fee table, expense example, and performance information at least
one week before the registration statement becomes effective.

Response. Registrant represents that the requested
information has been provided under separate cover.

 2. Comment. The staff notes that the fourth sentence of the
                                            first paragraph of the principal investment strategies of ROBO Global® Robotics
                                            and Automation Index ETF seems to be overly broad because of the term “in any capacity,”
                                            which could make the strategy inconsistent with the Fund’s name.

Response. Registrant represents that the term
has been deleted.

 3. Comment. With respect to the third sentence of the second
                                            paragraph of the principal investment strategies of ROBO Global® Robotics
                                            and Automation Index ETF, please add a brief description of the criteria used to determine
                                            which Robotics and Automation Companies “improve efficiency in traditional business
                                            lines”.

Response. Registrant represents that according
to the index provider the referenced language is extraneous and, therefore, has been deleted from the sentence.

    Morgan, Lewis & Bockius llp

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    Washington, DC  20004
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     +1.202.739.3001

August 29, 2023

Page 2

 4. Comment. With respect to the principal investment strategies
                                            of ROBO Global® Healthcare Technology and Innovation ETF, the staff notes
                                            that the second paragraph states that companies eligible for inclusion in the Index are those
                                            included in the HTEC Database. Please clarify how the HTEC Database is created.

Response. Registrant represents that the disclosure
has been clarified.

 5. Comment. The staff notes that ROBO Global®
                                            Healthcare Technology and Innovation ETF does not seem to disclose a global connection in
                                            its principal investment strategy.

Response. Registrant represents that the
term “Global” in the Fund’s name is part of the registered trademark “ROBO Global®” and
is not included in the name to connote diversification among a number of countries throughout the world. Nevertheless, Registrant notes
that the fifth paragraph of the Fund’s principal investment strategies states that the Index is comprised of U.S. and foreign issuers
and that under normal circumstances the Index expects at least 20% of its components to be securities of non-U.S. issuers.

 6. Comment. With respect to the principal investment strategies
                                            of ROBO Global® Artificial Intelligence ETF, the staff notes that the second
                                            paragraph states that companies eligible for inclusion in the Index are those included in
                                            the AI Database. Please clarify how the AI Database is created.

Response. Registrant represents that the disclosure
has been clarified.

 7. Comment. The staff notes that ROBO Global®
                                            Artificial Intelligence ETF does not seem to disclose a global connection in its principal
                                            investment strategy.

Response. Registrant represents that the
term “Global” in the Fund’s name is part of the registered trademark “ROBO Global®” and
is not included in the name to connote diversification among a number of countries throughout the world. Nevertheless, Registrant notes
that the sixth paragraph of the Fund’s principal investment strategies states that the Index is comprised of U.S. and foreign issuers
and that under normal circumstances the Index expects at least 25% of its components to be securities of non-U.S. issuers.

 8. Comment. Please consider prioritizing the most significant principal risks of each Fund rather than listing all the
risks alphabetically (see ADI 2019-08).

Response. Registrant notes that alphabetically
ordering the principal risks allows shareholders to more easily and quickly locate particular risk disclosure within the list of risks
and provides for easier comparison of risks across funds. Registrant also notes that Form N-1A does not require a particular method of
listing a fund’s principal risks. Therefore, Registrant respectfully declines to reorder the principal risks at this time.

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August 29, 2023

Page 3

If you have questions or comments, please do not hesitate to contact
me at 202.373.6091.

Sincerely,

/s/ Magda El Guindi-Rosenbaum

Magda El Guindi-Rosenbaum