SecProbe.io

CORRESP
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  Morrison Warren

Partner

  Chapman and Cutler LLP

320 South Canal Street, 27th Floor

Chicago, Illinois 60606

T 312.845.3484

warren@chapman.com

November 20, 2024

VIA EDGAR CORRESPONDENCE

Soo Im-Tang

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

    Re:
    Exchange Traded Concepts Trust (the “Registrant”), on behalf of its series,

    MUSQ Global Music Industry Index ETF

    File No. 333-156529

Dear Ms. Im-Tang:

This letter responds to your
comments provided telephonically regarding the registration statement filed by the Registrant on Form N-1A (the “Registration
Statement”) with the staff of the Securities and Exchange Commission (the “Staff”) on November 15, 2024,
on behalf of MUSQ Global Music Industry Index ETF (the “Fund”), a series of the Registrant. Capitalized terms used
but not defined herein have the meanings ascribed to such terms in the Registration Statement and the prospectus contained therein (the
“Prospectus”). We are submitting via EDGAR this letter on behalf of the Fund, which is intended to respond to your
comments.

Comment
1 – General

Please provide responses to
all of the Staff’s comments on EDGAR at least five business days before the effective date of the filing.

Response
to Comment 1

The Registrant confirms it
will provide responses in a timely manner.

Comment
2 – Fee Table

The fee table footnote states,
“Exchange Traded Concepts, LLC (the “Adviser”) has contractually agreed to waive a portion of its management fee in
an amount equal to 0.14% of average daily net assets through August 31, 2025.” Please confirm that the date will be extended so
that the termination of the agreement will be at least one year from the effective date of the Fund’s registration statement with
respect to the waiver.

Response
to Comment 2

The fee waiver agreement has
been extended to November 30, 2025 with respect to the Fund.

Comment
3 – Fee Table

Please confirm that, pursuant
to the terms of the fee waiver agreement, the Adviser has no ability to recoup previously waived fees.

Response
to Comment 3

The Registrant confirms that
the Adviser is not able to recoup waived fees pursuant to the terms of the fee waiver agreement.

Comment
4 – Principal Investment Strategies

The first paragraph of the
Principal Investment Strategy section states, “The Index is designed to track the performance of companies that are involved in
the following sub-segments of the global music industry (the “Global Music Industry”): (i) music streaming; (ii) music content
and distribution; (iii) live music events/ticketing; and (iv) music equipment and technology (“Global Music Companies”).”

Please explain whether the
term “Global Music Companies” applies solely to subpart (iv) or collectively to subparts (i) through (iv). If the latter,
please insert “collectively” in front of “Global Music Companies.”

Response
to Comment 4

The Registrant confirms that
the term “Global Music Companies” is intended to collectively apply to the enumerated subparts and will revise the disclosure
accordingly.

Comment
5 – Principal Investment Strategies

The Principal Investment Strategy
section states, “As of ________, 2024, the Index was concentrated in the Music Industry. In addition, in replicating the Index,
the Fund may from time to time invest a significant portion of its assets in the securities of companies in one or more sectors. As of
________, 2024, a significant portion of the Index consisted of companies in the ________ Sector.”

Please confirm whether such
sector will be included as a risk factor. If not, please explain why.

Response
to Comment 5

The Registrant respectfully
directs the Staff’s attention to “Sector Focus Risk.” To the extent that the Fund has significant exposure to a particular
investment sector, such sector will be disclosed, with the accompanying risks, in this particular risk factor.

Comment
6 – Principal Risks Section

The Staff notes the principal
risks currently appear in alphabetical order. Please organize this section to prioritize the risks that are most likely to adversely affect
the Fund’s NAV, yield or return.

Response
to Comment 6

The Registrant respectfully
declines to revise the disclosure as requested by the Staff. Ultimately, the Registrant has reached the same conclusion as many other
industry participants and declines to make the requested revisions as it believes the disclosure is compliant with the requirements of
Form N-1A. The Registrant continues to evaluate its approach to the ordering of risk factors in light of recent Securities and Exchange
Commission guidance.

Comment
7 – Principal Risks Section

The Staff notes that the Fund
will be concentrated in an industry or group of industries to the extent that the Index is so concentrated. Accordingly, please revise
the section entitled “Principal Risks” to include “Concentration Risk.” Such risk should disclose that because
the Fund’s assets will be concentrated in a particular industry or group of industries to the extent that the Index concentrates
in a particular industry or group of industries, the Fund is subject to loss due to adverse occurrences that may affect that particular
industry or group of industries.

Response
to Comment 7

The Registrant respectfully
declines to revise the disclosure as it believes that “Industry Concentration Risk,” currently included and reproduced below,
addresses the concern outlined by the Staff.

Industry Concentration Risk. Because
the Fund’s assets will be concentrated in an industry or group of industries to the extent the Index concentrates in a particular
industry or group of industries, the Fund is subject to loss due to adverse occurrences that may affect that industry or group of industries.
The list below is not a comprehensive list of the industries to which the Fund may have exposure over time and should not be relied on
as such. As of [           ], 2024, the Index was concentrated in the Music Industry.

Music Industry Risk. The music industry
is highly competitive and rapidly evolving, influenced by technological advancements, changing consumer preferences and regulatory developments.
The music industry is susceptible to technological changes that can alter the way music is produced, distributed and consumed. New technologies
may disrupt traditional business models, potentially rendering existing products or services obsolete. The rise of digital streaming platforms,
for instance, has significantly impacted physical music sales and traditional radio. Companies within the music industry rely heavily
on intellectual property rights, including copyrights and trademarks. Legal challenges, disputes over licensing, or changes in copyright
law could negatively impact revenue streams. Additionally, unauthorized use of copyrighted material, piracy, and inadequate enforcement
of intellectual property rights may lead to significant financial losses. The music industry is also highly influenced by consumer tastes,
which can be unpredictable and volatile. A sudden shift in popular genres, artists or formats may adversely affect companies that fail
to adapt quickly. Moreover, the cyclical nature of entertainment trends could lead to periods of decreased profitability for companies
reliant on specific music genres or artist portfolios. Additionally, the music industry is subject to various regulatory frameworks across
different jurisdictions, including content restrictions, royalty rates, and antitrust laws. Changes in regulations or enforcement practices
could increase costs, limit business operations or impact revenue. Additionally, companies may face litigation risks, including class
actions or regulatory investigations, that could result in substantial financial penalties. Like many industries that rely upon consumer
spending, the music industry is sensitive to broader economic conditions. In periods of economic downturn, discretionary spending on entertainment,
including music, may decline. This could result in reduced revenue for companies that depend on consumer spending for music purchases,
concert attendance, and other related activities. The success of music companies often depends on the popularity and productivity of specific
artists. The inability to attract or retain talent, or the loss of key artists, could adversely impact a company’s financial performance.
Additionally, the unpredictable nature of artist behavior, including public controversies or legal issues, can result in reputational
damage and financial loss.

Comment
8 – Principal Risks

To the extent that the Fund
will invest in securities that trade in a market that is closed while the market in which the Fund’s shares are listed and trading
in that market is open, please disclose there may be changes from its closed foreign market and the value of such security during the
Fund’s domestic trading day. In addition, please note that this difference, in turn, could lead to discrepancies between the market
price of the Fund’s shares and the underlying value of those shares.

Response
to Comment 8

Pursuant to the Staff’s
comment, the following risk disclosure has been added to the section entitled “Principal Risks”:

International Closed Market Trading
Risk. Because securities held by the Fund trade on non-U.S. exchanges that are closed when the Fund’s primary listing exchange
is open, there are likely to be deviations between the current price of an underlying security and the last quoted price for the underlying
security (i.e., the Fund’s quote from the closed foreign market) used for purposes of calculating the Fund's net asset value, resulting
in premiums or discounts to the Fund’s net asset value that may be greater than those experienced by other exchange-traded funds.
In addition, shareholders may not be able to purchase and sell shares of the Fund on the listing exchange for the Fund, on days when
the net asset value of the Fund could be significantly affected by events in the relevant foreign markets.

Comment
9 – Exhibits

Please file as an exhibit
to the Registration Statement the index license agreement or sub-license agreement to which the Fund is a party.

Response
to Comment 9

Pursuant to the Staff’s
comment, the Registrant has filed the index sub-license agreement as an exhibit to the Registration Statement.

Comment
10 – Additional Principal Risk Information

Please provide a title for
the risk beginning on page fourteen of the “Additional Principal Risk Information” section.

Response
to Comment 10

The referenced disclosure
has been revised to indicate that it is referring to “Index Provider Risk.”

Comment
11 – Additional Principal Risk Information

The “Sector Focus Risk”
states, “As of [         ], 2024, a significant portion of the Index consisted of companies in the [             ] Sector.” Please complete the
risk disclosure and include sub-risks that correspond to each identified sector.

Response
to Comment 11

The Registrant confirms that
the applicable disclosure will be provided.

Comment
12 – Statement of Additional Information

Please note that it is the
Staff’s position that a Fund and its adviser may not ignore the investments of both unaffiliated and affiliated investment companies
when determining whether a Fund is compliant with its concentration policy. Please confirm whether the Fund will consider the investments
of its underlying investment companies when determining the Fund’s compliance with its concentration policies.

Response
to Comment 12

The Fund’s principal
investment strategies do not contemplate investing in securities of either unaffiliated or affiliated investment companies. The Registrant
is also unaware of any requirement to “look through” its investments in an investment company to the underlying holdings of
the investment company for purposes of determining compliance with its policies on concentrating its investments; however, to the extent
that the Registrant determines that the Fund’s investments in an underlying investment company exposes the Fund to material risks
or significant exposure to a particular industry or group of industries, the Registrant would include appropriate disclosure in the Fund’s
Registration Statement.

* * * * * * * * * * * * * * *
* * * * * *

Please call me at (312) 845-3484
if you have additional comments or wish to discuss any of the foregoing responses. Thank you.

    Very truly yours,

    Chapman and Cutler llp

    By:
    /s/ Morrison C. Warren

    Morrison C. Warren, Esq.

 cc: Richard Malinowski, Esq., Vice President and Secretary of
Exchange Traded Concepts Trust

    Richard Coyle, Esq., Partner, Chapman and Cutler LLP