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 www.dechert.com

 VIA EDGAR CORRESPONDENCE

 September 19, 2025

 Deborah L. O'Neal

 Senior Counsel

 U.S. Securities and Exchange Commission

 Division of Investment Management

 100 F Street NE

 Washington, DC 20549

 Re: ARK ETF Trust ("Registrant"), SEC File No. 333-191019 and 811-22883

 Post-Effective Amendment
No. 34 to the Registrant's Registration Statement on Form N-1A ("Amendment")

 Dear Ms. O'Neal:

 We are writing in response to comments that you
provided on August 14, 2025 with respect to your review of the Amendment to the Registrant's registration statement filed with the
U.S. Securities and Exchange Commission ("SEC") on July 3, 2025. The Amendment was filed pursuant to Rule 485(a) under the
Securities Act of 1933 for the purpose of registering an unlimited number of shares of beneficial interest of ARK DIET Q1 Buffer ETF,
ARK DIET Q2 Buffer ETF, ARK DIET Q3 Buffer ETF and ARK DIET Q4 Buffer ETF (previously known as the ARK Q1 Defined Innovation ETF, ARK
Q2 Defined Innovation ETF, ARK Q3 Defined Innovation ETF and ARK Q4 Defined Innovation ETF, respectively) (each a "Fund" and,
collectively, the "Funds"). We have reproduced your comments below, followed by the Registrant's responses. Capitalized
terms have the meaning attributed to such terms in the Registration Statement.

 1. Comment :
With respect to the first page of the prospectus and summary prospectus, please add bulleted disclosure addressing the following:

 a. The Outcome risk related to the downside participation offset, Hurdle rate, underlying ETF, and period.

 b. State that the Hurdle rate is estimated and expected to be 5% (and show before and after Fund fees and
expenses), but there is no guarantee that the final Hurdle rate set for an Outcome Period will be the same as this estimate.

 c. Specify the type of return (market price, not NAV) on the underlying ETF on which the Outcomes are based.

 d. Show that the downside participation offset and Hurdle rate will be reduced by brokerage commissions,
trading fees, taxes, and extraordinary expenses not included in the management fee. Show the Hurdle rate and downside participation offset
values before and after expenses.

 e. Disclose that the specified outcomes may not be achieved, and investors may lose some or all of their
money.

 f. Disclose that the Fund only provides the specified Outcome if an investor buys on the first day of the
period and holds the Fund until the end of the period.

 g. Disclose that if investors buy or sell on a date other than the start or end date, their returns will
be different, and they may incur losses that are greater than the downside participation offset.

 h. Explain how an investor will be able to obtain the return data for the Fund through the end of the Outcome
Period and may change for each Outcome Period at that time.

 i. Disclose that the downside participation offset and Hurdle rate will be established each year on the first
day of each Outcome Period and may change for each Outcome Period at that time.

 Response : The Registrant
will include the cover page disclosure contained in Exhibit A to this response letter with the filing of the 485(b) for the Funds.

 2. Comment :
With respect to the narrative preceding the fee table in the prospectus and summary prospectus, please bold the second sentence in the
narrative on fund fees and expenses (" Investors may pay other fees, such as brokerage commissions and other fees to financial
intermediaries on their purchases and sales of Shares, which are note reflected in the tables and examples below. "), per Form
N-1A instructions.

 Response : The Registrant
will revise the referenced disclosure accordingly.

 3. Comment :
With respect to the fee table in each summary prospectus, please revise footnote (b) to the following: "Other Expenses, Acquired
Fund Fees and Expenses and Total Annual Fund Operating Expenses are based on estimated expenses for the current fiscal year."

 Response : The Registrant
will revise the referenced disclosure accordingly.

 4. Comment :
With respect to the fee table in each summary prospectus, please revise footnote (c) to clarify under what circumstances the fee arrangement
can be terminated. If only the Board can terminate this arrangement, it is okay to display in connection with the fee table; otherwise,
it is not. In addition, please confirm there is no reimbursement or recoupment of waived fees for the Adviser.

 Response : The Registrant confirms
there is no reimbursement or recoupment of waived fees for the Adviser. In addition, the Registrant has revised footnote c to the following:

 The Adviser has voluntarily agreed to
waive a portion of its management fee payable by the Fund in an amount equal to the investment advisory fee portion of the management
fee it earns as an investment adviser to the affiliated fund(s) in which the Fund invests. The fee waiver arrangement will continue for
at least one year from the date of this Prospectus and prior to such date the Investment Adviser may not terminate the arrangement
without the approval of the Board of Trustees.

 5. Comment :
With respect to the Principal Investment Strategies section in each summary prospectus, please address the following:

 a. In the Delta-One Exposure paragraph, since the performance of the Fund is based entirely on the performance
of the Underlying ETF, please describe the Underlying ETF's principal investments and include corresponding risks in the principal
risk discussion.

 Response : The Registrant has
added disclosure summarizing the Underlying ETF's principal investment strategies and principal risks to the extent not already
included in the "Principal Investment Strategies" and "Principal Risks" section of each Fund's prospectus,
as applicable. In addition, the following has been added to the "Principal Risks" section of each Fund's summary prospectus.

 Investments in Affiliated Underlying
Funds. The investments of the Fund will be concentrated in the Underlying ETF subject to limitations and/or conditions prescribed
by the Investment Company Act. The Investment Adviser is compensated by the Fund and the Underlying ETF for advisory services provided.
The portfolio managers may also be subject to conflicts of interest in allocating Fund assets to the Underlying ETF because the Fund's
portfolio management team may also manage the Underlying ETF. The Trustees and officers of ARK ETF Trust (the "Trust") may
also have conflicting interests in fulfilling their fiduciary duties to both the Fund and the Underlying ETF, for which the Adviser serves
as investment adviser. In addition, the Investment Adviser's authority to allocate investments among affiliated and unaffiliated
investment companies creates conflicts of interest. For example, investing in affiliated investment companies could cause the Fund to
incur higher fees and may cause the Investment Adviser and/or its affiliates to receive greater compensation, increase assets under management
or support particular investment strategies or affiliated investment companies.

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 b. Add disclosure about the impact of investing on a day other than the first day of the Outcome Period and
selling on a day other than the last day.

 Response : The Registrant will
add the following to each Fund's "Principal Investment Strategies" section:

 The Fund's investment strategy
is designed to deliver targeted outcomes that may only be realized if Fund shares are bought by the first day of the Outcome Period and
held until the end of the Outcome Period. If an investor purchases or sells shares during the Outcome Period, the returns realized by
the investor will not match those that the Fund seeks to achieve.

 The Hurdle, participation rate and downside
participation offset are established prior to taking into account the Fund's fees and expenses reflected in the "Fund Fees and Expenses"
Table annualized over each Outcome Period. Accordingly, the Fund's returns will be reduced by Fund fees and expenses as well as
any brokerage commissions, trading fees, taxes and non-routine or extraordinary expenses incurred by the Fund throughout an Outcome Period.
This means that the Fund's NAV will only increase to the extent that the Fund's participation in the Underlying ETF's
share price increase beyond the 5% Hurdle exceeds the Fund's fees and expenses. This also means that the Fund's returns will
be further reduced by the Fund's fees and expenses when the share price of the Underlying ETF declines. The Fund will receive any
dividends paid by the Underlying ETF with respect to the shares in the Underlying ETF held by the Fund.

 On or about the commencement of an Outcome
Period, the Fund will supplement this prospectus and publish on its website (https://www.ark-funds.com) the Fund's participation
rate for the next Outcome Period. Investors considering an investment in the Fund must visit the website for the latest information.

 c. Describe the relationship between the outcome, Underlying ETF, and fund NAV throughout the Outcome Period.

 Response : Please see
response to comment 5(b).

 d. Clarify that the downside participation offset and Hurdle rate can be reduced by brokerage commissions,
trading fees, taxes, and extraordinary expenses not included in the management fee. Show the Hurdle rate/downside participation offset
values before and after expenses.

 Response : Please see response
to comment 5(b). In addition, please note that the Registrant will add a chart to the end of the "Principal Investment Strategies"
section of each Fund's prospectus showing examples of Fund performance based on the Hurdle/downside participation offset level during
periods of positive, negative, and flat Underlying ETF returns both before and after Fund expenses.

 e. Disclose that the Fund's performance reflects the Underlying ETF's share price, not NAV, and whether dividends paid by
the Underlying ETF are reflected in the Fund's performance.

 Response : Please see
response to comment 5(b).

 f. Explain how the Hurdle rate works. Investors will only experience gains if the Underlying ETF's share price increases beyond
the 5% Hurdle over the Outcome Period, and then only to the extent that the Underlying ETF's share price increase beyond the 5%
Hurdle exceeds the Fund's fees and expenses.

 Response : Please see response
to comment 5(b).

 g. Describe what happens if the Underlying ETF share price does not exceed the Hurdle at the end of the Outcome Period. Describe how
the next Hurdle and downside participation offset is determined and where investors can find terms of the new Hurdle and downside participation
offset.

 Response : The Registrant will
revise the disclosure under the "Use of Options Premiums" sub-section of the Principal Investment Strategies section of each
Fund's prospectus to the following:

 a. Downside Participation Offset :
The Fund uses part of the call premium to purchase create the downside participation offset by purchasing
at-the-money put options on the Underlying ETF with a notional value equal to 50% of the Fund's NAV. This put position offsets half
of the Fund's delta-one exposure to the Underlying ETF's downside, resulting in a 50% net downside participation over the
Outcome Period. In other words, for every 1 2 % decline in the Underlying ETF, the net asset value
of the Fund is expected to decline by approximately 0.5 1 % , up to the full 50% cap .;
and

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 b. Hurdle and Participation
Rate : The Fund uses the remaining premium is used to purchase establish
the Hurdle and upside participation rate by purchasing out-of-the-money call options on the Underlying ETF with strike prices
equal to 105% of the Underlying ETF's share price at the beginning of the Outcome Period (i.e. the Hurdle) . This
creates a zero payoff region between 100% and 105% , meaning the net asset value of the Fund will not increase until the Underlying
ETF's share price exceeds 105% of the Underlying ETF's share price at the beginning of the Outcome Period plus the Fund's
fees and expenses , and allows the Fund to provide maximum upside participation above the Hurdle through the long
calls, subject to the size of the notional coverage. The participation rate is determined prior to each Outcome Period by the Sub-Adviser .

 h. Include a chart at the end of the "Principal Investment Strategies" section of each Fund's prospectus showing the
returns the Fund seeks to provide for investors holding shares throughout the Outcome Period based on the Hurdle/downside participation
offset that the Fund expects to offer as of the date of the prospectus. The presentation should show the Fund's expected return
based on the Hurdle/downside participation offset during periods of positive, negative, and flat Underlying ETF returns.

 Response :

 The Registrant will revise the "Principal
Investment Strategies section of each Fund's prospectus to add a chart depicting examples of the Fund's performance based
on the Hurdle/downside participation offset during periods of positive, negative, and flat Underlying ETF returns.

 6. Comment :
With respect to the Principal Risks section in each summary prospectus, please:

 a. Add that the Fund has characteristics unlike many other traditional investment products and may not be appropriate for all investors.

 Response : The Registrant will
add cover page disclosure including the following statement:

 "The Funds have characteristics
unlike many other traditional investment products and may not be suitable for all investors."

 b. Add that the Fund's value may not directly correlate to the Underlying ETF. This is because of fees and transaction expenses
and because the Flex Options are only exercisable on the expiration date, and the fluctuating value of the Flex Options will affect the
Fund's value.

 Response : The Registrant will
add disclosures regarding the impact of Fund fees and expenses as described in response to previous comments. The Registrant will add
the following sentence at the end of the "Flex Options Risk" sub-section of the "Principal Risks" section of each
Fund's prospectus:

 Due to the cost of the options used
by the Fund and other Fund fees and expenses, the correlation of the Fund's performance to that of the Underlying ETF is expected
to be less than if the Fund solely invested directly in the Underlying ETF (i.e., without using options), and could be substantially less.

 c. Add a risk describing the type of investors the Fund may be appropriate for and those it may not be appropriate for.

 Response : As discussed in response
to comment 1 above, the Registrant will include cover page disclosure including a discussion on the types of investors that an investment
in the Fund may be appropriate for and the types of investors that an investment in the Fund may not be appropriate for.

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 d. Clarify under "Limited Loss Risk" that the downside participation offset only provides a limited downside participation
offset. Until the floor is reached, investors are subject to all Underlying ETF losses.

 Response : The strategy of each
Fund does not establish an absolute floor on losses (and is not described as a "floor" in the Funds' prospectus), but
instead reduces downside exposure to the performance of the Underlying ETF by half. For example, if the share price of the Underlying
ETF declines by four percent over the Outcome Period, each Fund is only expected to experience a two percent decline in its net asset
value. To clarify the foregoing, the Registrant will revise the "Limited Loss Risk" sub-section of the "Principal Risks"
section of each Fund's prospectus to the following:

 Limited Loss Risk . The
Fund's strategy reduces downside exposure by half relative to the Underlying ETF. There is no guarantee that the Fund will
be successful in its strategy to limit the Fund's