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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 15, 2024

VIA EDGAR CORRESPONDENCE

Michael A. Rosenberg

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Re: WEBs ETF Trust

(Formerly Syntax ETF Trust)

File Nos. 333-215607; 811-23227

Dear Mr. Rosenberg:

This letter responds to your
comments regarding the registration statements filed on Form N-1A for WEBs ETF Trust, formerly Syntax ETF Trust (the “Trust”
or the “Registrant”) with the Securities and Exchange Commission (the “Commission”) on September
17, 2024 (the “Registration Statements”). The Registration Statements relate to WEBs Defined Volatility SPY ETF (“DVSP”)
and WEBs Defined Volatility QQQ ETF (“DVQQ”) (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 Registration
Statements. References to a “Fund” and to changes to be made to a Fund’s prospectus in Exhibit A shall be deemed to
refer to each Fund unless otherwise stated below.

Comment 1 – General

The staff of the Commission
(the “Staff”) reminds the Registrant and its management that they are responsible for the accuracy and adequacy of
the disclosures, notwithstanding any review, comments, action or absence of action by the Staff. Where a comment is made in one location,
it is applicable to all similar disclosures appearing elsewhere in the Registration Statements. Please ensure that corresponding changes
are made to all similar disclosure. Please provide responses to all of the Staff’s comments on EDGAR as soon as practicable and
at least five business days before the effective date of the Registration Statements.

Response to Comment 1

The Trust acknowledges the
Staff’s comment and confirms that corresponding changes made in response to the Staff’s comments have been made to any similar
disclosure throughout the Registration Statements. Further, the Registrant will provide the Staff with a response letter in the form of
correspondence at least five business days before effectiveness.

Comment 2 – General

Please
supplementally provide to the Staff background information on the Trust and the proposed investment adviser to the Funds, including a
link to the adviser’s website and Form ADV.

Response to Comment 2

Syntax
ETF Trust was organized as a Delaware statutory trust on June 27, 2013. On February 7, 2024, the Board of Trustees of Syntax ETF
Trust approved an Agreement and Plan of Reorganization providing for the reorganization of each of its existing series with and into
two newly created series of Exchange Listed Funds Trust, managed by Exchange Traded Concepts, LLC (the “ETC
Reorganization”). The ETC Reorganization was approved at special meetings of shareholders of the respective existing
series held on August 21, 2024, September 11, 2024 and September 18, 2024. Following the ETC Reorganization, no
series of the Trust remained outstanding prior to the establishment of the Funds. Effective on October 23, 2024, the Trust changed
its name from “Syntax ETF Trust” to “WEBs ETF Trust.” The proposed adviser to the Funds is WEBs Investments
Inc., www.websinv.com, an investment adviser registered with the SEC that is expected to serve as investment adviser and sponsor for
all future funds of the Trust. For more details on the investment adviser, please see its Form
ADV filed with the Commission.

Comment 3 – General

Please
supplementally provide the Staff the index methodology of Syntax Defined Volatility US Large Cap 500 Index and Syntax Defined Volatility
Triple Q’s Index (each, an “Index” and together, the “Indexes”) and the Indexes’ current
holdings.

Response to Comment 3

The
Registrant will supplementally provide the Staff with the whitepaper containing the index methodology of the Indexes.

Comment 4 – General

Please
explain how the term “Defined Volatility” does not render the Funds’ respective names misleading in violation of Section
35(d) (“Section 35(d)”) of the Investment Company Act of 1940, as amended.

Response to Comment 4

As
described in the revised prospectus attached as Exhibit A, the Index will vary its exposure to the Underlying ETF as it seeks to deliver
defined volatility percentages of 20% for DVSP and 22% for DVQQ. Because the Index, and therefore the Fund, seeks to track a set percentage
of volatility, the Registrant believes the term “Defined Volatility” is a true and accurate reflection of the Funds’
investment strategy under Section 35(d). The prospectus has been updated accordingly.

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Comment 5 – Fees and Expenses Table

Please disclose in a footnote
that the Fund’s management fee is a unitary management fee and that the investment adviser pays substantially all expenses of the
Fund, including certain expenses and excluding expenses for which the adviser is not responsible.

Response to Comment 5

The prospectus has been revised
in accordance with the Staff’s comment as set forth in Exhibit A.

Comment 6 – Principal Investment Strategies

Since
the Fund seeks to provide volatility adjusted returns of the respective Underlying ETF, please state, in the Fund’s Principal Investment
Strategies section, whether the returns of the Underlying ETF is based on that ETF’s net asset value or market price and whether
the returns reflect any dividends paid by the Underlying ETF.

Response to Comment 6

The prospectus has been revised
as set forth in Exhibit A to reflect that the Fund’s investment exposure to the Underlying ETF will reflect volatility adjusted
total returns.

Comment 7 – Principal Investment Strategies

Please
consider revising the Fund’s Principal Investment Strategies section to explain the Fund’s strategy in plain English. Please
consider moving excessive detail and complex disclosure to the section provided in response to Item 9 of Form N-1A.

Response to Comment 7

The prospectus has been revised
in accordance with the Staff’s comment as set forth in Exhibit A.

Comment 8 – Principal Investment Strategies

Please
disclose in this section in bold characters a statement to this effect: “There can be no assurance that the Fund will achieve its
investment objective and could incur substantial losses. The Fund’s returns will likely differ in amount, and possibly even direction,
from the returns of the Underlying ETF. These differences can be significant, the Fund could lose money regardless of the performance
of its Underlying ETF and as a result of portfolio rebalancing, fees, the Underlying ETF’s volatility, compounding and other factors,
the Fund is unlikely to match the performance of the Underlying ETF.”

Response to Comment 8

The prospectus has been revised
in accordance with the Staff’s comment as set forth in Exhibit A.

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Comment 9 – Principal Investment Strategies

Please
clarify in which securities the Fund will invest, particularly whether the Fund will invest in the securities that comprise the Underlying
ETF or in the Underlying ETF itself. To the extend the Fund invests in the Underlying ETF directly, please disclose to what extent it
will do so.

Response to Comment 9

The prospectus has been revised
in accordance with the Staff’s comment as set forth in Exhibit A.

Comment 10 – Principal Investment Strategies

Please
clarify that the Fund does not seek to track the Underlying ETF, and that exposure to the Underlying ETF will vary dynamically in the
Fund’s strategy, between 0-200%.

Response to Comment 10

The prospectus has been revised
in accordance with the Staff’s comment as set forth in Exhibit A.

Comment 11 – Principal Investment Strategies

Disclose
whether the Index creator and sponsor are affiliated with the Fund or its manager.

Response to Comment 11

The prospectus has been revised
in accordance with the Staff’s comment as set forth in Exhibit A.

Comment 12 – Principal Investment Strategies

Please
supplementally explain to the Staff how “volatility adjusted returns”, as referenced in the Fund’s strategy disclosure,
are different from risk adjusted returns.

Response to Comment 12

Risk
adjusted returns measure an investment’s returns while taking into account the amount of risk involved with such investment in comparison
to other investments (e.g. how much excess return an investor receives for the extra risk they take on by holding a riskier asset). Volatility
adjusted returns, in contrast, measures the magnitude of the returns generated by the Fund’s exposure to a single investment (i.e.
the Underlying ETF) which is adjusted up or down based on different levels of volatility.

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Comment 13 – Principal Investment Strategies

Please
define “long-term realized volatility”, including how it is measured.

Response to Comment 13

The prospectus has been revised
in accordance with the Staff’s comment as set forth in Exhibit A.

Comment 14 – Principal Investment Strategies

Please
supplementally explain to the Staff how a variable volatility level constitutes a defined level of volatility.

Response to Comment 14

The
Indexes, and therefore the Funds, seek to achieve a static, defined volatility target of 20% for DVSP and 22% for DVQQ, rather than variable
levels of volatility. The Fund has revised its prospectus as set forth in Exhibit A.

Comment 15 – Principal Investment Strategies

The
Staff notes that the Index appears to increase its exposure to the Underlying ETF when long term volatility is greater than short term
volatility. If this statement is accurate, please supplementally explain how this targets a “more stable volatility range”.
Please disclose how the Fund is defining a “more stable volatility range”.

Response to Comment 15

The
Funds seek to achieve a stable volatility target of 20% for DVSP and 22% for DVQQ, that is representative of the long-term volatility
of the respective Underlying ETF. When short-term volatility (calculated by taking the daily log returns of the past 21 days of trading
for each Underlying ETF and annualizing it) is below 20% and 22% respectively, each Index increases exposure to the Underlying ETF in
order to adjust the short-term volatility back up to 20% and 22%, respectively. When short-term volatility is above 20% and 22% respectively,
each Index decreases exposure to the Underlying ETF in order to adjust the short-term volatility back down to 20% and 22%, respectively.

The
prospectus has been revised accordingly in Exhibit A.

Comment 16 – Principal Investment Strategies

Please
disclose how the Index will determine the level of exposure it will target when the Ratio is more than 1 and what factors will impact
that determination. Please disclose the same when the Ratio is less than 1.

Response to Comment 16

The prospectus has been revised
in accordance with the Staff’s comment as set forth in Exhibit A.

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Comment
17 – Principal Investment Strategies

Please
explain what is a “hypothetical swap agreement”.

Response to Comment 17

The prospectus has been revised
to remove reference to “hypothetical” with respect to swap agreement as set forth in Exhibit A.

Comment
18 – Principal Investment Strategies

For
WEBs Defined Volatility QQQ ETF, please disclose that
while the Index and the Underlying ETF reflect companies across major industry groups, more than 50% of the holdings are in the information
technology sector.

Response to Comment 18

The prospectus has been revised
in accordance with the Staff’s comment as set forth in Exhibit A.

Comment
19 – Principal risks of Investing in the Fund

Please reorder the investment
risks in order of importance to provide investors a better understanding of the risks associated with the Fund.

Response to Comment 19

The Registrant respectfully
declines the Staff’s request to revise the Funds’ risk disclosure. Form N-1A and the relevant rules detail what is required
in a prospectus and how that information must be presented. No requirement contained in Form N-1A restricts a fund from ordering its principal
investment risks alphabetically, and the Funds’ current disclosure is consistent with the requirements of Form N-1A. Further, the
Registrant believes that ordering the risks alphabetically makes it easier for investors to find applicable risk factors.

Comment
20 – Principal risks of Investing in the Fund

Please include a discussion
of the specific risks associated with the Underlying ETF.

Response to Comment 20

The prospectus has been revised
in accordance with the Staff’s comment as set forth in Exhibit A.

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Comment
21 – Principal risks of Investing in the Fund

Please include disclosure
that in stressed market conditions, the market for the Fund’s shares may become less liquid in response to deteriorating liquidity
in the markets for the Fund’s underlying portfolio holdings. Please also note that this adverse effect on liquidity in turn could
lead to wider bid-ask spreads and differences between the market price of the Fund and the underlying value of those shares.

Response to Comment 21

The prospectus has been revised
in accordance with the Staff’s comment as set forth in Exhibit A.

Comment
22 – Principal risks of Investing in the Fund

At the end of Authorized Participant
Concentration Risk, please consider adding language to this effect: “This may also result in significantly diminished trading market
for the Fund’s shares.”

Response to Comment 22

The prospectus has been revised
in accordance with the Staff’s comment as set forth in Exhibit A.

Comment
23 – Principal risks of Investing in the Fund

Under Debt Securities Risk,
please disclose that investments in debt securities rated BBB or BAA may have speculative characteristics.

Response to Comment 23

The prospectus has been revised
in accordance with the Staff’s comment as set forth in Exhibit A.

Comment
24 – Principal risks of Investing in the Fund

Under Over-the-Counter Market
Risk, please remove reference to “securities” if the Fund will not invest in over-the counter securities other than swaps.

Response to Comment 24

The prospectus has been revised
in accordance with the Staff’s comment as set forth in Exhibit A.

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Comment
25 – Principal risks of Investing in the Fund

With respect to the Passive
Strategy/Index Risk, please supplementally explain to the Staff how the Index is an unmanaged index.

Response to Comment 25

The
prospectus has been revised to remove references to “unmanaged” with respect to the Index as set forth in Exhibit A.

Comment
26 – Principal risks of Investing in the Fund

Under Rebalancing Risk, please
disclose, if applicable, any risk specific to daily rebalancing.

Response to Comment 26

The prospectus has been revised
in accordance with the Staff’s comment as set forth in Exhibit A.

Comment
27 – Principal risks of Investing in the Fund

Please supplementally provide
to the Staff information on whether the Funds will be using a relative or an absolute value-at-risk (VaR) test to measure derivatives
risk.

Response to Comment 27

Each Fund will use a relative
VaR test to measure derivatives risk in accordance with Rule 18f-4 of the Investment Company Act of 1940, as amended.

Comment
28 – performance

Please supplementally disclose
to the Staff which broad-based security index each Fund intends to use. Please see Item 4 of Form N-1A.

Response
to Comment 28

Each Fund intends to use the
S&P 500® Index as its broad-based security index.

Comment 29 – Additional Information
About the Fund’s Principal Investment Strategies

Please
state that while the Fund is not subject to an upside cap, the Fund’s returns will generally not match those of the Underlying ETF.

Response to Comment 29

The prospectus has been revised
in accordance with the Staff’s comment as set forth in Exhibit A.

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Comment 30 – Statement of Additional In