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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

December 2, 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
additional 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 – Principal Investment Strategies

Please
clarify whether the returns of the Underlying ETF are based on that fund’s net asset value or market price and whether the returns
reflect any dividends paid by the Underlying ETF.

Response to Comment 2

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

Comment 3 – Principal Investment Strategies

Please
clarify the basis and significance of each Fund’s targeted annual volatility rate (the “Defined Volatility Rate”) of
20% and 22%, respectively.

Response to Comment 3

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

Comment 4 – Principal Investment Strategies

Please
supplementally explain to the Staff the circumstances under which the Defined Volatility Rate might change.

Response to Comment 4

The Defined Volatility Rate
provided by the Index is a static percentage and Fund does not currently expect that the Defined Volatility Rate to change. In the event
the Index adjusts the Define Volatility Rate in the future, the Fund would provide shareholders with notification of any such Index change
via a supplement to the Registration Statement.

    - 2 -

Comment 5 – Principal Investment Strategies

Please
state that there is no assurance that the Index and the Fund will successfully maintain the Defined Volatility Rate.

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

Please
consider disclosing, if accurate, that the Fund will increase exposure to the Underlying ETF to the extent short term volatility is lower
than the Defined Volatility Rate and that the Fund conversely will decrease exposure to the Underlying ETF to the extent short term volatility
is higher than the Defined Volatility Rate.

Response to Comment 6

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

Comment
7 – Principal risks of Investing in the Fund

Please
clarify that the defined volatility strategy employed by the Fund may reduce exposure to the Underlying ETF when short-term volatility
is relatively high and Underlying ETF returns are in a negative trend, which could result in the strategy not participating in positive
returns when markets switch from a negative trend to a positive trend and conversely, the Fund may increase exposure to the Underlying
ETF when short-term volatility is relatively low and market returns are in a positive trend, which could result in increased negative
returns when markets switch from a positive trend to a negative trend.

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 risks of Investing in the Fund

Please disclose as a risk
the fact that the investment adviser is newly registered with the SEC and, as an entity, has no experience advising a registered investment
company.

Response to Comment 8

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

    - 3 -

Comment
9 – Principal risks of Investing in the Fund

Under “Leveraged Volatility
Risk”, please revise the third sentence as follows: “The Fund tracks an Index that seeks to remain at a target realized volatility
and therefore the Fund may leverage its exposure to the Underlying ETF, which can result in greater exposure to the volatility of the
Underlying ETF.”

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 risks of Investing in the Fund

Under “Tax Risk”,
please supplementally explain to the Staff whether the Fund’s strategy presents any tax risks that are unique to this type of fund.

Response to Comment 10

The Fund believes that all
material tax disclosures are set forth in the Registration Statement.

*  *  *  *  *  *  *  *

Please call me at (312) 845-3484
if you have any questions or issues you would like to discuss regarding these matters.

    Sincerely yours,

    Chapman and Cutler llp

    By:
     /s/ Morrison C. Warren

    Morrison C. Warren

    - 4 -

Exhibit A

The information in this Prospectus is not complete
and may be changed. We may not sell these securities until the registration statement filed with the Securities and Exchange Commission
is effective. This Prospectus is not an offer to sell these securities and it is not soliciting an offer to buy these securities in any
state where the offer of sale is not permitted.

Subject to Completion

December [5], 2024

PROSPECTUS

WEBs ETF Trust

(formerly, Syntax ETF Trust)

WEBs Defined Volatility QQQ ETF

(DVQQ)

________, 2024

Principal U.S. Listing Exchange: Nasdaq, Inc.

WEBs Defined Volatility QQQ ETF (the “Fund”)
is an exchange-traded fund (“ETF”). This means that shares of the Fund (“Shares”) are listed on Nasdaq, Inc.,
its Principal U.S. Listing Exchange (the “Exchange”), a national securities exchange, and trade at market prices. The market
price for the Shares may be different from the Fund’s net asset value per share (the “NAV”).

The Securities and Exchange Commission (“SEC”)
has not approved or disapproved these securities or passed upon the accuracy or adequacy of this Prospectus. Any representation to the
contrary is a criminal offense. The Shares are not guaranteed or insured by the Federal Deposit Insurance Corporation or any other agency
of the U.S. Government, nor are Shares deposits or obligations of any bank. It is possible to lose money by investing in the Fund.

Table of Contents

    WEBs DEFINED VOLATILITY QQQ ETF
    3

    ADDITIONAL INFORMATION ABOUT THE FUND’S PRINCIPAL INVESTMENT STRATEGIES
    14

    ADDITIONAL RISK INFORMATION
    17

    MANAGEMENT
    24

    INDEX/TRADEMARK LICENSES AND DISCLAIMER
    27

    ADDITIONAL PURCHASE AND SALE INFORMATION
    28

    DISTRIBUTIONS
    30

    PORTFOLIO HOLDINGS DISCLOSURE
    30

    U.S. FEDERAL INCOME TAXATION
    31

    GENERAL INFORMATION
    34

    PREMIUM/DISCOUNT INFORMATION
    34

    CODE OF ETHICS
    34

    DISTRIBUTION PLAN
    35

    OTHER INFORMATION
    35

    FINANCIAL HIGHLIGHTS
    35

    WHERE TO LEARN MORE ABOUT THE FUND
    36

    2

WEBs DEFINED VOLATILITY QQQ ETF

OBJECTIVE

The Fund seeks to provide investment results that,
before fees and expenses, correspond to the performance of the Syntax Defined Volatility Triple Q’s Index (the “Index”).

FEES AND EXPENSES OF THE FUND

This table describes the fees and expenses that
you may pay if you buy, hold and sell shares of the Fund (“Fund Shares”). You may pay other fees, such as brokerage commissions
and other fees to financial intermediaries, which are not reflected in this table and the Example below.

Annual Fund Operating Expenses

(Expenses that you pay each year as a percentage of the value of
your investment):

    Management Fees1
    0.85%

    Distribution and Service (12b-1) Fees
    0.00%

    Other Expenses2
    0.00%

    Acquired Fund Fees and Expenses3
    0.11%

    Total Annual Fund Operating Expenses
    0.96%

 (1)  Unitary management fee under which the investment adviser pays substantially all expenses of the Fund
(including the cost of transfer agency, custody, fund administration, legal, audit and other service and license fees), excluding distribution
and service fees payable pursuant to a Rule 12b-1 plan, if any, brokerage commissions and other expenses connected with the
execution of portfolio transactions, taxes, interest, and extraordinary expenses.

 (2)  “Other Expenses” are estimates based on the expenses the Fund expects to incur for the current
fiscal year.

 (3)  “Acquired Fund Fees and Expenses” are based on estimated amounts for the current fiscal year.

Example:

This Example is intended to help you compare the
cost of investing in the Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the Fund for the
time periods indicated, and then sell all of your Fund Shares at the end of those periods. The Example also assumes that your investment
has a 5% return each year and that the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower,
based on these assumptions your costs would be:

    1 Year
    3 Years

    $98
    $306

PORTFOLIO TURNOVER

The Fund pays transaction costs, such as commissions,
when it buys and sells securities (or “turns over” its portfolio). A higher portfolio turnover rate may indicate higher transaction
costs and may result in higher taxes when Fund Shares are held in a taxable account. These costs, which are not reflected in Total Annual
Fund Operating Expenses or in the Example, affect the Fund’s performance. Because the Fund has not yet commenced operations, portfolio
turnover information is unavailable at this time.

    3

PRINCIPAL INVESTMENT STRATEGIES

The Fund is a passively managed ETF listed for
trading on the Exchange. The Fund implements its investment objective by investing, under normal market conditions, at least 80% of its
net assets (including borrowings for investment purposes) in financial instruments that achieve the investment results of the Index.

Syntax Defined Volatility Triple Q’s
Index. The Index is a rules-based strategy that seeks to track the
performance of the Invesco QQQ TrustSM , Series 1 (“QQQ” or the “Underlying ETF”), with investment exposure
to the Underlying ETF adjusted for a targeted annual volatility rate of 22% (a representation of the annual long-term volatility rate
of the Underlying ETF) (the “Defined Volatility Rate”). The Index was created by Syntax LLC (“Syntax” or the “Index
Provider”).

Volatility is a statistical measurement of the
magnitude of asset price fluctuations (increases or decreases in an asset’s price) over time. In general, an investment with high
levels of volatility will subject an investor to more significant variances in gains and losses than the investment with lower volatility
over the same period. Realized volatility is the historically observed movement of the price of an asset over a given period. The Index
dynamically allocates exposure to the Underlying ETF by comparing the Underlying ETF’s 21-day realized volatility (short-term volatility)
to the Defined Volatility Rate. The Fund, in seeking to track the Index, will increase exposure to the Underlying ETF to the extent short-term
volatility is lower than the Defined Volatility Rate and, conversely, will decrease exposure to the Underlying ETF to the extent short-term
volatility is higher than the Defined Volatility Rate. On each day of trading of the Underlying ETF, the Index calculates the short-term
volatility of the Underlying ETF by measuring the daily volatility returns of the past 21 days of trading for the Underlying ETF and

 · when the measured Underlying ETF short-term volatility is below the Defined Volatility Rate, the Index
increases exposure to the Underlying ETF in order to adjust the Underlying ETF short-term volatility up to the Defined Volatility Rate;

 · when the measured Underlying ETF short-term volatility is above the Defined Volatility Rate, the Index
decreases exposure to the Underlying ETF in order to adjust the Underlying ETF short-term volatility down to the Defined Volatility Rate.

As further described below, the Index seeks to
implement this strategy by primarily allocating to shares of the Underlying ETF and alternately allocating to either a total return swap
on the Underlying ETF, as a way of applying leverage to the Underlying ETF and thereby increasing volatility to the Defined Volatility
Rate, or a cash position as a way of reducing volatility to the Defined Volatility Rate. The Fund does not seek to track the investment
performance of the Underlying ETF, and exposure to the Underlying ETF will vary dynamically in the Fund’s strategy, between 0-200%.
See “Additional Information About the Fund’s Principal Investment Strategies” for a discussion of the Index.

There is no assurance that the Index or the
Fund will successfully maintain the Defined Volatility Rate in accordance with its investment objective. 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 and the Underlying ETF may incur substantial losses. 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.

    4

The Index seeks to provide investment exposure
to the “total returns” of the Underlying ETF. The total returns of the Underling ETF are based upon the Underlying ETF’s
market price and include capital gains, dividends and distributions paid by the Underlying ETF. The Underlying ETF is a unit investment
trust that seeks to track the investment results, before fees and expenses, of the NASDAQ-100 Index, which includes 100 of the largest
domestic and international non-financial companies listed on the Nasdaq Stock Market based on market capitalization. While Index and the
Underlying ETF reflect companies across major industry groups, more than 50% of the holdings are in the information technology sector.
The Underlying ETF does not contain securities of financial companies, including investment companies.

Swap agreements are contracts entered into primarily
with major financial institutions for a spe