SecProbe.io

CORRESP
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November 22, 2022

Rebecca Ament Marquigny

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Melissa McDonough

U.S. Securities and Exchange Commission

Staff Accountant, Division of Investment Management

U.S. Securities and Exchange Commission

33 Arch Street

Boston, MA 02110

 Re: EA Series Trust (the “Trust”)

Registration Statement on Form N-14
(the “Registration Statement”)

File No.: 333-265923

Dear Ms. Marquigny and Ms. McDonough:

This correspondence responds to the legal and
accounting comments received by the undersigned from the staff of the U.S. Securities and Exchange Commission (the “Staff”
of the “Commission”) on November 1, 2022 and November 9, 2022, respectively with respect to the Registration Statement
on Form N-14 under the Securities Act of 1933 to register shares of beneficial interest (“Shares”) in the EA Bridgeway Omni
Small-Cap Value ETF (the “Fund” or the “Acquiring Fund”), a series of the Trust, to be issued in connection with
the reorganization of the Omni Tax-Managed Small-Cap Value Fund (the “Target Fund”), a series of Bridgeway Funds, Inc. with
and into the Acquiring Fund. Capitalized terms not otherwise defined have the same meaning as in the Registration Statement.

Legal Comments

 1. Comment: In the Notice of Special Meeting of Shareholders, in the third paragraph from the end
of the notice, please disclose a date for which a proxy must be received or postmarked to be valid and counted at the meeting.

Response: The
Registrant has added the following disclosure has been added to the end of the third to last paragraph:

Your
proxy card must be received prior to the Meeting for your vote to be counted.

 2. Comment: In the Notice of Special Meeting of Shareholders, please confirm that the Registrant has
reviewed state law on how the meeting can be switched to a virtual setting and disclose the applicable notice requirements.

Response: The
Registrant has confirmed that a virtual shareholder meeting is permitted under Section 1 of the Target Fund’s By-Laws and Section
2-503 of the Maryland Corporation Law. The Registrant submits that no additional notice is required for a virtual shareholder meeting
except as provided in the regular notice of the shareholder meeting.

KAREN
A. ASPINALL ● PARTNER

11300
Tomahawk Creek Pkwy, Suite 310 ● Leawood, KS 66211 ●
p: 949.629.3928

Practus,
LLP ● Karen.Aspinall@Practus.com ● Practus.com

 3. Comment: In the last sentence in bold in the Notice of Special Meeting of Shareholders, who can
shareholders call to determine if they are eligible?

Response: The
Registrant has deleted the phrase “if eligible” from the last sentence.

 4. Comment: On page 1 and throughout the document, please delete any references to shareholders “disapproving”
of the reorganization.

Response: The
Registrant has made the requested change.

 5. Comment: In the third paragraph from the bottom of page 1, please state in bold that shareholders
won’t be able to redeem at NAV if the transaction is approved and the shareholder receives shares of the Acquiring Fund. Also, please
include a cross reference to the prospectus language that trading costs may involve brokerage fees post-reorganization.

Response: The
Registrant notes that this information is provided in the last paragraph on page 1 and has bolded the information as requested. The Registrant
has also added a cross-reference to the discussion of brokerage costs on page 2.

 6. Comment: If Target Fund shareholders vote to approve the Reorganization please make clear in the
same paragraph that the Acquiring Fund will be an ETF and the implications, including the market on which shares will trade, approximate
date after which they won’t be able to redeem Target Fund shares at NAV.

Response: The
Registrant has made the requested change.

 7. Comment: Please update the prospectus dates in bullet two on page ii.

Response: The
Registrant will make the requested change.

 8. Comment: The bold statement at the bottom of page ii should be located on the outside cover page
of the prospectus.

Response: The
Registrant respectfully declines to move the location of this disclosure as the Registrant views its current location to be within the
outside cover page of the Prospectus.

 9. Comment: In the Summary section, the section entitled “Are there any differences in risks
between the Target Fund and the Acquiring Fund?” should be located immediately after the synopsis.

Response: The
Registrant has made the requested change.

 10. Comment: In the section “What am I being asked to vote upon?” please move up
the text describing the proposals to the beginning of the section.

Response: The
Registrant has made the requested change.

 11. Comment: In the section “How will the Reorganization affect me?” and in all places
it appears in the document please delete the definition (“NTF”).

Response: The
Registrant has made the requested change.

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 12. Comment: On page 2, in the section “Will the Reorganization affect the way my investments
are managed?” please describe Bridgeway’s role as a sub-adviser to the new fund and please explain continuity of management.

Response: The
Registrant has added the following two sentences to the second-to-last paragraph:

Bridgeway will
serve as the Acquiring Fund’s sub-adviser and will be responsible for the selection of the Acquiring Fund’s investments. This
structure maintains continuity in the management of the Target Fund’s assets if the Reorganization is approved.

 13. Comment: If the Target Fund’s primary adviser is changing under the Acquiring Fund structure,
please discuss the implications.

Response: The
following changes have been made following the third sentence of the second paragraph on page 2:

If the Reorganization
is approved, Bridgeway will serve as the Acquiring Fund’s sub-adviser and will be responsible for the selection of the Acquiring
Fund’s investments. EA Advisers, will serve as the Acquiring Fund’s investment adviser, and will provide trading,
execution and various other administrative services and supervises the overall daily affairs of the Acquiring Fund. This is a change
from how the Target Fund is structured where Bridgeway is the sole investment adviser to the Target Fund. It is not anticipated that this
change will have a material effect on how the Target Fund is currently managed. Moreover, the Acquiring Fund’s management structure
maintains continuity in the investment selection process of the Target Fund’s assets if the Reorganization is consummated.

 14. Comment: On page 2, under the section “Are there any differences in risks between the
Target Fund and the Acquiring Fund?” please focus the answer on the transaction and implications to investors. Please highlight
important differences in risks and where risks are not changing, please eliminate unnecessary detail.

Response: The
Registrant has deleted Investment Risk, Equity Investing Risk, Geopolitical/Natural Disaster Risks and Fund Cybersecurity Risk, which
are risk factors that are common to both Funds, so as to better highlight the ETF-related risks and the other risks that are different
between the two Funds.

 15. Comment: On page 3, under the section “How do the fees and expenses of the Acquiring Fund
compare to the fees and expenses of the Target Fund?” please provide more detail and clarity on the impact of the fee waiver
arrangements. Currently the disclosure doesn’t compare the outcome in a way that is useful to investors.

Response: The
first two paragraphs of this section have been revised as follows:

Following the Reorganization,
as set forth in the table below, the Total Annual Fund Operating Expenses for the Acquiring Fund are expected to be lower than the Total
Annual Fund Operating Expenses (both before and after the contractual fee waiver and/or expense reimbursement) of the Target Fund. In
addition, the Acquiring Fund will be subject to a unitary fee structure, which will require the Acquiring Fund’s investment manager,
EA Advisers, to pay the Acquiring Fund’s ordinary operating expenses without any increase in the management fee, typically resulting
in lower fees and expenses to shareholders.

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As shown in the
table below, the Total Annual Fund Operating Expenses of the Acquiring Fund are lower than those of the Target Fund on a gross basis and
also on a net basis when giving effect to Bridgeway’s contractual expense limitation agreement. In addition, effective January 1,
2020, Bridgeway voluntarily agreed to waive fees and/or pay Target Fund expenses in an additional amount such that the net fiscal year
expense ratio for the Target Fund (management fees and other expenses less the contractual expense waiver and voluntary waiver) does not
exceed 0.47%. Total expenses are the expenses accrued daily by the accounting agent and exclude trading costs (e.g., commissions and other
trading costs), as well as Acquired Fund Fees and Expenses. This voluntary expense cap may be changed or eliminated at any time by Bridgeway.
When giving effect to the Bridgeway voluntary fee waiver, the Total Annual Fund Operating Expenses of the Acquiring Fund (0.47%) are equal
to the Target Fund’s current voluntary expense limitation of 0.47% (the voluntary expense limitation is not reflected in the table
below). As a result, the Total Annual Fund Operating Expenses of the Acquiring Fund are expected to be the same as those of the Target
Fund when taking the voluntary fee waiver into account. Bridgeway’s contractual and voluntary expense waivers exclude Acquired Fund
Fees and Expenses, if any.

 16. Comment: Do the waivers have the same parties, periods, and excluded expenses? What are the primary
differences?

Response: Bridgeway’s
existing contractual expense limitation agreement for the Target Fund is included within the Target Fund’s investment advisory agreement
and therefore remains in effect in perpetuity unless a change is approved by the Board of Directors of Bridgeway Funds, Inc. and Target
Fund shareholders. As the other expense waiver provided by Bridgeway is voluntary it may be terminated at any time by Bridgeway. The Acquiring
Fund will not have an expense limitation agreement and has a unitary fee structure. The voluntary and contractual expense limits provided
by Bridgeway both exclude Acquired Fund Fees and Expenses. Please see response 15 for the updated disclosure.

 17. Comment: Please eliminate the term “contractual” when referring to the voluntary fee
waiver provided by Bridgeway.

Response: The
Registrant has made the requested change.

 18. Comment: On page 4, with respect to the Pro Forma fee table, please note that certain costs, such
as brokerage commissions, bid ask spreads and taxes may still impact investors when invested in the Acquired Fund.

Response: The
following disclosure has been added prior to the Annual Operating Expense Table:

The following table
shows the fees and expenses for the Target Fund and the Acquiring Fund. As the Acquiring Fund has not yet commenced operations as of the
date of this Proxy Statement/Prospectus, the Other Expenses shown for the Acquiring Fund are estimated. You will not pay any sales load,
CDSC, brokerage commission, redemption fee, or other transaction fee in connection with the receipt of Acquiring Fund Shares in the Reorganization.
Shareholders pay annual fund operating expenses indirectly because they are deducted from a Fund’s assets. The fees and expenses
reflected below do not include the brokerage commissions, other fees to financial intermediaries and taxes that investors may pay on their
purchases and sales of shares of the Acquiring Fund after the completion of the Reorganization.

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 19. Comment: In footnote 1, please describe recoupment of expenses by the Acquiring Fund adviser.

Response: The
reference to footnote 1 has been moved to be aligned with the Target Fund fee waiver number. Recoupment of advisory fee waivers of the
Target Fund by the Acquiring Fund adviser is addressed in the section “What are the Funds’ investment management fee rates?”
where the second to last sentence in the last paragraph of the section has been revised as follows:

The management fees
waived by Bridgeway for the Target Fund are not subject to recoupment by Bridgeway from the Acquiring Fund.

 20. Comment: On page 5, under the section “What are some features of ETFs that differ from
mutual funds?” please restate the question as “How do ETFs Differ from Mutual Funds” and confirm that the unique
features is a complete list of material features for investors to consider.

Response: The
Registrant has made the requested changes and amended the applicable disclosure as follows:

The following are the
material features of ETFs as compared to mutual funds:

 21. Comment: In the same section, under the sub-heading “Transparency,” please state for
comparison how often the Target Fund discloses its portfolio holdings.

Response: The
following sentence has been added to the end of this section:

A description
of the Bridgeway Funds policies and procedures with respect to the disclosure of the Target Fund’s portfolio holdings is available
in the Target Fund’s SAI, which is incorporated into this Proxy Statement/Prospectus by reference.

 22. Comment: In the same section, under the sub-heading “Tax Efficiency,” please disclose
that some investors may hold mutual fund shares in a tax deferred accounts and may thereby defer taxable gains.

Response: The
Registrant respectfully declines to make this change as the language of this section already notes that the tax efficiency applies with
regard to taxable shareholder accounts, however the Registrant has clarified in this section that the tax consequences relate to taxable
shareholders. Further, shareholders who hold shares in tax deferred accounts will still pay tax, just at a later date, whereby ETFs structurally
seek to avoid taxable distributions by the use of in-kind creations and redemptions.

 23. Comment: In the same section, under the sub-heading “Sales only through a Broker,”
please revise the fifth sentence to emphasize that brokerage charges will impact long term earnings on fund shares.

Response: The
Registrant has made the requested change.

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 24. Comment: On page 6, under the section “What are the federal income tax consequences of
the Reorganization?” please directly state that the Registrant anticipates the tax opinion will be consistent with the view
that the reorganization will not result in recognition of gain or loss by the Target Fund or its shareholders.

Response: The
following has been added as the second sentence of the second paragraph:

The tax opinion
is expected to provide that the Reorganization will not result in the recognition of a taxable gain or loss to Target Fund shareholders.

 25. Comment: On page 6, under the section “How do the purchase procedures of the Funds compare?”
with respect to the subsection “Rule 12b-1 Fees” please directly compare the use of 12b-1 plans between the Target
Fund and the Acquiring Fund.

Response: The
following disclosure has been added to the end of this section:

Therefore, neither
shareholders of the Target Fund nor shareholders of the Acquiring Fund pay Rule 12b-1 fees, however shareholders of the Acquiring Fund
could pay up to 0.25% in Rule 12b-1 fees in the future, although this is not currently anticipated.

 26. Comment: On page 7, under the section “What will happen if I don’t have a Brokerage
Account that can accept ETF shares at the time of the Reorganization?” please present the last two sentences more prominently,
such as by using bold text.

Response: The
Registrant has made the requested change.

 27. Comment: On page 7, under the section “What if the Reorganization is approved by shareholders
and I don’t want to hold ETF shares?” please consider whether the Target Fund is held through variable products in which
investors could receive the same benefits. I