SecProbe.io

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    Eversheds Sutherland
        (US) LLP

        700 Sixth Street, NW,
        Suite 700

        Washington, DC 20001-3980

        D: +1 202.383.0472

        F: +1 202.637.3593

        cynthiabeyea@

        eversheds-sutherland.com

December 12, 2022

Jay Williamson, Esq.

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, DC 20549

 Re: Post-Effective No. 141 to the Registration Statement of USCF ETF Trust;

File Nos. 333-196273 and 811-22930

Dear Mr. Williamson:

On behalf of the USCF ETF Trust (the “Trust”), attached for
filing with the Securities and Exchange Commission is Post-Effective Amendment No. 141 to the Trust’s Registration Statement on
Form N-1A (the “Amendment”).  The Amendment is being filed pursuant to paragraph (a)(1) of Rule 485 under the Securities
Act of 1933, as amended, for the purpose of amending and updating the prospectus and statement of additional information (“SAI”)
for the USCF Energy Commodity Strategy Absolute Return Fund (the “Fund”).

The initial
filing for the Fund was made on January 9, 2020 in Post-Effective Amendment No. 73.  On each of February 24, 2020, June 1, 2020,
and June 11, 2020, SEC Staff reviewer, Ray Be, provided oral comments on Amendment No. 73 on behalf of the SEC staff (the “Staff”)
to me during a telephone call.  In email correspondence with Mr. Be in early February, 2021, I informed the Staff that the Trust
intended to file an additional amendment under paragraph (a)(2) of Rule 485 in order to incorporate the Staff’s comments into the
filing.  On February 5, 2021, Post-Effective Amendment No. 101 was filed to update the prospectus and SAI for the Fund.  Additionally,
correspondence was filed to respond to the previously issued Staff comments.  During the period from the initial filing until Post-Effective
Amendment No. 101, the Trust timely filed delaying amendments to delay the effectiveness of the registration statement for the Fund.

As I discussed during an August 31, 2022 telephone call with you and as
noted in correspondence filed by the Trust on June 24, 2021, due to an administrative error that led to a failure to file a delaying amendment,
Post-Effective Amendment No. 101 inadvertently went effective on June 18, 2021, which was before such time as the Trust intended to begin
offering the Fund. In the correspondence filed on June 24, 2021, the Trust represented that, prior to offering any shares of the Fund,
it would file an amended registration statement relating to the Fund pursuant to Rule 485 of the Securities Act. The Trust is now
filing this Post-Effective Amendment No. 141 in preparation for the launch of the Fund.

On March 24, 2021, via telephone, SEC Staff reviewer, Elena Stojic, provided
comments to me regarding Post-Effective Amendment No. 101. Correspondence containing those comments and the Trust’s response to
those comments has not yet been filed. Thus, those comments and the Trust’s response to those comments, are included immediately
below.

 1. It is stated on page 1 of the prospectus under the heading “Investment
Objective” that the Fund “seeks long-term total return,” but elsewhere stated on pages 2, 10, and 11 of the prospectus
that the fund “seeks total return.” Please conform these statements of the Fund’s investment objective to be identical.

    Eversheds Sutherland (US) LLP
    is part of a global legal practice, operating through various separate and distinct legal entities, under Eversheds Sutherland.
    For a full description of the structure and a list of offices, please visit www.eversheds-sutherland.com.

    Jay Williamson, Esq.

        December 12, 2022

        Page 2

   Response: The Trust has conformed
                                            each of these statements of the Fund’s investment objective to be identical and to
                                            provide that the Fund “seeks long-term total return.”

 2. In connection with the Energy Sector Risk Factor on page 13 of the prospectus,
the Fund makes a statement that it concentrates in the energy sector. If the Fund does, in fact, concentrate in an industry or group
of industries, please makes sure that any concentration policy is discussed in Item 4 and Item 9 of the Prospectus. Please also ensure
that any policy on concentration is with respect to an industry rather than a sector.

   Response: The Fund does not
                                            intend to concentrate its investments in any one industry or group of industries. The Fund
                                            has revised the risk factor in question to reference “investing” in the energy
                                            sector rather than “concentrating” in the energy sector. The Fund has also revised
                                            its fundamental policy regarding concentration to state:

        The Fund may not purchase any security if, as a result of that purchase,
25% or more of its total assets would be invested in securities of issuers having their principal business activities in the same industry,
provided that this restriction does not limit the Fund’s investments in (i) securities or other instruments issued or guaranteed
by the U.S. government or its agencies or instrumentalities, and (ii) securities of other investment companies

*        *        *

A redline showing the differences between Post-Effective Amendment No.
101 and Post-Effective No. 141 has been attached hereto for your convenience. If you have any questions or concerns about the information
or responses set forth above, please call the undersigned at (202) 383-0472.

    Sincerely,

    /s/ Cynthia R. Beyea

    Cynthia R. Beyea

    cc:
    Daphne G. Frydman, USCF

        Krisztina Nadasdy, Eversheds
        Sutherland