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    1900 K Street, NW

    Washington, DC 20006-1110

    +1  202  261  3300  Main

    +1  202  261  3333  Fax

    www.dechert.com

    CYNTHIA R. BEYEA

    Cynthia.Beyea@dechert.com

    +1 202 261 3447 Direct

October
10, 2024

U.S. Securities and Exchange Commission

Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Seamus J. O’Brien

Re: USCF
ETF Trust; File Nos.: 333-196273, 811-22930

Dear Mr. O’Brien:

On
August 16, 2024, USCF ETF Trust (the “Trust” or the “Registrant”) filed Post-Effective Amendment No. 185 to its
registration statement on Form N-1A (the “Amendment”) with the Securities and Exchange Commission (the “SEC”)
to reflect changes to the investment objective and principal investment strategies of the USCF SummerHaven Dynamic Commodity Strategy
No K-1 Fund (the “Fund”), a current series of the Trust. This letter responds to comments from the staff of the SEC (the
“Staff”) that you conveyed to Vince Nguyen and Mimi McCann telephonically on October 1, 2024. The Trust has considered your
comments and has authorized us to make the responses and changes discussed below on its behalf.

Please
find below a reiteration of your comments and the Trust’s responses. Terms not defined herein have the meanings ascribed to them
in the Fund’s prospectus and statement of additional information (“SAI”). References to prospectus page numbers refer
to the prospectus or SAI contained in the Amendment.

GENERAL

 1. Comment:
                                            Where a comment is made with regard to disclosure in one location, it is applicable to all
                                            similar disclosure appearing elsewhere in the registration statement.

Response:
We respectfully acknowledge the comment.

 2. Comment:
                                            We note that portions of the registration statement are incomplete. Please fill in all bracketed
                                            language and any placeholders and refresh all tables of contents prior to effectiveness.

Response:
We respectfully acknowledges the comment.

PROSPECTUS

Fee
Table

 3. Comment:
                                            Please provide the Staff with a completed fee table as part of your response.

Response:
The completed fee table is set forth below.

Annual Fund Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

    Management Fees(1)
      0.80 %

    Other Expenses of the Fund
      0.00 %

    Acquired Fund Fees and Expenses(2)
      0.00 %

    Total Annual Fund Operating Expenses
      0.00 %

    Fee Waivers(3)
      (0.20 )%

    Total Annual Fund Operating Expenses After Fee Waivers
      0.60 %

 (1) The
                                            Fund pays USCF Advisers LLC (the “Adviser”) an annual unitary management fee
                                            based upon the Fund’s average daily net assets at the rate set forth above. The Adviser
                                            is responsible for all direct expenses of the Fund, including the costs of investing in the
                                            Subsidiary (as defined below), except expenses for taxes and governmental fees; brokerage
                                            fees; commissions and other transaction expenses; costs of borrowing money, including interest
                                            expenses; securities lending expenses; extraordinary expenses (such as litigation and indemnification
                                            expenses); and fees and expenses of any independent legal counsel.

 (2) Acquired
                                            Fund Fees and Expenses are the indirect costs of investing in other investment companies.
                                            The operating expenses in this fee table will not correlate to the expense ratio in the Fund’s
                                            financial highlights because the financial statements include only the direct operating expenses
                                            incurred by the Fund.

 (3) The
                                            Adviser has contractually agreed through October 31, 2025 to waive 0.20% of its management
                                            fees. The agreement may be amended or terminated prior to October 31, 2025 only by agreement
                                            of the Board of Trustees (the “Board”) of USCF ETF Trust (the “Trust”)
                                            and the Adviser, and will terminate automatically if the investment advisory agreement between
                                            the Adviser and the Fund is terminated. After October 31, 2025, the Adviser, in its sole
                                            discretion, may choose to renew or amend the agreement, subject to approval by the Board.
                                            Amounts waived are not subject to recoupment by the Adviser.

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Expense
Example

 4. Comment:
                                            Please provide the Staff with a completed expense example as part of your response.

Response:
The completed expense example is set forth below.

Example

The following
example is intended to help investors compare the cost of investing in the Fund with the cost of investing in other funds. It illustrates
the hypothetical expenses that investors would incur over various periods if they were to invest $10,000 in the Fund for the time periods
indicated and then sell all of the shares at the end of those periods. This example assumes that the Fund provides a return of 5% per
year and that operating expenses remain the same except that it assumes the fee waiver is only in place for the one-year period. This
example does not include the brokerage commissions that investors may pay to buy and sell shares of the Fund. Although your actual costs
may be higher or lower, based on these assumptions, your costs would be:

    1
    Year
    3
    Years
    5
    Years
    10
    Years

    $61
    $235
    $425
    $971

Principal
Investment Strategies of the Fund

 5. Comment:
                                            With respect to the disclosures stating that “[i]n seeking to track the SDCITR, the
                                            Fund invests in a fully margined and collateralized portfolio of commodities futures contracts
                                            that will generally consist of the Component Futures Contracts, weighted equally by notional
                                            amount” and “[t]he Fund may also invest in futures contracts that the portfolio
                                            manager believe are economically identical or substantially similar to the Component Futures
                                            Contracts,” please confirm whether the Fund tracks the SummerHaven Dynamic Commodity
                                            Index Total ReturnSM (the “SDCITR”) through replication or representative
                                            sampling and amend the disclosure accordingly.

Response:
The Fund hereby confirms that the Fund tracks the SDCITR through replication and has revised its disclosure accordingly.

 6. Comment:
                                            Please consider moving the following disclosure to the previous paragraph adjacent to the
                                            disclosure describing how the Fund will track the SDCITR through fully margined and collateralized
                                            portfolios.

Under normal
market conditions, the Fund will invest 80% of its assets in Commodity-Linked Investments. In determining the value of the Fund’s
assets for this purpose, the Fund will value each derivative instrument using the instrument’s notional amount.

Response:
The disclosure has been revised in response to the comment.

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 7. Comment:
                                            Based on the following disclosure, please confirm whether or not futures contracts make up
                                            a portion of Commodity-Linked Investments. Please amend the disclosure accordingly:

In addition
to the market price movements of the Fund’s futures contracts and other Commodity-Linked Investments, the Fund’s total return
includes the return on any assets used to collateralize the Fund’s portfolio.

Response:
The Fund hereby confirms that futures contracts are a part of Commodity-Linked Investments and the disclosure has been revised accordingly.

 8. Comment:
                                            Please specify the type(s) of money market mutual funds that will make up the collateralization
                                            of the Fund’s portfolio.

Response:
We respectfully acknowledge the comment and note that the Fund reserves the flexibility to invest in any type of money market fund to
the extent permitted by the Investment Company Act of 1940, as amended (the “1940 Act”), and consistent with its investment
objective and principal investment strategies. Accordingly, no revisions have been made in response to this comment.

 9. Comment:
                                            Please rephrase the disclosure stating that “[t]he assets of the Subsidiary are subject
                                            to the same investment restrictions and limitations, and follow the same compliance policies
                                            and procedures, as the Fund” to clarify that the Subsidiary itself is subject to the
                                            investment restrictions and limitations, rather than the assets of the Subsidiary.

Response:
The disclosure has been revised in response to the comment.

 10. Comment:
                                            Please explain the statement that SummerHaven Index Management, LLC (“SHIM”)
                                            is not affiliated with the Fund. Please refer to the definition of affiliated person in section
                                            2(a)(3) of the 1940 Act.

Response:
The disclosure has been revised to remove references indicating that SHIM is not affiliated with the Trust or the Fund.

Principal
Risks of Investing in the Fund

 11. Comment:
                                            Please consider moving Small Fund Risk alongside the sub-risks under Investment Strategy
                                            Risks.

Response:
We respectfully acknowledge the comment; however, we note that Small Fund Risk is intended to reflect the risks associated with the current
size of the Fund, rather than the risks associated with the Fund’s investment strategies, and therefore believe the current location
of Small Fund Risk is appropriate. Accordingly, no revisions have been made in response to this comment.

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Management
of the Subsidiary

 12. Comment:
                                            Please consider moving or redisclosing the following statement under the “Management
                                            of the Subsidiary” section.

To the extent
applicable, the Subsidiary is otherwise subject to the same fundamental and non-fundamental investment restrictions as the Fund and,
in particular, to the same requirements relating to portfolio leverage, liquidity, capital structure, and the timing and method of valuation
of portfolio investments and Fund shares described elsewhere in this Prospectus and in the SAI. The Subsidiary will also comply with
the provisions of Section 17 of the 1940 Act related to affiliated transactions and with the requirements of the 1940 Act related to
the custody of a registered investment company’s assets.

Response:
The disclosure has been redisclosed under the “Management of the Subsidiary” section in response to this comment, subject
to certain revisions thereto.

 13. Comment:
                                            In the appropriate section of the registration statement, please disclose that the Fund does
                                            not intend to create or acquire primary control of any entity which primarily engages in
                                            investment activities in securities or other assets other than entities wholly-owned by the
                                            Fund.

Response:
We respectfully acknowledge the comment and hereby supplementally confirm that the Fund does not intend to create or acquire primary
control of any entity which primarily engages in investment activities in securities or other assets other than entities wholly-owned
by the Fund. However, we believe that the Fund is generally not obligated to disclose in the prospectus investment activities and strategies
it does not intend to engage in. We further note that the prospectuses
of other series of the Trust and many existing registered investment companies that have wholly-owned subsidiaries do not contain the
disclosure requested. Accordingly, no revisions have been made in response to this comment.

 14. Comment:
                                            Explain in correspondence whether the financial statements of the Subsidiary will be consolidated
                                            with those of the Fund. If not, please explain why not.

Response:
We hereby confirm that the financial statements of the Subsidiary will be consolidated with those of the Fund.

 15. Comment:
                                            Confirm in correspondence that the Subsidiary and its board of directors will agree to inspection
                                            by the Staff of the Subsidiary’s books and records, which will be maintained in accordance
                                            with Section 31 of the 1940 Act and the rules thereunder.

Response:
We hereby confirm that the Subsidiary and its board of directors will agree to inspection by the Staff of the Subsidiary’s books
and records, which will be maintained in accordance with Section 31 of the 1940 Act and the rules thereunder.

 16. Comment:
                                            Confirm in correspondence that the Subsidiary and its board of directors will agree to designate
                                            an agent for service of process in the United States.

Response:
We hereby confirm that the Subsidiary and its board of directors will agree to designate an agent for service of process in the United
States.

 17. Comment:
                                            Confirm in correspondence that the Subsidiary’s management fee, including performance
                                            fee, if any, will be included in the “Management Fees” and the Subsidiary’s
                                            expenses will be included in the “Other Expenses” in the Fund’s fee table.

Response:
We hereby confirm that the Subsidiary’s management fee, including performance fee, if any, will be included in the “Management
Fees,” and the Subsidiary’s expenses will be included in “Other Expenses” in the Fund’s fee table.

*   *   *

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If you have any questions,
please feel free to contact me at (202) 261-3447.

    Sincerely,

    /s/ Cynthia R. Beyea

    Cynthia R. Beyea

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