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[Chapman
and Cutler LLP Letterhead]

July 25, 2023

VIA EDGAR CORRESPONDENCE

Lisa Larken

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Amplify ETF Trust

    File Nos. 333-207937; 811-23108

Dear Ms. Larken:

This letter responds to your
comments provided by telephone regarding the registration statement filed on Form N-1A for Amplify ETF Trust (the “Trust”)
with the Staff of the Securities and Exchange Commission (the “Staff”) on June 2, 2023 (the “Registration
Statement”). The Registration Statement relates to the Amplify Cash Flow Dividend Leaders ETF (the “Fund”),
a series of the Trust. Capitalized terms used herein, but not otherwise defined, have the meanings ascribed to them in the Registration
Statement.

Comment 1 – General

Please provide the Staff in
a separate correspondence the index methodology used by the Fund.

Response to Comment 1

The Trust confirms that it
will provide the Staff the index methodology used by the Fund in a separate correspondence.

Comment 2 – Principal Investment Strategies

The Staff notes the use of
“dividend” in the Fund’s name. Please revise the Fund’s 80% policy to explicitly refer to the Fund’s dividend
investment within its existing or separate policy.

Response to Comment 2

Pursuant to the Staff’s
comment, the referenced disclosure has been revised as follows:

The Fund invests at least
80% of its net assets (plus borrowings for investment purposes) in securities that comprise the Index, which will primarily include dividend
paying U.S. equity securities.

Comment 3 – Principal Investment Strategies

The Staff notes the subsection
entitled “The Index” set forth in the section entitled “Principal Investment Strategies.” Please revise references
to “high free cash flow yields” to read in plain English.

Response to Comment 3

Pursuant to the Staff’s
comment, the referenced disclosure has been revised as follows:

The Index. The Index
uses an objective, rules-based methodology that comprises of at least 40 and up to 100 mid- to large-capitalization publicly traded equity
securities of US companies exhibiting characteristics of high free cash flow and consistent dividend growth. A company’s “free
cash flow” or “FCF” measures its cash flow from operations minus capital expenditures. (Emphasis added)

Comment 4 – Principal Investment Strategies

The Staff notes that the Fund
uses a screen based on free cash flow estimates and earnings but it is not clear to the Staff what relevance the screen has with respect
to companies that do not have free cash flow. Please clarify.

Please also provide the Staff
with an estimate of the percentage of companies in the Index that are without forward year free cash flow estimates.

Response to Comment 4

The Trust confirms that the
Index does not include companies with no forward year estimates available for FCFs or earnings. The referenced disclosure, as well as
all similar disclosures, has been removed from the Registration Statement.

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Comment 5 – Principal Investment Strategies

The Staff notes the following
disclosure set forth in the subsection entitled “Index Methodology” set forth in the section entitled “Principal Investment
Strategies”:

The remaining securities are
ranked by one-half trailing FCF yield plus one-half forward FCF yield. From this list, the 100 securities with the highest values will
be selected.

Please consider revising
this disclosure to read in plain English.

Response to Comment 5

Pursuant to the Staff’s
comment, the referenced disclosure has been revised as follows:

The remaining securities are ranked in descending order separately by Trailing FCF Yield (defined as trailing 12-month free
cash flow dividends by enterprise value) and Forward FCF Yield (defined as estimated forward-year free cash flow per share divided by
share price).

For each candidate, an “FCF Yield
Rank” is created by averaging a candidate’s Trailing FCF Yield rank and Forward FCF Yield rank. From the eligible
candidates, the 100 securities with the highest FCF Yield Rank will be selected. (Emphasis added)

Comment 6 – Principal Investment Strategies

The Staff notes the references
to “positive consensus earnings,” “payout ratio,” and “indicative dividend yield” set forth in the
subsection entitled “Index Methodology” set forth in the section entitled “Principal Investment Strategies.”

Please explain what relevance
these disclosures have to the Fund’s investment strategy.

Response to Comment 6

The terms noted by the Staff
are each a measurement that the Fund uses to screen from the Index certain potential outlier companies that may have a higher likelihood
of diminished long-term payout capabilities due to current high payouts.

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Comment 7 – Principal Investment Strategies

The Staff notes the following
disclosure set forth in the subsection entitled “Index Methodology” set forth in the section entitled “Principal Investment
Strategies”:

In the case of a spin-off,
the spun-off company will remain in the Index but will require continued dividend growth carting with the next year. The parent company
will not require dividend growth in the spin-off year where “year” is the 12-month period between annual Index reconstitutions.

Please consider revising this
disclosure to read in plain English.

Response
to Comment 7

Pursuant to the Staff’s
comment, the referenced disclosure has been revised as follows:

In the case of a spin-off, the spun-off company will remain in the Index so long as dividend growth continues the next year.
The parent company will not require dividend growth in the spin-off year where “year” is the 12-month period between quarterly
Index reconstitutions. (Emphasis added)

Comment 8 – Principal Investment Strategies

The Staff notes that in certain
instances, the Fund discloses that it will be reconstituted annually, while in others that it will be reconstituted quarterly. Please
reconcile or supplementally explain the discrepancy.

Response to Comment 8

The Trust confirms that the
Fund will be reconstituted quarterly (each March, June, September and December), and pursuant to the Staff’s comment, the referenced
disclosures have been reconciled.

Comment 9 – Principal Investment Strategies

The Staff notes the following
disclosure set forth in the subsection entitled “Index Methodology” set forth in the section entitled “Principal Investment
Strategies”:

The minimum amount of constituents
is 40. If 40 securities satisfy the above criteria, those are selected and given a 2.5% position weighting.

Please supplementally explain
to the Staff what “2.5% position weighting” means.

Response to Comment 9

The Trust confirms that “a
2.5% position weighting” refers to a 2.5% position weighting of the total Index exposure.

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Comment 10 – Principal Investment Strategies

The
Staff notes the subsection entitled “Diversification Status” set forth in the section entitled “Principal Investment
Strategies.” Please consider revising the header “Diversification Status” to “Concentration and Diversification
Status.”

Response to Comment 10

Pursuant
to the Staff’s comment, the referenced disclosure has been revised accordingly.

Comment 11 – Principal Risks

The Staff notes that the principal
risks appear in alphabetical order. Please order the risks to prioritize the risks that are most likely to adversely affect the Fund’s
net asset value, yield and total return.

Response to Comment 11

The Trust respectfully declines
to revise the disclosure as requested by the Staff. Ultimately, the Trust has reached the same conclusion as many other industry participants
and declines to make the requested revisions as it believes the disclosure is compliant with the requirements of Form N-1A. The Trust
continues to evaluate its approach to the ordering of risk factors in light of recent Securities and Exchange Commission guidance.

Comment 12 – Principal Risks

The Staff notes “Concentration
Risk” set forth in the section entitled “Principal Risks.” Please consider rewording the disclosures set forth under
“Concentration Risk” to exclude references to “sector” or, if appropriate, replace this risk with “Industry
Concentration Risk.”

Response
to Comment 12

Pursuant to the Staff’s
comment, the risk disclosure has been revised to remove references to “sector” from the risk factor entitled “Concentration
Risk.”

Comment 13 – Principal Risk

Please
supplementally inform the Staff whether “Creation Units” are purchased primarily with cash or redeemed primarily with cash.

Response to Comment 13

The Trust confirms that Creation
Units are expected to be purchased in-kind.

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Comment 14 – Principal Risks

If
the Fund is classified as “non-diversified” under the 1940 Act, please consider adding a tax risk to the section entitled
“Principal Risks.”

Response to Comment 14

Please
refer to the Trust’s response to Comment 10 above and the Trust’s “Non-Diversification Risk” disclosure. The Trust
does not believe that any additional risks relating to the Fund’s non-diversified status are material to the Fund for the purposes
of disclosure in the Registration Statement.

Comment 15 – Additional Information About the Fund’s
Strategies and Risks

The
Staff notes that, pursuant to Form N-1A, the disclosures in Item 9 should be more fulsome than the disclosures in Item 4. Please revise
the disclosures in Item 9 accordingly.

Response to Comment 15

Pursuant to the Staff’s
comment, the disclosures in Item 9 have been revised accordingly.

Comment 16 – Additional Information About the Fund’s
Strategies and Risks

The
Staff notes the following disclosure set forth under the subsection entitled “Equity Securities” set forth under the section
entitled “Additional Information About the Fund’s Strategies and Risks”:

The
Fund invests in equity securities, including common stocks and/or depositary receipts.

If
the use of depositary receipts are part of the Fund’s principal investment strategy, please add relevant disclosures to the summary
and statutory prospectus.

Response to Comment 16

Pursuant to the Staff’s
comment, the referenced disclosure has been revised as follows to remove the reference to depositary receipts:

“The Fund invests in equity
securities, including common stocks.”

********

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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

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