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[Chapman
and Cutler LLP Letterhead]

January 12, 2024

VIA EDGAR CORRESPONDENCE

Christopher Bellacicco

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 Mr. Bellacicco:

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 July 26, 2023 (the “Registration
Statement”). The Registration Statement relates to the Amplify Junior Silver Miners 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 – Investment Objective.

The Staff notes that the investment
objective states, “The Amplify Junior Silver Miners ETF seeks investment results that generally correspond (before fees and expenses)
to the total return performance of the Nasdaq Metals Focus Silver Miners Index (the “Index”).” Please change “correspond”
to “correlate” as the Staff believes “correlate” is a more accurate term.

Response to Comment 1

The disclosure has been revised
in accordance with the Staff’s comment.

Comment 2 – Principal Investment Strategies

The Staff notes the following
statement set forth in the section entitled “Principal Investment Strategies”:

“The Index tracks the performance of the
equity securities (or corresponding American Depositary Receipts (“ADRs”) or Global Depositary Receipts (“GDRs”))
of companies actively engaged in silver mining industry (“Silver Companies”). Silver Companies are selected based on classification
by Metals Focus, an independent precious metals research consultancy. Silver Companies include companies that derive the majority of their
revenues from silver mining, have a significant market share of global silver production, or are principally engaged in exploration and
development activities related to new silver production as defined by Metals Focus. All securities are assigned to an individual sector
by Metals Focus. The eligible sectors include: Project Development, Silver Mining, Streaming, Diversified Mining, Gold Mining, Zinc Mining,
and Copper Mining.”

The Staff notes that the beginning
of the paragraph discusses Silver Companies, but the end of the paragraph references “sectors” that are broken out by Metals
Focus. Please consider revising the structure of the paragraph for better clarity.

Response to Comment 2

In accordance with the Staff’s
comment, the disclosure has been revised as follows:

“The Index
tracks the performance of the equity securities (or corresponding American Depositary Receipts (“ADRs”) or Global Depositary
Receipts (“GDRs”)) of silver companies, subject to the market capitalization screen as describe below. All securities are
assigned to an individual category by Metals Focus, an independent precious metals research consultancy. These categories include Project
Development, Silver Mining, Streaming, Diversified Mining, Gold Mining, Zinc Mining, and Copper Mining. Silver Companies include companies
that derive a majority of their revenues from silver mining, have a significant market share of global silver production, or are principally
engaged in exploration and development activities related to new silver production as defined by Metal Focus.

Securities are then
screened as of the Reconstitution Reference Date (defined below) for investability to determine initial inclusion (e.g., must not
be listed on an exchange in a country which employs certain restrictions on foreign capital investment), a minimum market capitalization
of $20 million, a minimum three minimum three-month average daily dollar trading volume of $10,000, and subject to the market capitalization
weightings described below.

The Index is rebalanced
quarterly in February, May, August and November in connection with the Index’s reconstitution. The Reconstitution Reference Date
is either the last trading day of April or October.

Weighting.
A theme-adjusted free float market value is calculated for each Index constituent as the product of the constituent’s free float
market capitalization and its silver revenue, as defined by Metals Focus. Each Index constituent’s weight is determined by dividing
its theme-adjusted free float market value by the aggregate theme-adjusted free float market value of all Index constituents.

    - 2 -

Index constituents
are then grouped based on their market capitalization at the time of the Reconstitution Reference Date. Group 1 constituents are those
that have a full market capitalization in the 90th percentile of the portfolio. Group 2 constituents consist of all other securities.
The aggregate weight of Group 1 securities cannot exceed 10% of the total portfolio weight.

Comment 3 – Principal Investment Strategies

The Staff notes the following
statement set forth in the section entitled “Principal Investment Strategies”:

“Silver Companies are then screened as
of the Selection Date for investibility to determine initial inclusion (e.g., must not be listed on an exchange in a country which
employs certain restrictions on foreign capital investment), a minimum market capitalization of $20 million, a minimum three-month average
daily dollar trading volume of $10,000, and a maximum market capitalization.”

The Staff notes that “Selection
Date” is not previously defined or otherwise used throughout the prospectus. Please define or revise accordingly.

Response to Comment 3

The
disclosure has been revised accordingly. Please refer to the Fund’s response to Comment No. 2.

Comment 4 – Principal Investment Strategies

The Staff notes the following
statement set forth in the section entitled “Principal Investment Strategies”:

“… and a maximum market capitalization.”

Please describe with greater
detail the “maximum market capitalization.”

Response to Comment 4

The Fund notes that the Index
does not have maximum market capitalization parameters and accordingly the disclosure has been revised. Please refer to the Fund’s
response to Comment No. 2.

    - 3 -

Comment 5 – Principal Investment Strategies

The Staff notes the following
statement set forth in the section entitled “Principal Investment Strategies”:

“The Fund invests at least 80% of its
total assets, exclusive of collateral held from securities lending, in the component securities of the Index and in ADRs and GDRs based
on the component securities in the Index.”

Please confirm that “total
assets” is equivalent to net assets plus borrowings for investment purposes under Rule 35d-1.

Response to Comment 5

The Fund confirms “total
assets” is equivalent to net assets plus borrowings for investment purposes. However, the Fund has revised the disclosure to state
net assets plus borrowings for investment purposes.

Comment 6 – Principal Investment Strategies

If
the Fund intends to use derivatives to gain exposure to the Index, please disclose with specificity.

Response to Comment 6

The Fund supplementally confirms
that it does not intend to gain exposure to the Index by investing in derivatives.

Comment 7 – Principal Investment Strategies

Please
specify what securities are included in the 20% bucket. If the Fund intends to invest in derivatives as part of the 20% bucket, please
ensure enough specificity in the risk disclosure with respect to derivatives.

Response to Comment 7

The Fund points the Staff
to the first paragraph under “Additional Information about the Fund’s Strategies and Risks,” which includes the following
disclosure: “The Fund may invest up to 20% of its total assets in equity securities that are not in the Fund’s Index to the
extent that the Adviser believes such investments should help the Fund’s overall portfolio to provide returns substantially similar
to the Index.” The Fund supplementally confirms that it does not intend use the 20% bucket to invest in derivatives.

    - 4 -

Comment
8 – Principal Investment Strategies

The Staff notes the following
statement set forth in the section entitled “Principal Investment Strategies”:

Concentration Policy. The Fund will not
concentrate its investments (i.e., invest more than 25% of the value of its total assets) in securities of issuers in any industry or
group of industries, except to the extent the Index is concentrated in an industry or a group of industries.

Please disclose whether the
Index is currently concentrated and if so, disclose the specific industry or group of industries in which the Index is concentrated.

Response to Comment 8

In accordance with the Staff’s
comment, the above-referenced disclosure has been deleted in its entirety and replaced with the as following:

“The
Fund will not concentrate its investments (i.e., invest more than 25% of the value of its total assets) in securities of issuers
in any one industry or group of industries, except to the extent that the Index concentrates in an industry or group of industries. As
of the date of this prospectus, the Index is concentrated in the [ ] industries.”

Comment 9 – Principal Risks

The Staff notes that the principal
risks appear in alphabetical order. The Staff requests the Fund list its principal
risks in the order of importance rather than alphabetically. See ADI 2019-08 – Improving Principal Risk Disclosure.

Response to Comment 9

The Fund respectfully declines
to revise the disclosure as requested by the Staff. Ultimately, the Fund 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 Fund continues
to evaluate its approach to the ordering of risk factors in light of recent Securities and Exchange Commission guidance.

Comment 10 – Principal Risks

The Staff notes the “Canada
Specific Risk” under the “Principal Risks” section. If the Fund’s investments will be focused in Canada, please
add disclosure to the “Principal Investment Strategies” section.

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Response
to Comment 10

The disclosure has been revised
to note that the Index has significant exposure to Canadian companies.

Comment 11 – Principal Risks

Please
consider whether Emerging Markets Risk and/or risk regarding index issues should be added to the prospectus. The Staff notes that the
Fund has an investment strategy to track an index with significant exposure to non-US companies in emerging and frontier markets. Please
provide disclosure with respect to the following risks (and any related risks) associated with this investment strategy or explain to
the Staff why such disclosure would not be appropriate: 1) the potential for errors in index data, index computation, and/or index construction
if information on non-U.S. companies is unreliable or outdated, or if less information about the non-U.S. companies is publicly available
due to differences in regulatory, accounting, auditing and financial record keeping standards, 2) the potential significance of such errors
on the Fund’s performance, 3) limitations on the Fund Advisor’s ability to oversee the Index Provider’s due diligence
process over index data prior to its use in index computation, construction and/or rebalancing, and/or 4) the rights and remedies associated
with investments in the Fund that tracks an index comprised of foreign securities may be different than a fund that tracks an index of
domestic securities.

Response to Comment 11

In accordance with the Staff’s
comment, the Fund has added the following “Index Provider Risk” and “Emerging Markets Risk” to the “Principal
Risks” section:

Index
Provider Risk. The Fund seeks to achieve returns that generally correlate before fees and expenses, to the performance of the Index,
as published by their Index Provider. There is no assurance that the Index Provider will compile the Index accurately, or that the Index
will be determined, composed or calculated accurately. The composition of the Index is heavily dependent on information and data supplied
by third parties over which the Adviser has no or limited ability to oversee. While the Index Provider gives descriptions of what the
Index is designed to achieve, the Index Provider does not provide any warranty or accept any liability in relation to the quality, accuracy
or completeness of data in its indices, and it does not guarantee that its Index will be in line with its methodology. Because of this,
if the composition of the Index reflects any errors, the Fund’s portfolio can be expected to also reflect the errors. In addition,
data and information on non-U.S. countries may be unreliable or outdated or there may be less publicly available data or information about
non-U.S. countries due to differences in registration, accounting, audit and financial record keeping standards which creates the potential
for errors in Index data, Index computation and/or Index construction and could have an adverse effect on the Fund’s performance.

    - 6 -

Emerging
Markets Risk. Emerging market countries include, but are not limited to, those considered to be developing by the International Monetary
Fund, the World Bank, the International Finance Corporation or one of the leading global investment banks. The majority of these countries
are likely to be located in Asia, Latin America, the Middle East, Central and Eastern Europe, and Africa. Investments in emerging market
issuers are subject to a greater risk of loss than investments in issuers located or operating in more developed markets. This is due
to, among other things, the potential for greater market volatility, lower trading volume, higher levels of inflation, political and economic
instability, greater risk of a market shutdown and more governmental limitations on foreign investments in emerging market countries than
are typically found in more developed markets. Moreover, emerging markets often have less uniformity in accounting and reporting requirements,
less reliable securities valuations and greater risks associated with custody of securities than developed markets. In addition, emerging
markets often have greater risk of capital controls through such measures as taxes or interest rate control than developed markets. Certain
emerging market countries may also lack the infrastructure necessary to attract large amounts of foreign trade and investment. Emerging
market economies’ exposure to specific industries, such as tourism, and lack of efficient or sufficient health care systems, could
make these economies especially vulnerable to global crises, including but not limited to, pandemics such as the global COVID-19 pandemic.
In addition, the rights and remedies associated with investments in a fund that tracks an index comprised of foreign securities may be
different than a fund that tracks an index of domestic securities.

Comment 12 – Performance

The Staff notes that the other
shell registration statements filed contemporaneously with this Registration Statement included disclosure similar to the below:

On ___, 2023, the Fund ceased tracking
the ____ and began investing in securities that comprise the Index. Therefore, the Fund’s performance and historical returns shown
below are not necessarily indicative of the performance that the Predecessor Fund, based on the current strategy, would have generated.

The Staff requests similar
disclosure be added to the Fund’s prospectus.

    - 7 -

Response
to Comment 12

In
accordance with the Staff’s comment, the following has been added to the “Performance” section:

“On ___, 2024, the Fund
ceased tracking the Prime Junior Silver Miners & Explorers Index and began investing in securities that comprise the Index. Therefore,
the Fund’s performance and historical returns shown below are not necessarily indicative of the performance that the Predecessor
Fund, based on