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CORRESP
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[Chapman
and Cutler LLP Letterhead]

January 12, 2024

VIA EDGAR CORRESPONDENCE

Lisa Larkin

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. Larkin:

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 Treatments, Testing and Advancements 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

The Staff notes that this
is an automatically effective filing pursuant to Rule 485(b) of Securities Act of 1933, and as such, a Staff accountant is not required
to review the Registration Statement. If the Registrant intends to request acceleration of the filing, please ensure a Staff accountant
reviews the Registration Statement.

Response to Comment 1

The Registrant acknowledges
the Staff’s comment relating to the requirement of a Staff accountant’s review of a Registration Statement filed pursuant
to an acceleration request.

Comment 2 – Investment Objective.

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

Response to Comment 2

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

Comment 3 – Principal Investment Strategies

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

“The Index tracks the performance of U.S.-listed
equity securities or depositary receipts of companies that (i) perform research, development, and commercialization of treatments or vaccines
for infectious diseases or (ii) engage in the research, development, manufacturing, and provision of biological tests for patients.”

Please confirm whether Global
Depositary Receipts (GDRs) are included. If GDRs do not trade on U.S. exchange, please revise the disclosure to clarify that.

Response to Comment 3

The Fund confirms that GDRs
are not included in the Index. The disclosure has been revised to clarify that the Index tracks the performance of U.S.-listed equity
securities or American Depositary Receipts (ADRs) of such companies.

Comment 4 – Principal Investment Strategies

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

“The Index tracks the performance of U.S.-listed
equity securities or depositary receipts of companies that (i) perform research, development, and commercialization of treatments or vaccines
for infectious diseases or (ii) engage in the research, development, manufacturing, and provision of biological tests for patients.”

Please tie back this disclosure
with the immediately succeeding paragraph where the definitions of “Treatment Companies” and “Testing Companies”
(i.e., please explain how the two prongs in the referenced disclosure relate to “Treatment Companies” and “Testing Companies”).

Response to Comment 4

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

Under normal circumstances, the Fund
invests at least 80% of its net assets (plus borrowings for investment purposes) in U.S.-listed equity securities or American Depositary
Receipts (“ADRs”) of Treatments, Testing and Advancements Companies (as defined below). In general, the Index seeks to be
comprised of companies: i) performing advancements in research, development, and commercialization of treatments or vaccines for infectious
diseases, or ii) engaged in the advancement of research, development, manufacturing, and provision of biological tests for patients.

    - 2 -

Prime Indexes (the “Index Provider”)
determines whether a company is a “Treatments, Testing and Advancements Company” based on the assessment of: i) if a company
has one or more vaccines or treatments for infectious diseases in preclinical research, in any phase of U.S. Food and Drug Administration
(“FDA”) clinical trials, or in commercial stage (i.e., capable of being manufactured for widespread use) and is classified
by North American Industry Classification System as being in either a) the “Pharmaceutical and Medicine Manufacturing” industry,
or b) the “Research and Development in the Physical, Engineering, and Life Sciences” industry; or ii) if a company derives
more than 50% of its revenue from research, development, manufacturing, and provision of biological tests for patients.

To qualify for inclusion in the Index,
Treatments, Testing and Advancements Companies must have an operating company structure. To be added to the Index, Treatments, Testing
and Advancements Companies must have a minimum market capitalization of $100 million, must have an average daily value traded over the
prior three-month period of $250,000 and must be listed on a U.S. exchange. Companies already included in the Index must have a minimum
market capitalization of $50 million.

Comment 5 – Principal Investment Strategies

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

“The Index is comprised of two groups
of companies, as described below: “Treatment Companies” and “Testing Companies”. “Treatment Companies”
are companies that (i) have one or more vaccines or treatments for infectious diseases in pre-clinical research, in any phase of U.S.
Food and Drug Administration clinical trials, or in a commercial stage.”

Please explain what is meant
by “commercial stage.”

Response to Comment 5

Please refer to the Fund’s
response to Comment no. 4 for the revised disclosure.

    - 3 -

Comment 6 – Principal Investment Strategies

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

“…(ii) are classified by the North
American Industry Classification System as either “Pharmaceutical and Medicine Manufacturing” or “Research and Development
in the Physical, Engineering, and Life Sciences.”

Please clarify what classification
is being referenced here.

Response to Comment 6

The Fund notes that the North
American Industry Classification System (NAICS) is the standard used by Federal statistical agencies in classifying business establishments
for the purpose of collecting, analyzing, and publishing statistical data related to the U.S. business economy. “Pharmaceutical
and Medicine Manufacturing” or “Research and Development in the Physical, Engineering, and Life Sciences” are industries
classified by NAICS. The disclosure has been revised to clarify. Please refer to the Fund’s response to Comment no. 4 for the revised
disclosure.

Comment 7 – Principal Investment Strategies

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

“To qualify for inclusion in the Index,
Treatments Companies and Testing Companies must have an operating company structure (as opposed to being a pass-through security).”

Please explain the relevance
of the parenthetical or consider deleting if not necessary.

Response to Comment 7

The parenthetical has been
removed from the disclosure. Please refer to the Fund’s response to Comment no. 4 for the revised disclosure.

    - 4 -

Comment 8 – Principal Investment Strategies

Please
add disclosure to the “Principal Investment Strategies” section regarding the Index Weighting Methodology.

Response to Comment 8

In accordance with the Staff’s
comment, the following disclosure has been added to the prospectus:

Weighting. All components with a market
capitalization greater than $15 billion (A “MegaCap Component”) are equally weighted within an aggregate weighting of 10%.
The determination for whether a company is designated a MegaCap Component is made only at the time of that company’s initial entry
into the Index. The remaining constituents are then ranked from highest to lowest market capitalization, subject to the following constraints:
(i) the top five components are weighted at 6% each and (ii) the remaining constituents are weighted based on their market capitalization
subject to a 4% limit per security.

Comment 9 – Principal Investment Strategies

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

“The remaining constituents with a market
capitalization under $15 billion are weighted bases on their market capitalization subject to a 4% limit per security.”

Please change “bases”
to “based”.

Response to Comment 9

The disclosure has been revised
in accordance with the Staff’s comment. Please refer to the Fund’s response to Comment no. 8 for the revised disclosure.

Comment 10 – Principal Investment Strategies

Please confirm supplementally
to the Staff what the term “advancements” has to do with the name of the Fund or the Index.

Response to Comment 10

The Registrant considers the
term “advancements” to mean developments or improvements in medicine. For example, the Index may include companies who have
one or more vaccines or treatments for infectious diseases in preclinical research, in any phase of FDA clinical trials, or in commercial
stages preparing for more widespread distribution. The Registrant would consider these companies to represent advancement in the field
if their vaccines are new to the market. Further, the Index may include a company that derives more than 50% of its revenue from research,
development, manufacturing, and provision of biological tests. If the research generated from such company resulted in a new vaccine,
the Registrant would consider this to be an advancement in the field. Please refer to the Fund’s response to Comment no. 4 for the
more fulsome revised disclosure.

    - 5 -

Comment 11 – Principal Investment Strategies

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 11

The Fund supplementally confirms that it does not
intend to use the 20% bucket to invest in derivatives.

Comment 12 – Principal Investment Strategies

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

“The Index was initially created by the
Index Provider. The Index Provider is not affiliated with the Fund, the Adviser or r Toroso Investments, LLC (the “Sub-Adviser”).”

Please remove the hanging
“r”.

Response to Comment 12

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

Comment
13 – 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. As of [__], 2024, the Index
was concentrated in the biotechnology sector.

    - 6 -

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.

Related, please confirm whether
the reference to “biotechnology sector” should instead be “biotechnology industry.” If the Index is concentrated
in the biotechnology sector, please remove the last sentence of the above referenced disclosure as only industry concentrations should
be disclosed.

Response to Comment 13

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

“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 14 – 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 14

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 15 – Principal Risks

The Staff notes the “Correlation
Risk” set forth in the section entitled “Principal Risks.” The Staff notes that the “Tracking Error Risk”
already addresses the concept covered in the Correlation Risk. Please reconcile the repetitive disclosure.

Response
to Comment 15

The Fund has deleted the “Correlation
Risk” from the prospectus.

    - 7 -

Comment 16 – Principal Risks

The Staff notes the “Depositary
Receipts Risk” set forth in the section entitled “Principal Risks.” If GDRs are included in the Index, please update
the risk to include risk disclosure specific to GDRs.

Response
to Comment 16

As previously noted in the
Fund’s response to Comment no. 3, the Index will not include GDRs. Therefore, the Fund respectfully declines to add any additional
disclosure regarding GDRs.

Comment 17 – Principal Risks

The Staff notes there is no
“Foreign Investment Risk” set forth in the section entitled “Principal Risks.” Please confirm whether foreign
risk disclosure should be included in the disclosure.

Response
to Comment 17

In accordance with the Staff’s
comment, the “Foreign Investment Risk” (and the accompanying sub-risks) have been added to the Principal Risks section.

Comment 18 – Principal Risks

The Staff notes “ETF
Risks” set forth in the section entitled “Principal Risks.” Please supplementally confirm if the Fund invests in instruments
traded outside of a collateralized settlement system.

Response
to Comment 18

The Registrant confirms that
none of the instruments in which the Fund intends to invest in are traded outside of a collateralized settlement system.

Comment 19 – Principal Risks

The Staff notes the “Cash
Transactions Risk” set forth in the section entitled “Principal Risks.” Please confirm that the Fund may effect its
creations and redemptions primarily for cash.

Response
to Comment 19

In accordance with the Staff’s
comment, the “Cash Transactions Risk” has been removed from the disclosure.

    - 8 -

Comment 20 – Principal Risks

The Staff notes the “Management
Risk” set forth in the section entitled “Principal Risks.” Please confirm this risk is appropriate for inclusion in
the disclosure.

Response
to Comment 20

In accordance with the Staff’s
comment, the “Management Risk” has been removed from the disclosure.

Comment 21 – Principal Risks

The Staff notes that “Smaller
Companies Risk”, “Tax Risk” and “Valuation Risk” do not appear in the section entitled “Principal
Risks”. Please confirm to the Staff whether these risks should be included as Principal Risks to the Fund.

Response
to Comment 21

In accordance with the Staff’s
comment, the following risks have been added to the Principal Risks section:

Smaller