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CORRESP
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[Chapman
and Cutler LLP Letterhead]

January 12, 2024

VIA EDGAR CORRESPONDENCE

Valerie Lithotomos

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. Lithotomos:

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 Alternative Harvest 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 confirm the Registrant
intends to enter into a license agreement with the Index Provider to continue use of the Index.

Response to Comment 1

The Registrant confirms it
will enter into an Index license agreement with the Index Provider.

Comment 2 – Investment Objective.

The Staff notes that the investment
objective states, “The Amplify Alternative Harvest ETF seeks investment results that generally correspond (before fees and expenses)
to the total return performance of the Prime Alternative Harvest 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 – Fund Fees and expenses

The Staff notes that the Fee
Table contemplates an expense waiver agreement. Please confirm the expiration date of the expense waiver agreement (included
in footnote 2 to the fee table) will be at least one year from the effective date of the Registration Statement.

Response
to Comment 3

The Registrant confirms the
expiration date of the expense waiver agreement will be at least one year from the effective date of the
Registration Statement. In accordance with the Staff’s comment, the footnote to the Fee Table has been revised as follows:

 (2) The Fund’s investment adviser, Amplify Investments LLC (the “Adviser”), has agreed to waive its management fee in an amount equal to the acquired fund fees and expenses related to any investment in Amplify Seymour Cannabis ETF and Amplify U.S. Alternative Harvest ETF. This arrangement will remain in effect for at least one year from the date of this prospectus, and prior to such date the Adviser may not terminate the arrangement without the approval of the Board of Trustees of the Trust.

Comment 4 – Fund Fees and expenses

Please supplementally confirm
that the Fund’s fee and expense waiver arrangement does not permit recoupment of any fees waived and/or expenses reimbursed.

Response
to Comment 4

The Fund confirms that the
fee and expense waiver arrangement does not permit recoupment of any fees waived and/or expenses reimbursed.

Comment 5 – Principal Investment Strategies

Please provide to the Staff
a copy of the Index methodology white paper.

Response
to Comment 5

The Fund will provide the
Staff a copy of the Index methodology under separate cover.

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Comment 6 – Principal Investment Strategies

Please confirm whether the
Index Provider is affiliated with the Fund or the Adviser.

Response
to Comment 6

The Fund confirms the Index
Provider is not affiliated with the Fund or the Adviser and directs the Staff to the following disclosure, which appears in the tenth
paragraph under the “Principal Investment Strategies” section:

The Index Provider is not
affiliated with Solactive AG, the Fund, the Adviser, Toroso Investments, LLC (the “Sub-Adviser) and the Fund’s distributor.

Comment 7 – Principal Investment Strategies

The Staff requests the Fund
consider revising the first paragraph of the “Principal Investment Strategies” section to contemplate the full name of the
index, Prime Alternative Harvest Index, to enhance readability for investors. .

Response
to Comment 7

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

Comment 8– Principal Investment Strategies

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

A company is considered to
be a “U.S. Cannabis Company” if it derives more than 50% of its revenue from the activity described in categories (i), (ii),
(iii), or (vii) within the United States.

Given that “U.S.”
does not appear in the name of the Fund, please confirm that the above-referenced disclosure is appropriate.

Response
to Comment 8

The Fund confirms that the
above referenced disclosure is part of the selection criteria, but is only meant to qualify which cannabis companies are considered to
be U.S. cannabis companies (as opposed to cannabis companies operating outside the U.S.). The Index includes companies across the globe,
including U.S. cannabis companies with the limitations described in the Principal Investment Strategies section. Therefore, the Fund believes
the disclosure, as currently stated, is accurate for investor comprehension.

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Comment 9 – 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 9

The Fund points the Staff
to the first paragraph under “Principal Investment Strategies,” 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.

Comment 10– Principal Investment Strategies

The Staff notes the following
statement 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 confirm whether the
Fund will be concentrated in the pharmaceuticals industry.

Response
to Comment 10

In accordance with the Staff’s
comment, the above referenced disclosure will be revised as follows:

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 the date of this prospectus,
the Fund is concentrated in securities of issuers in the cannabis industry.

Comment 11 – 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 11

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.

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Comment 12 – Principal Risks

The Staff notes the “Associated
Risks of Investments in SPACs” under the “Principal Risks” section. What percentage of the Fund will be invested in
SPACs?

Response
to Comment 12

The Fund has removed the references
to its investments in SPACs from the Principal Investment Strategies and Principal Risks section, as the Fund does not currently expect
that SPACs will be a principal investment of the Fund in accordance with the Index. The Fund has revised further revised the Registration
Statement to include a reference to the possibility of non-principal investments in SPACs in the Statement of Additional Information,
as follows:

NON-PRINCIPAL FUND INVESTMENTS

Special Purpose Acquisition
Companies

The Fund may invest
on a limited basis in securities of special purpose acquisition companies (each a “SPAC” and collectively, “SPACs”).
A SPAC is a special purpose company whose business plan is to raise capital in an initial public offering (“IPO”) and, within
a specific period of time, engage in a merger or acquisition with one or more unidentified companies. SPACs are formed by sponsors who
believe that their experience, reputations and/or contacts will allow them to identify and complete a business combination transaction
with one or more target businesses that will ultimately be a successful public company. Some SPACs focus on acquiring a target in a particular
industry while others may pursue a business combination transaction in any business, industry or geographic location, including outside
of the United States. The Fund may, from time to time, seek investments in SPACs with a stated purpose to find an acquisition target consistent
with the Fund’s investment strategy.

In a SPAC’s
IPO, the SPAC typically offers units comprised of a share of common stock and a warrant to purchase a share or less of common stock that
is exercisable, with a strike price higher than the offering price of the unit, if the SPAC completes a business combination transaction.
Generally, the units offered in a SPAC’s IPO are listed on a national securities exchange and the common stock and warrants comprising
the units are listed and trade separately shortly after the IPO. Because SPACs have no operating history or ongoing business other than
seeking acquisitions, the value of their securities is particularly dependent on the ability of the entity’s management to identify
and complete a profitable acquisition. There is no guarantee that the SPACs in which the Fund may invest will complete an acquisition
or that any acquisitions that are completed will be profitable. Public stockholders of SPACs may not be afforded a meaningful opportunity
to vote on a proposed initial business combination because certain stockholders, including stockholders affiliated with the management
of the SPAC, may have sufficient voting power, and a financial incentive, to approve such a transaction without support from public stockholders.
As a result, a SPAC may complete a business combination even though a majority of its public stockholders do not support such a combination.
SPACs in which the Fund may invest pursue acquisitions only within a certain industry or industries, which may increase the volatility
of their prices.

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In addition, the following
has been added to the section entitled “Investment Strategies and Risks” in the Statement of Additional Information:

Special Purpose Acquisition
Companies Risk

The Fund may invest
on a limited basis in SPACs. Shares of a SPAC purchased in an initial public offering will generally bear a sales commission, which may
be significant. The shares of a SPAC are often issued in “units” that include one share of common stock and one right or warrant
(or partial right or warrant) conveying the right to purchase additional shares or partial shares. In some cases, the rights and warrants
may be separated from the common stock at the election of the holder, after which they may become freely tradeable. After going public
and until a transaction is completed, a SPAC generally invests the proceeds of its initial public offering (less a portion retained to
cover expenses) in U.S. Government securities, money market securities and cash. To the extent the SPAC is invested in cash or similar
securities, this may impact the Fund’s ability to meet its respective investment objective. If a SPAC does not complete a transaction
within a specified period of time after going public, the SPAC is typically dissolved, at which point the invested funds are returned
to the SPAC’s shareholders (less certain permitted expenses) and any rights or warrants issued by the SPAC expire worthless. SPACs
generally provide their investors with the option of redeeming an investment in the SPAC at or around the time of effecting a transaction.
In some cases, a holder may forfeit its right to receive additional warrants or other interests in the SPAC if it redeems its interest
in the SPAC in connection with a transaction. Because SPACs often do not have an operating history or ongoing business other than seeking
a transaction, the value of their securities may be particularly dependent on the quality of its management and on the ability of the
SPAC’s management to identify and complete a profitable transaction. Some SPACs may pursue transactions only within certain industries
or regions, which may increase the volatility of an investment in them. In addition, the securities issued by a SPAC, which may be traded
in the over the-counter market, may become illiquid and/or may be subject to restrictions on resale. Other risks of investing in SPACs
include that a significant portion of the monies raised by the SPAC may be expended during the search for a target transaction; an attractive
transaction may not be identified at all (or any requisite approvals may not be obtained) and the SPAC may be required to return any remaining
monies to shareholders; a transaction once identified or effected may prove unsuccessful and an investment in the SPAC may lose value;
the warrants or other rights with respect to the SPAC may expire worthless or may be repurchased or retired by the SPAC at an unfavorable
price; and an investment in a SPAC may be diluted by additional later offerings of interests in the SPAC or by other investors exercising
existing rights to purchase shares of the SPAC.

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Comment 13 – Principal Risks

The Staff notes the “Foreign
Investment Risk” under the “Principal Risks” section. If the Fund has significant exposure to Emerging Market countries,
please add relevant disclosure.

Response
to Comment 13

The Fund confirms that it
will not have significant exposure to Emerging Market countries. Therefore, the Fund respectfully declines to add any additional disclosure.

Comment 14 – Exhibits

The Registrant should include
index license or sub-license agreements to which the Fund is a party as an exhibit to the Registration Statement, as applicable, as such
contract would be considered an other material contract pursuant to Item 28(h) of Form N-1A.

Response
to Comment 14

The Fund respectfully declines
to file the Index licensing agreement as an exhibit to the Registration Statement as it is an agreement between the Adviser and the Index
Provider to which the Fund is not a party. However, the Fund will file the Index sub-licensing agreement between the Fund and the Adviser.

Comment 15– Exhibits

The Staff requests that the
Registrant include a legal opinion regarding the legality of investing in cannabis related industries.

Response
to Comment 15

The Fund confirms it will
provide the requested legal opinion to the Staff prior to effectiveness.

Comment 16– Exhibits

Given that financials are
included in the Registration Statement, please include Exhibit J (Auditor’s Consent) as an Exhibit to the Registration Statement.

Response
to Comment 16

The Fund confirms that the
Independent Auditor’s consent will be included as an Exhibit to the Registration Statement.

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Comment 17 – Exhibits

The Staff notes that the referenced
Powers of Attorney are almost 8 years old. The Staff requests the Registrant provide updated Powers of A