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CORRESP
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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 Travel Tech 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 Travel Tech ETF seeks investment results that generally correspond (before fees and expenses) to
the total return performance of the Prime Travel Technology Index NTR (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 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 2

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 3 – Principal Investment Strategies

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

Response to Comment 3

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

Comment 4 – 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 4

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.

Comment
5 – Principal Investment Strategies

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

“The Fund may also invest in other
investment companies that principally invest in the types of instruments allowed by the investment strategies of the Fund.”

Please confirm that acquired
fund fees and expenses (AFFE) does not need to be disclosed in the fee table.

 Response
to Comment 5

The Fund confirms that it
does not expect to incur AFFE during its first year of operations.

    - 2 -

Comment
6 – Principal Investment Strategies

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

“The Index tracks the performance
of globally exchange-listed equity securities (or corresponding American Depositary Receipts (“ADRs”) or Global Depositary
Receipts (“GDRs”)) of companies across the globe...”

The Staff notes that the terms
“ADRs” and “GDRs” are previously used earlier in the Principal Investment Strategies section. Please revise the
disclosure to define “ADRs” and “GDRs” the first time such terms are used.

Response
to Comment 6

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

Comment
7 – 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 in the component securities of the Index and in ADRs and GDRs based on the component securities in the Index. The Fund may invest
up to 20% of its total assets in 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 track the Index.”

The Staff notes that that
the 80% policy is already disclosed earlier in the “Principal Investment Strategies” section. Please consider deleting the
duplicative disclosure.

Response
to Comment 7

In accordance with the Staff’s
comment, the duplicative disclosure has been removed from the prospectus.

    - 3 -

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.

    - 4 -

Comment 10 – Principal Risks

The Staff notes the “Depositary
Receipts Risk” under the “Principal Risks” section. 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 10

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.

    - 5 -

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 11 – Principal Risks

Please consider adding an
“Index Provider Risk” to the “Principal Risks” section.

Response
to Comment 11

The
disclosure has been revised in accordance with the Staff’s comment. Please refer to the risk disclosure in the Fund’s response
to Comment No. 10.

    - 6 -

Comment 12 – Principal Risks

Please consider adding a “Tax
Risk” to the “Principal Risks” section.

Response
to Comment 12

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

Tax
Risk. To qualify for the favorable tax treatment generally available to RICs, the Fund must satisfy certain diversification requirements
under the Internal Revenue Code of 1986, as amended (the “Code”). In particular, the asset diversification requirements will
be satisfied if (i) at least 50% of the value of the Fund’s total assets are represented by cash and cash items, U.S. government
securities, the securities of other RICs and “other securities,” provided that such “other securities” of any
one issuer do not represent more than 5% of the Fund’s total assets or greater than 10% of the outstanding voting securities of
such issuer, and (ii) no more than 25% of the value of the Fund’s assets are invested in securities of any one issuer (other than
U.S. government securities and securities of other RICs), the securities (other than securities of other RICs) of any two or more issuers
that are controlled by the Fund and are engaged in the same or similar or related trades or business, or the securities of one or more
“qualified publicly traded partnerships.” When the Index is concentrated in a relatively small number of securities, it may
not be possible for the Fund to fully implement a replication strategy or a representative sampling strategy while satisfying these diversification
requirements. The Fund’s efforts to satisfy the diversification requirements may cause the Fund’s return to deviate from that
of the Index, and the Fund’s efforts to replicate the Index may cause it inadvertently to fail to satisfy the diversification requirements.
If the Fund were to fail to qualify as a RIC, it would be subject to U.S. federal income tax at corporate rates on its income, and distributions
to its shareholders would not be deductible by the Fund in computing its taxable income. In addition, distributions to a Fund’s
shareholders would generally be taxed as ordinary dividends.

Comment 13 – Purchase and Sale of Shares

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

Response
to Comment 13

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

    - 7 -

Comment 14 – Additional Information about the Fund’s
Strategies and Risks

The Staff notes the following
statement set forth in the section entitled “Additional Information About the Fund’s Strategies and Risks”:

The Fund’s investment objective
has been adopted as a non-fundamental investment policy and may be changed without shareholder approval upon reasonable notice to shareholders.
Additionally, in accordance with rules under the Investment Company Act of 1940, as amended (the “1940 Act”), the Fund’s
80% Policy has been adopted as a non-fundamental investment policy and may be changed without shareholder approval upon 60 days’
written notice to shareholders. The Fund may liquidate and terminate at any time without shareholder approval.

The Staff believes this paragraph
is duplicative of the immediately preceding paragraph in the section entitled “Additional Information about the Fund’s Strategies
and Risks”. Please considering removing the duplicative disclosure.

Response
to Comment 14

The Fund confirms the duplicative
disclosure has been removed from the prospectus. For the sake of clarity, the disclosure has been revised as follows:

“The Fund is a
series of the Trust, an investment company and a passively managed ETF. The Fund uses an “indexing” investment approach to
attempt to replicate, before fees and expenses, the performance of the Index. The investment objective of the Fund is to provid