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CORRESP
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[Chapman
and Cutler LLP Letterhead]

May 3, 2024

VIA EDGAR CORRESPONDENCE

Kim McManus and 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. McManus and Ms. Lithotomos:

This letter responds to your
comments, provided by telephone on April 23 2024 regarding the registration statement (the “Registration Statement”)
filed on Form N-1A for Amplify ETF Trust (the “Trust”) with the Securities and Exchange Commission (the “Commission”).
The Registration Statement relates to the Amplify Weight Loss Drug & Treatment 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 requests information
for all blanks, brackets, and otherwise missing information, including the Ticker, is completed in advance of effectiveness.

Response to Comment 1

The Fund confirms all required
information will be completed in advance of effectiveness in accordance with the Staff’s request.

Comment 2 – General

Please respond to our comments
in writing and file the responses as correspondence on EDGAR. Where a comment asks for revised disclosure or revisions are contemplated
by the Registrant’s response, please provide revised disclosure with your letter.

Response to Comment 2

The Registrant acknowledges
the Staff’s comment to respond in writing and file the responses as correspondence. The Registrants confirms it will provide revised
disclosure in its responses, as applicable.

Comment 3 – General

Please supplementally provide
a completed fee table and expenses examples.

Please also confirm that the
acquired fund fees and expenses (AFFE) on the fee table are $0.01 or less. If they are not, please include the AFFE line item per Form
N-1A.

Response to Comment 3

A completed fee table and
expense examples have been attached hereto as Exhibit A. The Fund confirms that it does not expect to incur AFFE and therefore the fee
table will not include an AFFE line item.

Comment 4 – General

Please confirm to the Staff
that the index methodology (the “Methodology”) for the VettaFi Weight Loss Drug Index (the “Index”)
is the same as the one publicly provided on the Index provider’s website.

Response to Comment 4

The Fund notes that the name of the Index has been
revised to VettaFi Weight Loss Drug & Treatment Index. The Fund will provide the Staff with the white paper for the index methodology
in supplemental correspondence.

Comment 5 – Principal Investment Strategies

The Staff requests the disclosure
clearly state whether the Index Provider is affiliated with the Fund, the Adviser or the Sub-Adviser.

Response to Comment 5

The Fund confirms that the Index Provider is not
affiliated with the Fund, the Adviser or the Sub-Adviser. The Fund has revised the last sentence of the first paragraph under “Principal
Investment Strategies,” which now states: “The Index Provider is not affiliated with the Fund, the Adviser, or the Sub-Adviser.”

    - 2 -

Comment 6 – Principal Investment Strategies

The Staff requests that the
Fund move the parenthetical for GLP-1 to the first instance it is used in the disclosure.

Response to Comment 6

The disclosure has been revised in accordance with
the Staff’s comment. Please refer to Exhibit A for the revised disclosure.

Comment 7 – Principal Investment Strategies

The Staff requests that the
Fund provide a list of the companies that currently comprise the Index.

Response to Comment 7

The Fund will provide the list of companies that
currently comprise the Index to the Staff in supplemental correspondence.

Comment 8 – Principal Investment Strategies

Please explain how the Fund’s
80% test via the companies included in the Index may be stated to provide a reasonable definition of securities that comprise an industry.

Please further explain how
these companies and their fortunes and risks are tied to weight loss drugs and treatment.

Response to Comment 8

The Registrant relies upon
the guidance provided by the Commission in the Adopting Release to the recently amended Rule 35d-1 of the Investment Company
Act of 1940 Act, as it relates to funds that track an index. 17 CFR § 270.35d-1; Investment Company Names, Rel. No. IC-35000 (Sep.
20, 2023) (“Adopting Release”). Such guidance notes that terms used in fund names, including index funds, can communicate
an investment focus that creates a reasonable expectation among investors that the fund will hold investments that support that focus.
The Adopting Release states:

“If a fund’s name indicates
an investment focus, such as investments in a specified industry, investors reasonably will expect that there is a meaningful nexus between
fund's investments and the fund's investment focus—regardless of whether the fund executes its strategy by selecting companies in
the specified industry or tracking an index that identifies such companies. As a result, consistent with rule 38a–1, index
funds should generally adopt and implement written policies and procedures reasonably designed to ensure that indexes selected by a fund
do not have materially misleading or deceptive names themselves.”

    - 3 -

The Registrant believes the
Fund is meeting the reasonability standard noted above by investing in securities that comprise the Index. Each constituent in the Index
is deemed to be a “Weight Loss Drug and Treatment Company,” as defined in the Registration Statement. Each constituent of
the Index was selected because (i) the company is either a manufacturer of a weight loss drug or as a company that supports the production
and distribution of a weight loss drug and/or treatment and (ii) the company is selected for inclusion in the Index because of its expectation
to be impacted economically from the development, approval or market adoption of weight loss drugs as a result of the company’s
activities associated with manufacturing or supporting weight loss drugs. Under normal market conditions, the Fund will invest at least
80% of its net assets (plus borrowings for investment purposes) in Weight Loss Drug and Treatment Companies. As a result, the Fund believes
there is a meaningful nexus between the name of the Index and the constituents comprising the Index, and thus, the name of the Index is
not materially misleading or deceptive.

The disclosure has been revised
accordingly. Please refer to Exhibit A for the revised disclosure. As previously noted, the Fund will also provide the Staff with the
list of Index constituents and a copy of the Index methodology under separate cover.

Comment 9 – Principal Investment Strategies

The Staff notes that the use
of the term “Enabler” appears vague and broad. Please revise the disclosure to include examples of “Enablers.”

Response to Comment 9

The disclosure has been revised in accordance with
the Staff’s comment. Please refer to Exhibit A for the revised disclosure.

Comment 10 – Principal Investment Strategies

The Staff notes that the disclosure
states, “The Drug Manufacturer segment comprises 70% of the weight of the Index and the Enablers segment comprises the remaining
30% of the Index at the time of rebalance, with a float market cap weighting allocation within each segment.” Please explain “a
float market cap weighting allocation within each segment” in plain English.

Response to Comment 10

The disclosure has been revised in accordance with
the Staff’s comment. Please refer to Exhibit A for the revised disclosure.

Comment 11 – Principal Risks

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.

    - 4 -

Response to Comment 11

The Fund respectfully declines
the Commission’s request to revise the Fund’s risk disclosures. Form N-1A and the relevant rules thereunder detail what is
required of information in a prospectus and how that information must be presented. No requirement to Form N-1A restricts a fund from
ordering its principal investment risks alphabetically, and the Fund’s current disclosure is consistent with the requirements of
Form N-1A and the rules thereunder. Further, the Fund believes that ordering the risks alphabetically makes it easier for investors to
find applicable risk factors.

Comment 12 – Management of the Fund

The Staff requests that the
Fund disclose whether it intends to include the fee waiver agreement in the fee table. If so, the fee waiver agreement must be contractual
for at least one year.

Response to Comment 12

The Fund does not intend to
include the fee waiver agreement in the fee table.

Comment 13 –Disclaimers

Please provide the information
to be included in the section entitled Disclaimers in your response letter prior to filing the 485B for the Fund.

Response to Comment 13

The disclosure has been revised in accordance with
the Staff’s comment. Please refer to Exhibit A for the revised disclosure.

********

    - 5 -

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

    - 6 -

exhibit
a

AMPLIFY
WEIGHT LOSS DRUG & TREATMENT ETF

Summary Information

INVESTMENT OBJECTIVE

The Amplify Weight Loss Drug
& Treatment ETF seeks investment results that generally correspond to the performance (before fees and expenses) of the VettaFi Weight
Loss Drug & Treatment Index (the “Index”).

FUND FEES AND EXPENSES

This table describes the fees
and expenses that you may pay if you buy, hold, and sell shares of the Fund (“Shares”). You may pay other fees,
such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the table and example below.

Annual Fund Operating Expenses (expenses that you pay each year
as a percentage of the value of your investment)

    Management Fees
    [____]%0.59%

    Distribution and Service (12b-1) Fees
    0.00%

    Other Expenses(1)
    0.00%

    Total Annual Fund Operating Expenses
    [____]%0.59%

 1. Estimate based on the expenses
the Fund expects to incur for the current fiscal year.

EXAMPLE

This example is intended to
help you compare the cost of investing in the Fund with the cost of investing in other funds. This example assumes that you invest $10,000
in the Fund for the time periods indicated and then sell all of your Shares at the end of those periods. The example also assumes that
your investment has a 5% return each year and that the Fund’s operating expenses remain at current levels. This example does not
include the brokerage commissions that investors may pay to buy and sell Shares. Although your actual costs may be higher or lower, your
costs, based on these assumptions, would be:

    1 YEAR

    3 YEARS

    $60
    $189

    $[___]
    $[___]

PORTFOLIO TURNOVER

The Fund pays transaction
costs, such as commissions, when it purchases and sells securities (or “turns over” its portfolio). A higher portfolio turnover
will cause the Fund to incur additional transaction costs and may result in higher taxes when Shares are held in a taxable account. These
costs, which are not reflected in Total Annual Fund Operating Expenses or in the example, may affect the Fund’s performance. Because
the Fund has not yet commenced investment operations, no portfolio turnover information is available at this time.

PRINCIPAL INVESTMENT STRATEGIES

The Fund invests at least
80% of its net assets (plus borrowings for investment purposes) in securities that comprise the Index. VettaFi LLC, a wholly-owned subsidiary
of TMX Group Limited developed and maintains the Index (the “Index Provider”). Amplify Investments LLC is the investment adviser
to the Fund (“Amplify” or the “Adviser”) and [_____]Penserra
Capital Management LLC serves as the investment sub-adviser to the Fund (“[____]Penserra”
or the “Sub-Adviser”). The Fund will generally use a “replication” strategy to achieve its investment objective,
meaning the Fund will generally invest in all of the component securities of the Index. However, the Fund may use a “representative
sampling” strategy, meaning it may invest in a sample of the securities in the Index whose risk, return, and other characteristics
closely resemble the risk, return, and other characteristics of the Index as a whole, when the Fund’s portfolio managers believe
it is in the best interests of the Fund. The Index includes common stocks and/or depositary receipts, such as American Depositary Receipts
(“ADRs”) and Global Depositary Receipts (“GDRs”). The
Index Provider is not affiliated with the Fund, the Adviser, or the Sub-Adviser.

The
Index. The Index is comprised of global companies who are manufacturers in the GLP-1 agonist (glucagon-like
peptide) pharmaceutical business or who enable such business.
GLP-1 agonists (glucagon-like peptide) seek
to lower blood sugar levels and reduce appetite and promote fullness, with the ultimate potential for weight loss.
The Index seeks to identify companies associated with the manufacturing
or supporting of GLP-1 agonists drugs that have the expectation to benefit economically from the development, approval or market adoption
of GLP-1 agonist drugs. The Index begins with a universe
of common stocks issued by companies located in developed countries around the world. From this initial universe, to be eligible
for inclusion in the Index, a company must have a market capitalization greater than or equal to $500 million. For Index inclusion, the
constituents must meet the requirements of the Index to be classified as a GLP-1 agonist “Drug Manufacturer” or “Enabler.”

 · “Drug Manufacturers” are those companies with GLP-1 agonist drugs that have either been launched
or are currently in U.S. Food and Drug Administration (FDA) clinical trials.

 · “Enablers” are those companies engaged in the outsourced development and manufacturing of
GLP-1 agonist drugs, including companies conducting measurement and analysis or other work that supports GLP-1Agonist production and distribution.
Enablers include contract development and manufacturing organizations that
have been contracted for the development and manufacturing of GLP-1 agonist drugs and those companies involved in the distribution or
administration of GLP-1 agonist drugs, including the coordination of prescriptions and drug-delivery mechanisms.

    - 2 -

Each
resulting constituent selected for inclusion in the Index is defined as a “Weight Loss Drug and Treatment Company.” Under
normal market conditions, the Fund will invest at least 80% of its net assets (plus any borrowings for investment purposes) in Weight
Loss Drug and Treatment Companies.

The Drug Manufacturer segment
comprises 70% of the weight of the Index and the Enablers segment comprises the remaining 30% of the Index at the time of rebalance,
with a. Each constituent within a given segment is weighted
according to its float-adjusted market cap weighting
allocation within each segment, which is determined by taking
the company’s price and multiplying it by the number of shares readily available in the market. Within the Drug Manufacturer
segment, a company at the commercial or phase 3 stage are capped at 15% of the Index, and a company at the phase 2 stage or lower stage
are capped at 5% of the Index. A company included in the Enabler segment is capped at a weight of 5% of the Index. Finally, the sum of
all constituent weights greater than 5% must be less than or equal to 45% of the Index. Excess weights above the stated caps are redistributed
to the constituents within the given segment.

The Index is reconstituted
and rebalanced quarterly, after the close of business on the third Friday of each March, June, September and December. For each reconstitution
of the Index