SecProbe.io

CORRESP
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[Chapman
and Cutler LLP Letterhead]

January 17, 2025

VIA EDGAR CORRESPONDENCE

Valerie J. 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 Securities and Exchange Commission (the “Commission”) on January 15, 2025 (the “Registration Statement”).
The Registration Statement relates to the Amplify Video Game Leaders ETF (formerly Amplify Video Game 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 – General

Please supplementally provide
an index methodology for the VettaFi Video Game Leaders Index.

Response to Comment 1

Please see Exhibit B.

Comment 2 – Fee Table

If there is a fee waiver or
recoupment, please disclose.

Response to Comment 2

The Fund will not utilize
any fee waiver or recoupment arrangements.

Comment 3 – Principal Investment Strategies

The Staff notes the Fund’s
updated name implicates the Names Rule. Please note that the Fund must have a name that indicates that it is an index fund and this Fund
does not. The Fund must have an 80% policy associated with the Fund’s name, not just the index. Please clarify the current disclosure
in the “Principal Investment Strategies” section.

Response to Comment 3

The prospectus has been revised
in accordance with the Staff’s comment, as reflected in Exhibit A.

Comment 4 – Principal Investment Strategies

Does the Fund use derivatives
to gain exposure to the VettaFi Video Game Leaders Index?

Response to Comment 4

No, the Fund invests solely
in equity securities.

Comment 5 – General

Please fill in blanks, brackets
and otherwise missing information sufficiently in advance of effectiveness for review.

Response to Comment 5

The Fund confirms it will
endeavor to provide the Staff with responses sufficiently in advance of effectiveness for its review.

Comment 6 – Principal Risks

The “Principal Investment
Strategies” section currently states, “As
of [   ], the Index is concentrated in the [   ].” Please specify the industry in which the Index concentrates.

Response to Comment 6

The prospectus has been revised
in accordance with the Staff’s comment, as reflected in Exhibit A.

    - 2 -

Comment 7 – 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.

Response to Comment 7

The Fund respectfully declines
the Staff’s comment to revise the Fund’s risk disclosure so that the principal risks appear in alphabetical order. No requirement
of 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. Further, the Fund believes ordering the risks alphabetically makes it easier for investors
to find applicable risk factors.

Comment 8 – Principal Risks

The Staff notes there is currently
a “Japan Investment Risk” in the “Principal Risks” section. Please include related disclosure in the “Principal
Investment Strategies” section.

Response to Comment 8

The prospectus has been revised
in accordance with the Staff’s comment, as reflected in Exhibit A.

Comment 9 – Performance

The Staff notes there has
been a change in the index. If a fund uses an index that is different than the Index from the immediately preceding year, please explain
the reason for the change. Additionally, please show the new and former indices in the performance table. See Form N-1A Item (4).

Response to Comment 9

The Fund notes that the VettaFi
Video Game Leaders Index is new and therefore performance is not currently available. The performance section of the Fund has been revised
to note this and the Fund confirms it will include the performance information for both the new index and the prior index on a going forward
basis once performance information is available. Please refer to Exhibit A for the revised disclosure. With respect to the reason
for the change in index, Amplify Investments believes the Fund and its shareholders will benefit from a more narrowly focused index that
provides increased exposure to gaming companies, including those involved in the development and publishing of video games, in order to
better align with the Fund’s investment objective.

Comment 10 – Additional Information about the Fund’s
Strategies and Risks

The “Additional Information
about the Fund’s Strategies and Risks” section currently states, “This policy may be changed by the Board without shareholder
approval upon 60 days’ prior notice.” Please add the phrase “written notice” to this sentence to be more accurate.

Response to Comment 10

The prospectus has been revised
in accordance with the Staff’s comment, as reflected in Exhibit A.

********

    - 3 -

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

    - 4 -

Exhibit
A

Amplify ETF Trust

Amplify Video Game Leaders ETF

(formerly Amplify Video Game Tech ETF)

(NYSE Arca — GAMR)

PROSPECTUS

January 28, 2025

Amplify Video Game Leaders ETF (the “Fund”)
is a series of Amplify ETF Trust (the “Trust”) and a passively-managed exchange-traded fund organized as a separate series
of a registered investment management company. The Fund lists and principally trades its shares on NYSE Arca, Inc. (“NYSE Arca”
or the “Exchange”). Market prices of shares of the Fund may differ to some degree from their net asset value. The Fund issues
and redeems shares at net asset value only in large blocks of shares called “Creation Units.” Except when aggregated in Creation
Units, shares of the Fund are not redeemable securities of the Fund.

The SEC has not approved or disapproved these
securities or passed upon the accuracy or adequacy of this prospectus. Any representation to the contrary is a criminal offense.

Contents

    Summary Information
    3

    Additional Information About the Fund’s Strategies and Risks
    16

    Fund Investments
    17

    Additional Information Regarding Fund Risks
    18

    Portfolio Holdings
    27

    Management of the Fund
    27

    How to Buy and Sell Shares
    30

    Dividends, Distributions and Taxes
    31

    Distribution Plan
    35

    Net Asset Value
    36

    Disclaimers
    38

    Fund Service Providers
    38

    Premium/Discount Information
    38

    Other Information
    39

    Financial Highlights
    40

    2

AMPLIFY
VIDEO GAME LEADERS ETF

Summary Information

INVESTMENT OBJECTIVE

The Amplify Video Game Leaders
ETF seeks investment results that generally correlate (before fees and expenses) to the total return performance of the VettaFi Video
Game Leaders 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
    0.00%

    Total Annual Fund Operating Expenses
    0.59%

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
    5 YEARS
    10 YEARS

    $60
    $189
    $329
    $738

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. During
the fiscal year ended September 30, 2024, the Fund’s portfolio turnover rate was 52% of the average value of its portfolio.

    3

PRINCIPAL INVESTMENT STRATEGIES

Under normal circumstances,
the Fund will invest at least 80% of its net assets (plus borrowings for investment purposes) in equity securities in the video gaming
industry that comprise the Index. The Fund uses a “passive” or indexing approach to try to achieve the Fund’s investment
objective. Unlike many investment companies, the Fund does not try to “beat” the Index and does not seek temporary defensive
positions when markets decline or appear overvalued. The Fund uses a replication strategy. A replication strategy is an indexing strategy
that involves investing in the securities of the Index in approximately the same proportions as in the Index. However, the Fund may utilize
a representative sampling strategy with respect to the Index when a replication strategy might be detrimental to shareholders, such as
when there are practical difficulties or substantial costs involved in compiling a portfolio of equity securities to follow the Index,
in instances in which a security in the Index becomes temporarily illiquid, unavailable or less liquid, or as a result of legal restrictions
or limitations (such as tax diversification requirements) that apply to the Fund but not the Index.

Amplify Investments LLC is
the investment adviser to the Fund (“Amplify” or the “Adviser”) and Penserra Capital Management LLC (“Penserra”
or the “Sub-Adviser”). VettaFi, LLC developed and maintains the Index (the “Index Provider”). The Index Provider
is not affiliated with the Fund, the Adviser or the Sub-Adviser.

The Index. The Index
is constructed to track the performance of a concentrated portfolio of companies that are components of the video gaming value-chain (i.e.,
the ecosystem of creating and distributing video games). These companies include those involved in game development and publishing, mobile
games, online games, gaming graphic processing units (“GPUs”), development platforms and supporting software, hardware
and peripherals (i.e., a keyboard, mouse or monitor), and the metaverse (collectively, “Gaming Activities”).

The initial universe of the
Index begins with companies that are listed on an exchange in a major country that meet the following criteria: (i) an average daily trading
value of $1 million USD; (ii) a free float market capitalization percentage of 20%; and (iii) a full market capitalization of $250 million
USD. For additional information regarding the eligible exchanges, please see “Additional Information About the Fund’s Strategies
and Risks.” From this initial universe, companies are considered for inclusion if they meet one or more of the following categories:

 1. The company derives at least 50% of its revenues from Gaming Activities;

 2. The company has at least a 20% market share in either game development or systems, mobile gaming or gaming
GPUs or hardware; or

 3. The company is within the top ten based on revenue for game development and publishing, mobile gaming,
development platforms and supporting software, hardware and peripherals, or metaverse.

From this eligible universe,
the Index Provider selects the top twenty (20) companies based on float market capitalization for inclusion in the Index.

    4

The Index constituents are
weighted based on a banded float modified market capitalization ranking. To determine weightings, constituents are divided into three
bands based on the float modified market capitalization of each company. The top five companies each receive a 10% weighting, the companies
ranking 6-10 each receive a 5% weighting and the bottom 10 companies each receive a 2.5% weighting.

The Index is reconstituted
and rebalanced quarterly in March, June, September, and December. The composition of the Index and the constituent weights are determined
on calendar quarters on the open of trading following the third Friday of the month. Component changes are made on the open of trading
following the third Friday of March, June, September and December. The Fund rebalances its portfolio in accordance with its Index, and,
therefore, any changes to the Index’s rebalance schedule will result in corresponding changes to the Fund’s rebalance schedule.

As of September 30, 2024,
the Index had 90 constituents and had significant exposure to Japanese issuers.

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 December 31, 2024, the Index is concentrated in the video gaming industry.

Diversification Status.
The Fund is classified as “non-diversified” under the Investment Company Act of 1940, as amended (the “1940
Act”).

PRINCIPAL RISKS OF INVESTING IN THE FUND

You could lose money by investing
in the Fund. An investment in the Fund is not a deposit of a bank and is not insured or guaranteed by the Federal Deposit Insurance Corporation
or any other governmental agency. There can be no assurance that the Fund’s investment objective will be achieved.  The principal
risks are presented in alphabetical order to facilitate finding particular risks and comparing them with other funds. Each risk summarized
below is considered a “principal risk” of investing in the Fund, regardless of the order in which it appears.

Concentration Risk. The
Fund’s investments will be concentrated in an industry or group of industries to the extent the Index is so concentrated. To the
extent the Fund invests more heavily in particular industries, groups of industries, or sectors of the economy, its performance will be
especially sensitive to developments that significantly affect those industries, groups of industries, or sectors of the economy, and
the value of Fund shares may rise and fall more than the value of shares that invest in securities of companies in a broader range of
industries or sectors.

    5

Cybersecurity
Risk. The Fund is susceptible to operational risks through breaches in cyber security. A breach in cyber security refers to both intentional
and unintentional events that may cause the Fund to lose proprietary information, suffer data corruption or lose operational capacity.
Such events could cause the Fund to incur regulatory penalties, reputational damage, additional compliance costs associated with corrective
measures and/or financial loss. Cyber security breaches may involve unauthorized access to the Fund’s digital information systems
through “hacking” or malicious software coding, but may also result from outside attacks such as denial-of-service attacks
through efforts to make network services unavailable to intended users. In addition, cyber security breaches of the Fund’s third-party
service providers, such as its administrator, transfer agent, custodian, or sub-adviser, as applicable, or issuers in which the F