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[Chapman
and Cutler LLP Letterhead]

September 22, 2025

VIA EDGAR CORRESPONDENCE

Daniel Greenspan

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. Greenspan,

This letter responds to your
additional 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 18, 2025 (the “Registration
Statement”). The Registration Statement relates to the Amplify Ethereum 3% Monthly Option Income ETF (a “Fund”
or the “Option Income ETF”) and Amplify Ethereum Max Income Covered Call ETF (a “Fund” or the “Covered
Call ETF”, and collectively with the Option Income ETF, the “Funds”), each a series of the Trust. Capitalized
terms used herein, but not otherwise defined, have the meanings ascribed to them in the applicable Registration Statement. References
to a “Fund” and to changes to be made to a Fund’s Registration Statement shall be deemed to refer to each Fund unless
otherwise stated below.

Comment
1 – Amplify Ethereum 3% Monthly Option Income ETF and Amplify Ethereum Max Income Covered Call ETF – General

Please review the use of the
term “income” through the Registration Statement. Please ensure the term is used appropriately.

Response to Comment 1

The Registrant acknowledges
the Staff’s comment and in its review of references to “income” has revised disclosure to consistently refer to “option
premium income” throughout the Registration Statements as applicable.

Comment
2 – Amplify Ethereum 3% Monthly Option Income ETF – Principal
Investment Strategies

Please provide a supplemental
explanation regarding the reasonableness of the 36% annualized option premium and the 3% monthly premium target in light of current anticipated
market conditions. Additionally, please confirm that, should market conditions change sufficiently to alter underlying assumptions, the
Registrant will reevaluate the Fund’s strategies and name accordingly.

Response to Comment 2

The
Registrant confirms that the Adviser has performed an analysis of the annualized option premium income and monthly option premium income
that it reasonably believes will be available to the Fund. The Fund’s modeling to achieve the annualized option premium income and
monthly option premium has been conducted across a variety of market environments, including periods of low and high volatility, to ensure
that the target is reasonably attainable under different market conditions.

The
Registrant further confirms it will periodically assess the reasonableness of the target and the Fund will revise its strategy and name
should market conditions change such that achieving the stated target is no longer reasonable.

Comment
3 – Amplify Ethereum 3% Monthly Option Income ETF and Amplify Ethereum Max Income Covered Call ETF – Principal
Investment Strategies

Please revise the disclosure
to make clear that the Target Option Premium is not intended to be an indication of the Fund’s future performance.

Response to Comment 3

In
accordance with the Staff’s comment, the following disclosure has been added to the section entitled “Principal Investment
Strategies:”

The Target Option
Premium is not a projection or guarantee of the Fund’s future performance or total return.

Comment
4 – Amplify Ethereum 3% Monthly Option Income ETF and Amplify Ethereum Max Income Covered Call ETF – Principal
Investment Strategies

Please clarify whether the
Fund is targeting a specific rate of distribution to shareholders as distinguished from the Target Option Premium.

Response to Comment 4

The Fund is not targeting
a specific rate of distribution. While the total distributions paid to shareholders will not be identical to the Target Option Premium,
the other sources of income (such as dividends and interest earned on U.S. Treasuries) are not expected to be material as compared to
the Target Option Premium.

    - 2 -

Comment
5 – Amplify Ethereum 3% Monthly Option Income ETF and Amplify Ethereum Max Income Covered Call ETF – Principal
Investment Strategies

The section entitled “Principal
Investment Strategies” states that there is no guarantee that the Fund will achieve the Target Option Premium in any given investment
period. Please revise the disclosure to also clearly note that there is no guarantee that the Fund will make a distribution in any given
period.

Response to Comment 5

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

Please note
that there is no guarantee the Fund will achieve the Target Option Premium in any given investment period. Additionally, there is no guarantee
that the Fund will make a distribution in any given period

Comment
6 – Amplify Ethereum 3% Monthly Option Income ETF and Amplify Ethereum Max Income Covered Call ETF – Principal
Investment Strategies

Please revise the disclosure
in the section entitled “Principal Investment Strategies” to disclose that distributions to the Fund’s shareholders
may be treated as return of capital in whole or in part.

Response to Comment 6

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

The Fund currently
expects to make distributions on a monthly basis, a portion of which may be considered return of capital. Distributions in excess of the
Fund’s current and accumulated earnings and profits will be treated as a return of capital

Comment
7 – Amplify Ethereum 3% Monthly Option Income ETF and Amplify Ethereum Max Income Covered Call ETF – Principal
Investment Strategies

Please clarify in the disclosure
that, notwithstanding any distributions of premium income or the realization of the Fund’s options strategies, shareholders may
still experience losses if the Fund’s investment exposure to Ethereum ETPs performs poorly. Please also clearly note reaching the
Target Option Premium does not guarantee that shareholders will realize a profit or avoid a loss.

Response to Comment 7

The disclosure has been revised
in accordance with the Staff’s comment as follows:

Notwithstanding
any distributions of premium income or the realization of the Fund’s options strategies, shareholders may still experience losses
if the Fund’s investment exposure to Ethereum ETPs performs poorly.

    - 3 -

Comment
8 – Amplify Ethereum 3% Monthly Option Income ETF and Amplify Ethereum Max Income Covered Call ETF – General

Please supplementally disclose:

 (a) How the Fund’s covered call strategy and options purchases are expected to impact the market or
shares of unaffiliated Ethereum ETPs; and

 (b) Whether any of the Ethereum ETPs are affiliates of the Fund. If so, please supplementally provide a legal
analysis as to why payment of the Ethereum ETP’s management fee complies with Section 17(d)-1.

Response to Comment 8

 (a) The Registrant confirms that it does not anticipate the strategy of either Fund to have a material impact
on the market or shares of unaffiliated Ethereum ETPs. However, the Registrant will monitor the size and frequency of its covered call
writing and options purchases and will evaluate the liquidity of each Fund’s investments under both normal and reasonably foreseeable
stressed conditions to ensure that it does not exceed the available liquidity or capacity of the overall market.

 (b) The Registrant confirms that none of the Ethereum ETPs are affiliates of the Fund or the Adviser.

Comment
9 – Amplify Ethereum 3% Monthly Option Income ETF and Amplify Ethereum Max Income Covered Call ETF – Principal
Investment Strategies

In the section entitled “Ether
Price Exposure,” please include a brief definition of the phrase “digital vault.”

Response to Comment 9

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

Ethereum ETPs are
exchange-traded investment products not registered under the Investment Company Act of 1940, as amended (the “1940 Act”),
that reflect the price of ether, before fees and expenses, by purchasing and storing ether in a digital vault (a secure, institutional-grade
storage solution used to safeguard the Ethereum assets backing the ETP) and issuing exchange-listed shares that correspond to the price
of ether it holds and trade intra-day on a national securities exchange.

    - 4 -

Comment
10 – Amplify Ethereum 3% Monthly Option Income ETF and Amplify Ethereum Max Income Covered Call ETF – Principal
Investment Strategies

Please supplementally explain
the general policies and procedures related to how the Adviser, Administrator and/or Chief Compliance Officer will monitor trades or conflicts
of interest regarding Fund personnel trades of Ethereum made against or ahead of the Fund’s purchase of Ethereum ETPs. Please describe
any changes to the Fund’s code of ethics to take such transactions into account.

Response to Comment 10

The Registrant confirms it
maintains robust policies and procedures to monitor trades and to assess conflicts of interest across all transactions. The Registrant
further confirms that the Adviser’s code of ethics have been updated to apply to transactions in Ethereum or Ethereum-linked investments/derivatives
and that Access Persons, as defined in Rule 17j-1 of the Investment Companies Act, will be required to preclear such transactions. The
updated code of ethics will be filed with each Registration Statement.

Comment
11 – Amplify Ethereum 3% Monthly Option Income ETF and Amplify Ethereum Max Income Covered Call ETF – Principal
Investment Strategies

The Staff notes the following
disclosure set forth in the “Target Option Premium” subsection:

This strategy effectively converts a portion
of the potential upside Ether Price return growth into current income. In a traditional covered call strategy, an investor (such as the
Fund) writes a call option on a security it owns. However, the Fund expects to derive exposure to Ethereum ETPs through the use of Ethereum
ETP Options that use the Ethereum ETPs as the reference asset. This distinction causes the Fund’s strategy to be commonly referred
to as a “synthetic covered call strategy” as opposed to a traditional covered call strategy, because the Fund expects to have
synthetic exposure to the Ether Price through Ethereum ETP Options.

Please clearly state whether
the Fund will favor a synthetic long position or a traditional position.

Response to Comment 11

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

This distinction
causes the Fund’s strategy to be commonly referred to as a “synthetic covered call strategy” as opposed to a traditional
covered call strategy, because the Fund expects to have synthetic exposure to the Ether Price through Ethereum ETP Options. The Fund retains
the flexibility to employ either the traditional covered call strategy or the synthetic covered call strategy.

    - 5 -

Comment
12 – Amplify Ethereum 3% Monthly Option Income ETF and Amplify Ethereum Max Income Covered Call ETF – Principal
Investment Strategies

The Staff notes the “Cayman
Subsidiary” subparagraph states, “Furthermore, the Adviser, as the investment adviser to the Subsidiary, complies with the
provisions of the 1940 Act relating to investment advisory contracts as it relates to its advisory agreement with the Subsidiary.”
Please supplementally confirm that the Investment Advisory Agreement contemplates providing services to the Subsidiary or that the Adviser
will enter into an Investment Advisory Agreement for any services to the Subsidiary.

Response to Comment 12

The Registrant confirms that
the Adviser will enter into an Investment Advisory Agreement for any services to a Subsidiary.

Comment
13 – Amplify Ethereum 3% Monthly Option Income ETF and Amplify Ethereum Max Income Covered Call ETF – Principal
Investment Strategies

With respect to the Subsidiary,
please supplementally confirm:

 (a) Whether the financial statements of the Subsidiary will be consolidated with those of the Fund. If the
financial statements will not be consolidated, please explain;

 (b) Whether the Subsidiary and its Board will agree to inspection by the Staff of the Subsidiary’s books
and records which will be maintained in accordance with Section 31 of the Investment Company Act of 1940 and the rules thereunder;

 (c) That the Subsidiary and its Board will agree to designate an agent for service or process in the United
States; and

 (d) That the wholly-owned Subsidiary’s management fee (including any performance fee) if any will be
included in the “Management Fees” line item of the fee table and that the Subsidiary’s expenses will be included in
the “Other Expenses” line item in the fee table.

Response to Comment 13

 (a) The Registrant confirms the financial statements of a Subsidiary will be consolidated with the Fund’s
financial statements.

 (b) The Registrant confirms any Subsidiary and its Board will agree to inspection of its books and records
by the Staff, which will be maintained in accordance with the Investment Company Act.

 (c) The Registrant confirms any Subsidiary and its Board will designate an agent for service of process in
the United States.

    - 6 -

 (d) The Registrant confirms that the Adviser will assume any Subsidiary’s expenses (and therefore it
is not necessary to include such expenses in “Other Expenses”).

Comment
14 – Amplify Ethereum 3% Monthly Option Income ETF – Statement
of Additional Information

The Staff notes the following
disclosure set forth in the “Investment Objective and Policies” section: “The Fund will not concentrate its investments
in securities of issuers in any industry or group of identified industries, as the term “concentrate” is used in the 1940
Act, except to the extent the Index concentrates in an industry or group of identified industries.” Please confirm this fundamental
policy.

Response to Comment 14

The Registration Statement
has been revised in accordance with the Staff’s comments to reflect that the Fund may invest more than 25% of its assets in investments
that provide exposure to Ethereum.

Comment
15 – Amplify Ethereum Max Income Covered Call ETF – Principal
Investment Strategies

The Staff notes the following
disclosure set forth in the “Principal Investment Strategies” section: “Based on market conditions as of the date of
this Prospectus, the anticipated annualized option premium range is between 50% - 80%. Given market volatility, the actual annualized
option premium received may be significantly higher or lower than the stated range.” If applicable, please disclose the monthly
premium range. Additionally, please provide a set of potential targets associated with the monthly premium range.

Response to Comment 15

The Registrant confirms it
will disclose the monthly premium range in the Registration Statement. The Registrant does not believe factors other than volatility affect
the annual or monthly ranges.

Comment
16 – Amplify Ethereum Max Income Covered Call ETF – Principal
Investment Strategies

Please supplementally explain
to the Staff what assumptions are being made, or are otherwise necessary, in order for the Fund to generate the annualized option premium
range between 50-80%.

Response to Comment 16

The
Registrant confirms that the Adviser has performed an analysis of the annualized option premium income range that it reasonably believes
will be available to the Fund. The Fund’s modeling to achieve the annualized option premium income range has been conducted across
a variety of market environments, including periods of low and high volatility, to ensure that the target is reasonably attainable under
different market conditions.

The
Registrant further confirms it will periodically assess the reasonableness of the target range, and the Fund will revise its strategy
and name should market conditions change such that achieving the stated target range