SecProbe.io

CORRESP
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CORRESP

 Stradley Ronon Stevens & Young, LLP

 2005 Market Street

Suite 2600

 Philadelphia, PA 19103

Telephone 215.564.8000

 Fax
215.564.8120

 www.stradley.com

 J. Stephen Feinour, Jr.

 (215)
564-8521

 jfeinourjr@stradley.com

February 5, 2025

 Filed via EDGAR

 Ms. Karen Rossotto

 U.S. Securities and Exchange
Commission

 100 F Street, NE

 Washington, DC 20549

 Subject:

 Legg Mason ETF Investment Trust (the “Trust”)

(File Nos. 333-206784; 811-23096)

 Dear Ms. Rossotto:

On behalf of the Trust, submitted herewith via the EDGAR system are the responses to the comments of the staff (the “Staff”) of the
U.S. Securities and Exchange Commission (the “Commission”) provided via telephone with regard to Post-Effective Amendment Nos. 147/150 to the Trust’s Registration Statement on Form N-1A (the “Amendment”) related to the
ClearBridge Dividend Strategy ESG ETF (to be renamed Franklin ClearBridge Enhanced Income ETF) series of the Trust (the “Fund”), which was filed with the Commission on October 9, 2024 under the Securities Act of 1933 (the “1933
Act”) and the Investment Company Act of 1940 (the “1940 Act”). The Staff’s comments are summarized below, followed by the Trust’s responses thereto. Terms not defined herein have the meaning set forth for that term in the
Amendment.

 1. Comment: In the Fund’s principal investment strategies sections of the Prospectus, please disclose the specific types of
options the Fund will use (such as, for example, naked options or covered options). Please also disclose the expected duration of the options in either the Item 4 or Item 9 principal investment strategies section of the Prospectus.

Response: The Trust has added clarifying disclosure to the principal investment strategies sections of the Prospectus in response to
this comment.

 2. Comment: The second sentence of the third paragraph in the Item 4 and Item 9 principal investment strategies sections
of the Prospectus states as follows: “The options overlay strategy will consist of selling-to-open and buying-to-close call options based upon U.S. large capitalization equity indices.” Please review this description of
the options overlay strategy, including in particular the disclosure regarding “selling-to-open” and “buying-to-close” call options, for consistency with the Fund’s stated investment strategy of “selling call options to
generate income from premiums received” and ensure that the disclosure is representative of the Fund’s investment strategy.

 Response: The Trust has revised the above-referenced disclosure as follows:

The options overlay strategy will consist of selling-to-open call options (i.e., writing a call option to open an option
position) and buying-to-close such call options (i.e., closing out the open option position prior to the expiration of the written option) based upon U.S. large capitalization equity
indices (such as the S&P 500® Index).

 3. Comment: The
Fund’s principal investment strategies disclosure states that the equity securities in which the Fund may invest include securities of other investment companies. Please disclose the types of other investment companies in which the Fund may
invest in as part of its principal investment strategy. If investing in other investment companies will not be a principal investment strategy of the Fund, please remove this reference from the principal investment strategies sections of the
Fund’s Prospectus.

 Response: The Trust has removed the reference to investments in other investment companies from the
Item 4 and Item 9 principal investment strategies sections of the Prospectus.

 4. Comment: The Fund’s principal investment
strategies disclosure states that the equity securities in which the Fund may invest include convertible securities. If the Fund’s investments in convertible securities will include contingent convertible securities, please disclose this in the
Fund’s principal investment strategies sections of the Prospectus and advise the Staff of the extent of such investments.

Response: The Trust has removed the reference to convertible securities from the Item 4 and Item 9 principal investment
strategies sections of the Prospectus as well as the corresponding risk for convertible securities in the Item 9 risk section.

 5. Comment:
The Fund’s principal investment strategies disclosure states that the Fund may invest in equity securities of foreign issuers. If these investments may include emerging market issuers, please also disclose that.

Response: The Fund does not currently expect to invest in emerging market issuers as a principal investment strategy and, therefore,
has not included disclosure regarding such investments in the Fund’s principal investment strategies.

 6. Comment: Please explain briefly what
FLexible EXchange Options (“FLEX Options”) are in the Item 4 section of the Fund’s Prospectus.

 Response: The
Trust has added the requested disclosure.

 7. Comment: The Fund appears to focus in the information technology and financial services sectors.
Consider noting the Fund’s sector focus in the principal investment strategies sections of the Prospectus and adding relevant risk disclosure to the principal risks sections of the Prospectus.

Response: The Trust has added the following disclosure in the Fund’s principal investment strategies sections:

As of the date of this Prospectus, the top sectors represented by the fund’s underlying investments were financial services and
information technology. These sectors may change over time.

 The Trust has also added principal risk disclosure corresponding to these sectors in the
Item 4 fund summary section. The Trust notes that the Fund already includes risk disclosure for the financial services and information technology sectors in the Item 9 risk section of the Prospectus.

8. Comment: In the second bullet point under the second paragraph of the principal investment strategies sections of the Prospectus, the disclosure
indicates that the Fund’s portfolio managers may focus on companies that have the “potential” to significantly grow their dividends. Please disclose if these securities will be counted towards the Fund’s 80% investment policy
and, if so, please disclose how the Fund will determine that these securities will be income generating for purposes of calculating compliance with its 80% investment policy.

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 Response: The Trust has removed the Fund’s 80% investment policy, as the term
“enhanced income” as used in the Fund’s name does not connote a focus in a particular type of investment, or investments that have, or whose issuers have, particular characteristics, within the meaning of the 2023 amendments to Rule
35d-1 under the 1940 Act (Investment Company Names, Investment Company Act Release No. 35000 (September 20, 2023)). The Staff in its 2025 Frequently Asked Questions release concerning the 2023 amendments made clear (in the response to question
6) that use of the term “income” in a fund’s name, when the term “income” does not refer to “fixed income” securities, generally suggests that the fund emphasizes the achievement of income as a portfolio-wide
result, and in these circumstances, would not, alone, require the fund to adopt an 80% investment policy. See Division of Investment Management: Frequently Asked Questions: 2025 Names Rule FAQs (January 8, 2025) (“2025 Names Rule
FAQs”). Accordingly, based on the 2025 Names Rule FAQs, the Trust respectfully submits that the Fund’s use of “enhanced income” in its name does not trigger the requirements of Rule 35d-1 under the 1940 Act and has therefore
removed the 80% investment policy as a result of this guidance. The Trust is also cognizant that, pursuant to Section 35(d) of the 1940 Act, a fund’s name may not otherwise be materially deceptive or misleading. The Trust believes that the
Fund’s principal investment strategy disclosure appropriately reflects the terms in the Fund’s name.

 The Trust also notes that
the Fund’s investments in companies that have the “potential” to significantly grow their dividends includes only those companies that are already paying dividends (and are expected to grow such dividends in the future) and is
consistent with the Fund’s principal investment strategies. In particular, the Trust notes the principal investment strategy disclosure that “Under normal market conditions, the fund will pursue an enhanced equity income strategy by
(1) investing primarily in dividend-paying equity securities and (2) “enhancing” income through the employment of an options overlay by writing (selling) U.S. exchange-traded call options based upon U.S. large capitalization
equity indices (such as the S&P 500® Index).”

 9. Comment: The Fund’s
principal investment strategies disclosure states that the Fund will employ “an options overlay by writing (selling) U.S. exchange-traded call options based upon U.S. large capitalization equity indices.” Please disclose the specific
equity indices that the options will be based upon. This disclosure can be included in the Item 9 section of the Fund’s Prospectus if that is preferable.

Response: The Trust has added the requested disclosure.

10. Comment: The Fund’s principal investment strategies disclosure states as follows: “The subadviser monitors the value of short call
options and seeks to buy-to-close short call options when the subadviser determines that the risk reward characteristics are no longer favorable.” Please explain what is meant by the “risk reward characteristics” referenced
in the disclosure.

 Response: The Trust has revised the above-referenced disclosure as follows:

The subadviser Franklin MOST monitors the value of short call options and seeks
to buy-to-close short call options when Franklin MOST the subadviser determines that the risk reward characteristics are no longer favorable. (e.g., to seek to minimize
potential losses if Franklin MOST determines, based on a risk-based analysis, that the value of the reference index is likely to exceed the exercise price at the time of the option expiry).

11. Comment: In connection with the last paragraph of the Fund’s principal investment strategies disclosure, please explain in plain English how
the Fund’s call options may hedge against declines in down markets but constrain the Fund’s performance in up markets.

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 Response: The Trust has revised the above-referenced disclosure as follows:

During periods in which the U.S. equity markets are flat, declining or modestly rising it is expected that the portfolio may outperform a
similar portfolio that did not engage in a call selling strategy because of the premiums received from writing call options. However, in rising markets (where the aggregate appreciation of the reference index over the
option exercise price exceeds the income from premiums) it is expected the portfolio could significantly underperform a similar portfolio that did not engage in a call selling strategy.

12. Comment: In the Fund’s “Dividend-paying stock risk” in the Principal Risks sections of the Fund’s Prospectus, briefly address
some of the factors that might cause dividend-paying stocks to not participate in broad market advances to the same degree as other stocks.

Response: The Trust has revised “Dividend-paying stock risk” as follows:

Dividend-paying stock risk. There is no guarantee that the issuers of the stocks held by the fund will pay dividends in the future
or that, if dividends are paid, they will remain at their current levels or increase over time. The fund’s emphasis on dividend-paying stocks could cause the fund to underperform similar funds that invest without consideration of a
company’s track record of paying dividends or ability to pay dividends in the future. Dividend-paying stocks can fall out of favor with the market (such as in periods of rising interest rates, high inflation and/or strong economic
growth) and may not participate in a broad market advance to the same degree as other stocks. , and a A sharp rise in interest rates or economic downturn or other market or
company-specific developments could cause a company to reduce or eliminate its dividend.

 13. Comment: The first sentence of the Fund’s
“Option writing risk” in the Principal Risks sections of the Fund’s Prospectus states as follows: “Writing (selling) call options limits the opportunity to profit from an increase in the market value of stocks in exchange
for up-front cash (the premium) at the time of selling the call option.” Please briefly explain why this is the case in plain English.

Response: The Trust refers the Staff to the response to comment 11 above, as well as the disclosure included as part of the Fund’s
principal investment strategies, which provides as follows: “As the seller of the call options, the fund will receive cash (the “premium”) from the purchaser. At each index option expiration, if the value of the reference index
exceeds the fixed price of the option (the “exercise price”), the fund is required to pay the purchaser a cash amount equal to that difference. The premium, the exercise price and the market price of the reference index determine the gain
or loss realized by the fund as the seller of the call option.” The Trust believes that this disclosure, along with the changes described in response to comment 11 above, explain in plain English that, in return for the receipt of the premiums,
the Fund will give up the opportunity to benefit from potential increases in the market value of the reference index above the exercise price, in which case the Fund would be required to pay the option purchaser a cash amount equal to that
difference.

 14. Comment: The first sentence of the Fund’s “Small fund risk” in the Principal Risks sections of the Fund’s
Prospectus states as follows: “When the fund’s size is small, the fund may experience low trading volume and wide bid/ask spreads.” Please explain here or where appropriate elsewhere in the Prospectus what the “bid/ask
spread” is.

 Response: The Trust refers the Staff to the disclosure provided under the section titled “Purchase and sale
of fund shares” in the Item 4 section of the Prospectus, which provides as follows: “When buying or selling shares in the secondary market, you may incur costs attributable to the difference between the highest price a buyer is
willing to pay to purchase shares of the fund (bid) and the lowest price a seller is willing to accept for shares of the fund (ask) (the “bid-ask spread”).” The “bid/ask spread” is also

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described under the risk titled “Costs of buying or selling fund shares” under the section titled “More on risks of investing in the fund” and in the section titled
“Shareholder information—Share prices are reported in dollars and cents per share” in the Item 9 section of the Prospectus. As such, the Trust has not made any changes in connection with the above request.

15. Comment: Please include corresponding risk disclosure for each type of investment that is included as part of the principal investment strategy of
the Fund (for example, preferred securities, convertible securities, depositary receipts, warrants, rights, securities of other investment companies (including exchange-traded funds), and real estate investment trusts (“REITs”)).

Response: Please see the responses to comments 3 and 4 above regarding the Trust’s removal of the references to convertible
securities and securities of other investment companies in the principal investment strategies sections. The Trust has also removed the references to preferred securities, warrants and rights in the Item 4 and Item 9 principal investment
strategies sections of the Prospectus as well as the corresponding risks for convertible securities and warrants and rights in the Item 9 risk section. The Trust has added principal risk disclosure regarding depositary receipts in the
Item 4 and Item 9 risk sections of the Prospectus. The Trust has also added principal risk dis