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            Stradley Ronon Stevens & Young, LLP

            2005 Market Street, Suite 2600

            Philadelphia, PA  19103

            Telephone  215.564.8000

            Fax  215.564.8120

            www.stradley.com

    Kenneth L Greenberg

    Partner

    kgreenberg@stradley.com

    215.564.8149

    October 11, 2024

    VIA EDGAR

    U.S. Securities and Exchange Commission

    Division of Investment Management

    100 F Street, N.E.

    Washington, D.C.  20549-9303

            Attention:

            Christina DiAngelo Fettig

            Alison White, Esq.

            Re:

            Franklin Templeton ETF Trust

            File No. 333-282057

    Dear Ms. DiAngelo Fettig and Ms. White,

    This letter responds to the accounting comments provided by Ms. DiAngelo Fettig on October 4, 2024, and the disclosure comments provided by Ms.
      White on September 30, 2024, to Kenneth L. Greenberg, Esq, counsel to Franklin Templeton ETF Trust (the “Registrant”), regarding the registration statement on Form N-14 (the “Registration Statement”) relating to the proposed Reorganization of the
      Western Asset Total Return ETF (the “Target Fund”) of Legg Mason ETF Investment Trust into the Western Asset Bond ETF (the “Acquiring Fund”) of the Registrant. The Registration Statement was filed via the EDGAR system on September 12, 2024.  We have
      summarized each of your comments below, in the order you provided them, and have set forth the Registrant’s response immediately below each comment.  Defined terms not herein defined shall have the meaning set forth in the Registration Statement.

    Pennsylvania • New Jersey • Delaware • DC • New York • Illinois • California

    A Pennsylvania Limited Liability Partnership

    Ms. Christina DiAngelo Fettig

    Ms. Alison White, Esq.

    U.S. Securities and Exchange Commission

    October 11, 2024

    Page 2

            Disclosure Comments on the Registration Statement:

            1.

            Text:  The last sentence of the answer to the question titled: “Are there any differences in
                principal risks between the Target Fund and the Acquiring Fund?” on page 4 states:

            The Target Fund, but not the Acquiring Fund, discloses principal risks relating to asset class, commodity regulatory, forward roll
              transactions, hedging, illiquidity, investing in ETFs, investing in loans, leverage, national closed market trading, sovereign debt, stock market and equity securities, and valuation.

            Comment:  It is unclear why the Target Fund, but not the Acquiring Fund, has “commodity regulatory” as a principal risk.  What principal investment
              strategy of the Target Fund would trigger the need to disclose commodity regulatory risk?

            Response:  When the Target Fund was launched, it opted to register as a commodity pool operator with the Commodity Futures
              Trading Commission (“CFTC”) to avoid the risk of exceeding the limits of Rule 4.5 (Exclusion for certain otherwise regulated persons from the definition of the term “commodity pool operator”) under the Commodity Exchange Act.  Because the
              Target Fund is registered as a commodity pool operator (“CPO”) with the CFTC, it elected to include commodity regulatory risk as a principal investment risk in its prospectus disclosure.  The Acquiring Fund is not registered as a CPO;
              currently, does not expect to need to register as a CPO as a result of the Reorganization; and accordingly, does not disclose commodity regulatory risk as a principal investment risk.

            2.

            Text:  The second paragraph of the answer to the question titled: “Will the fees and expenses
                of the Acquiring Fund be lower than the fees and expenses of the Target Fund?” on pages 4-5 states:

            The unitary management fee of the Acquiring Fund (0.35%) is lower than the unitary management fee of the Target Fund (0.49%).
              Pursuant to the Acquiring Fund’s investment management agreement, the Acquiring Fund pays FAV a unitary management fee for managing the Acquiring Fund’s assets and FAV pays Western Asset for its services.  FAV reimburses the Acquiring Fund
              for all acquired fund fees and expenses such as those associated the Acquiring Fund’s investment in a Franklin Templeton money fund) and pays all of the ordinary operating expenses of the Acquiring Fund, except for (i) the Bond Fund's
              management fee, (ii) payments under the Acquiring Fund's Rule 12b-1 plan (if any), (iii) brokerage expenses (including any costs incidental to transactions in portfolio securities or instruments), (iv) taxes, (v) interest (including borrowing
              costs and dividend expenses on securities sold short and overdraft charges), (vi) litigation expenses

    Ms. Christina DiAngelo Fettig

    Ms. Alison White, Esq.

    U.S. Securities and Exchange Commission

    October 11, 2024

    Page 3

            (including litigation to which the Acquiring Trust or the Acquiring Fund may be a party and indemnification of the trustees and
              officers with respect thereto), and (vii) other non-routine or extraordinary expenses.  Pursuant to the Target Fund’s investment management agreement, the Target Fund pays FTFA a unitary management fee for all investment management,
              supervisory, administrative and other services reasonably necessary for the operation of the Target Fund, including certain distribution services (provided pursuant to a separate distribution agreement) and investment advisory services
              (provided pursuant to separate subadvisory agreements).  The Target Fund is responsible for paying interest expenses, taxes and governmental fees, brokerage expenses, costs of borrowing money (including interest expenses), future 12b-1 fees
              (if any), acquired fund fees and expenses, extraordinary expenses (such as litigation and indemnification expenses) and the management fee payable to FTFA under the management agreement.

            Comments:

            (a)

            Numeral (i) in the third sentence refers to the “Bond Fund.”  Change that reference to the “Acquiring Fund.”

            (b)

            Please disclose any differences between what is included in and excluded from the unitary management fee of the Target Fund and
              Acquiring Fund.

            Responses:

            (a)

            The reference to the “Bond Fund” has been removed.

            (b)

            Revised as requested.

            3.

            Text:  The first sentence of the first paragraph under the question titled: “Who will pay the
                costs in connection with the Reorganization” on page 6 states:

            The estimated cost of the Reorganization is expected to be approximately $233,000, which is proposed to be allocated 75% to Fund
              management and 25% to the Target Fund.

            Comment:  Confirm whether the allocation will remain unchanged if the Reorganization is not effected.

            Response:  The Registrant confirms that the allocation will remain unchanged if the Reorganization is not effected, and
              disclosure to that effect has been added to the Prospectus/Proxy Statement.

    Ms. Christina DiAngelo Fettig

    Ms. Alison White, Esq.

    U.S. Securities and Exchange Commission

    October 11, 2024

    Page 4

            4.

            Text:  The question titled: “How do the performance records of the Funds compare?” on
              page 12.

            Comment:  Performance format should meet the requirements of Form N-1A.

            Response:  The performance information in the Prospectus/Proxy Statement is intended to supplement the
              performance information provided in the statutory prospectus of each Fund.  The statutory prospectus of the Target Fund and the Acquiring Fund are each incorporated by reference into the Prospectus/Proxy Statement.  In addition, the statutory
              prospectus of the Acquiring Fund will accompany the Prospectus/Proxy Statement.

            5.

            Text:  The section titled: “REASONS FOR THE REORGANIZATION” on page 14.

            Comment:  Please provide background as to why the Board considered the Reorganization in
              the first place.  Also, provide disclosure in the Summary section that addresses the reasons driving the Reorganization and how the transaction is designed to address those reasons.

            Response:  Revised as requested.

            6.

            Text:  The sentence under the section titled: “80% Investment Policy” in the table on page 19 regarding the
              Target Fund states:

            Under normal market conditions, the Fund will seek its investment objective by investing at least 80% of its assets in a portfolio
              comprised of fixed income securities, debt instruments, derivatives, equity securities of any type acquired in reorganizations of issuers of fixed income securities or debt instruments (“work out securities”), non-convertible preferred
              securities, warrants, cash and cash equivalents, foreign currencies, and exchange-traded funds (“ETFs”) that provide exposure to these investments (“Principal Investments”). Debt instruments include loans and similar debt instruments.

            Comment:  Clarify whether the 80% investment policy of the Target Fund applies to net or total assets.  If it is net assets, then confirm whether
              it includes borrowing for investment purposes.

            Response:  Clarifying language has been added to indicate that the Target Fund’s 80% investment policy is 80% of
                its net assets (including borrowing for investment purposes).

    Ms. Christina DiAngelo Fettig

    Ms. Alison White, Esq.

    U.S. Securities and Exchange Commission

    October 11, 2024

    Page 5

            7.

            Text:  The first sentence of the paragraph under the question titled: “How will proxies be
                solicited” on page 33 states:

            EQ Fund Solutions, LLC, a professional proxy solicitation firm (the “Solicitor”), has been engaged to assist in the solicitation of
              proxies, at an estimated cost of approximately $31,520 which will be borne by FTFA and FAV.

            Comment:  Confirm supplementally whether the cost of solicitation is not included in the cost of the Reorganization which is being split 75% to
              Fund management and 25% to the Target Fund.

            Response:  The Registrant confirms that the cost of solicitation is not included in the cost of the Reorganization.

            8.

            Text:  The second sentence under the heading titled: “PRINCIPAL HOLDERS OF SHARES” at the bottom of page 35 states:

            As of the Record Date, the Acquiring Fund was not operational and, therefore, had no shareholders.

            Comment:  As the Acquiring Fund commenced operations on September 19, 2023, revise the sentence to provide information on the beneficial ownership
              of the Acquiring Fund.

            Response:  Revised as requested.

            Proxy Card Comment

            9.

            Text:  The last sentence of the second paragraph on the second page of the proxy card states:

              If no specification is made for the proposal, this proxy shall be voted FOR.

            Comment:  The text should be bolded.

            Response:  Revised as requested.

    Ms. Christina DiAngelo Fettig

    Ms. Alison White, Esq.

    U.S. Securities and Exchange Commission

    October 11, 2024

    Page 6

            Accounting Comments on the Registration Statement:

            Prospectus/Proxy Statement Accounting Comments

            1.

            Text:  The answer to the question on page 3 of the Summary titled: “What am I being asked to
                vote upon?” states:

            Shareholders of the Target Fund are being asked to approve the Plan between the Target Trust, on behalf of the Target Fund, and the
              Acquiring Trust, on behalf of the Acquiring Fund, that provides for: (1) the acquisition of substantially all of the assets (net of any liabilities) of the Target Fund by the Acquiring Trust, on behalf
              of the Acquiring Fund, in exchange solely for full shares of beneficial interest, with no par value, of the Acquiring Fund (the “Acquiring Fund Shares”) and cash (in lieu of fractional shares, if any), (2) the issuance of shares of the
              Acquiring Fund and cash (in lieu of fractional shares, if any) to the Target Fund and the distribution of Acquiring Fund Shares to the holders of shares of beneficial interest, with a par value of $0.00001, of the Target Fund (the “Target
              Fund Shares”) and cash (in lieu of fractional shares, if any), according to their respective interests in the Target Fund, and (3) the complete liquidation and dissolution of the Target Fund.  [emphasis added]

            Comment:  The answer states that “substantially all” of the assets of the Target Fund will be acquired by the Acquiring Trust on behalf of the
              Acquiring Fund. Explain supplementally the use of the phrase “substantially all of the assets.”

            Response:  The reference to “substantially all” aligns with the definition of a “merger”
              under Rule 17a-8 under the Investment Company Act of 1940, as amended, upon which the Registrant is relying to effect the Reorganization.  The reference to “substantially all” also is consistent with the requirements for a tax-free Reorganization under Section 368 of the Internal Revenue Code of 1986, as amended. The Registrant believes that this disclosure is appropriate because it
                provides additional flexibility under circumstances where certain assets cannot be transferred in connection with a merger.  Accordingly, the Registrant will retain the phrase “substantially all”.  For the Staff’s information, the
                Registrant notes that it currently anticipates that all assets of the Target Fund will be transferred to the Acquiring Fund in connection with the Reorganization.

      Ms. Christina DiAngelo Fettig

      Ms. Alison White, Esq.

      U.S. Securities and Exchange Commission

      October 11, 2024

      Page 7

            2.

            Text:  The second paragraph of the answer to the question titled: “Will
                the fees and expenses of the Acquiring Fund be lower than the fees and expenses of the Target Fund?” on pages 4-5 states:

            The unitary management fee of the Acquiring Fund (0.35%) is lower than the unitary management fee of the Target Fund (0.49%).
              Pursuant to the Acquiring Fund’s investment management agreement, the Acquiring Fund pays FAV a unitary management fee for managing the Acquiring Fund’s assets and FAV pays Western Asset for its services.  FAV reimburses the Acquiring Fund
              for all acquired fund fees and expenses such as those associated the Acquiring Fund’s investment in a Franklin Templeton money fund) and pays all of the ordinary operating expenses of the Acquiring Fund, except for (i) the Bond Fund's
              management fee, (ii) payments under the Acquiring Fund's Rule 12b-1 plan (if any), (iii) brokerage expenses (including any costs incidental to transactions in portfolio securities or instruments), (iv) taxes, (v) interest (including borrowing
              costs and dividend expenses on securities sold short and overdraft charges), (vi) litigation expenses (including litigation to which the Acquiring Trust or the Acquiring Fund may be a party and indemnification of the trustees and officers
              with respect thereto), and (vii) other non-routine or extraordinary expenses.” Purs