SecProbe.io

CORRESP
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 [Stradley Ronon Logo] 2005 Market Street Suite 2600 Philadelphia,
PA 19103 T: 215.564.8000 F: 215.564.8120 Miranda
Sturgis Partner (215) 564-8131 msturgis@stradley.com August 14, 2025 Filed via EDGAR Mr.
Daniel Greenspan Division of Investment Management U.S.
Securities and Exchange Commission 100 F Street, NE Washington,
DC 20549 Subject: Franklin Templeton ETF Trust (the “Registrant” or the “Trust”)   (File Nos. 333-208873 and 811-23124)       Dear Mr. Greenspan: On
behalf of the Trust, the following are the responses to the U.S. Securities and Exchange Commission (“SEC”)
Staff’s comments conveyed telephonically on July 30, 2025, regarding Post-Effective Amendment Nos.
118/122 to the Trust’s Registration Statement on Form N-1A (the “Amendment”). The Amendment was
filed with the SEC pursuant to Rule 485(a) under the Securities Act of 1933, as amended, on Form N-1A
on June 13, 2025. The sole purpose of the Amendment was to register a new series of the Trust: Franklin
Dividend Growth ETF (the “Fund”). The Trust will file a subsequent Post-Effective Amendment under
Rule 485(b) to update any missing information, respond to Staff comments, and file updated exhibits,
as applicable. Each comment is summarized below, followed by the Fund’s response to the comment. Capitalized
terms not defined herein have the meaning ascribed to such terms in the Amendment. Comment
1 : Please confirm the Fund’s investment objective “to seek to provide long-term
capital” is consistent with its dividend focused investment strategy. Response:
The Trust so confirms. Comment 2 : In the Principal
Investment Strategies section of the Prospectus, please revise the disclosure to describe any additional
portfolio construction parameters or limitations, if applicable, that clarify how the investment manager
identifies and selects investments for the Fund and constructs the Fund’s investment universe, including
any criteria, limitations or standards apply. Response:
 The Trust confirms that the investment process disclosure for the Fund is accurate and declines to revise
the disclosure at this time. Comment 3 : In the Principal
Investment Strategies section of the Prospectus, the disclosure provides: “The Fund invests predominantly
in equity securities, primarily common stock. Equity securities include common stocks,

 preferred stocks, and securities convertible into common
stocks, as well as equity-related instruments and other investments with similar economic characteristics.”
Please clarify what is meant by the reference to “other investments with similar economic characteristics”
in this context (e.g., what investments are intended to be included beyond those specified in the disclosure).
 Response: The above-cited reference to “other investments with similar
economic characteristics” has been removed. Comment 4:
With respect to the principal risk disclosure, please revise as necessary to ensure that all of the risk
factors disclosed in response to Item 9 are also included in the summary section. Specifically, we note
the “ESG Considerations” risk is included in the Item 9 section, but no corresponding risk is included
in the summary section. Response: The Trust confirms
that the principal risks of the Fund are accurately disclosed and respectfully declines to revise the
disclosure as requested at this time. Because ESG considerations are just one facet of the Fund’s investment
process and do not constitute a principal investment strategy or risk of the Fund, the Trust believes
that expanding on the risks related to the incorporation of ESG-related considerations in the Fund’s
portfolio construction process in the Item 9 section without including a related risk factor in the Fund
summary is appropriate and consistent with the requirements of Form N-1A. Comment
5: To the extent investing in emerging markets is a principal strategy and/or principal
risk of investing in the Fund, please include appropriate discussion of that strategy and corresponding
risk in the Prospectus as appropriate. Additionally, please disclose the amount the Fund invests in emerging
markets, including any unique risks associated with such investments. Response:
The Trust confirms that investments in emerging markets securities are not a principal investment strategy
or principal risk of the Fund and accordingly, no further changes have been made in response to this
comment. Comment 6 : In the “Fund Details” section of
the Prospectus, we note the Fund includes disclosure regarding how the investment manager analyzes investment
opportunities with reference to environmental, social and governance (ESG) factors. Please briefly identify
examples of ESG factors and any risks considered. Response:
The Trust notes that ESG-related data, risks or opportunities that may be analyzed and considered as
a part of the Fund’s portfolio construction process are expected to be dynamic and may vary in the
investment manager’s discretion. Accordingly, the Trust respectfully declines to revise the disclosure
as requested at this time. Comment 7: In the Statement
of Additional Information under “Fundamental Investment Policies,” please consider revising the fundamental
investment policy regarding concentration to include a reference to “a particular industry or group
of industries” to more closely align with the statutory language in Section 8(b) of the Investment
Company Act of 1940, as amended (the “1940 Act”). Response:
The Trust respectfully submits that the current policy formulation satisfies applicable disclosure requirements
per Form N-1A and the 1940 Act. By way of additional background, the Trust notes that funds across the
Franklin Templeton complex generally use a uniform formulation of the fundamental investment policy on
concentration where a fund does not have a policy to concentrate in a particular industry or group of
industries, in order to facilitate efficiencies in compliance monitoring and administration. Accordingly,
the Trust respectfully declines to make the requested change at this time. Please do not hesitate to contact me at the above-referenced
telephone number if you have any questions or wish to discuss any of the responses presented above. Very truly yours,

 /s/
Miranda Sturgis Miranda Sturgis cc: Tara Gormel, Franklin Templeton
 Harris Goldblat, Franklin Templeton Steve Feinour,
Stradley Ronon