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        Allison Fumai

    allison.fumai@dechert.com

    +1 212 698 3526 Direct

    +1 698 698 3599 Fax

November 1, 2023

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Attention:     Eileen
Smiley and Kenneth Ellington

 Re: Morgan Stanley ETF Trust (the “Trust”) (File No. 333-274831)

Dear Ms. Smiley and Mr. Ellington:

Thank you for your telephonic
comments regarding the Trust’s registration statement on Form N-14 relating to the Eaton Vance Total Return Bond ETF and Eaton
Vance Short Duration Municipal Income ETF (each, an “Acquiring Fund”), each a series of the Trust, filed with the Securities
and Exchange Commission (the “Commission”) on October 2, 2023 (the “Registration Statement”), in connection
with the transfer of substantially all of the assets of each acquired fund identified below (each, an “Acquired Fund”) to
its corresponding Acquiring Fund in exchange for the assumption of the Acquired Fund’s stated liabilities by the corresponding
Acquiring Fund and shares of the Acquiring Fund having an aggregate net asset value (“NAV”) equal to the aggregate NAV of
the Acquired Fund followed immediately by the distribution by the Acquired Fund to its shareholders of the portion of shares of the Acquiring
Fund to which the shareholder is entitled in complete liquidation of the Acquired Fund, except as noted in the Registration Statement,
(such transactions, a “Reorganization”) subject to approval by shareholders of the corresponding Acquired Fund. The Acquired
Funds and Acquiring Funds are referred to herein together as the “Funds.”

    Acquired
    Fund
    Acquiring
    Fund

    MSIFT
    Core Plus Fixed Income Portfolio
    Eaton
    Vance Total Return Bond ETF

    MSIFT
    Short Duration Municipal Income Portfolio
    Eaton
    Vance Short Duration Municipal Income ETF

The Trust has considered
your comments and has authorized us to make the responses, changes and acknowledgements discussed below relating to the Registration
Statement on its behalf. Below, we describe the changes made to the Registration Statement in response to the Commission staff’s
(the “Staff”) comments and provide any responses to or any supplemental explanations of such comments, as requested. These
changes will be reflected in the proxy statement and prospectus that will be filed via EDGAR on or about November 1, 2023. Capitalized
terms not otherwise defined herein have the meanings ascribed to them in the Registration Statement.

    1

Legal Comments

Comment 1.      
    Please complete all empty or bracketed fields.

Response 1.     The
Trust confirms that all empty or bracketed fields will be completed.

Comment 2.          Please
revise the first sentence of the second paragraph on the second page of the Notice to state that “Acquired Fund Shareholders
will be able to authorize proxies to vote their shares by returning the enclosed proxy card, by touchtone telephone or by Internet by
following the instructions on the Proxy Card accompanying this combined Proxy Statement and Prospectus.”

Response 2.     The
disclosure will be revised accordingly.

Comment 3.          With
respect to the answer to the question “Why am I receiving a Proxy Statement and Prospectus?” in the “Questions and
Answers” section, please consider structuring the answer to include bullet points or sub-headings.

Response 3.     The
disclosure will be revised accordingly.

Comment 4.          With
respect to the last paragraph in the answer to the question “What are the differences between an ETF and a mutual fund?”
in the “Questions and Answers” section, please revise this paragraph to include additional disclosure regarding the potential
risks and benefits of the ETF structure compared to mutual fund structure. The Staff notes that other sections of the Registration Statement
include disclosure regarding such risks and benefits which could be relocated to the “Questions and Answers” section. The
Staff further notes that this discussion could be presented in a table format.

Response 4.     The
disclosure will be revised to include additional disclosure regarding the benefits and potential risks associated with the ETF structure.

Comment 5.          In
the answer to the question “What are the differences between an ETF and a mutual fund?” in the “Questions and Answers”
section, please revise the first bullet point to state that “[a] mutual fund may offer multiple share classes with different sales
charges, expenses, and/or minimum investments. The Acquiring Funds will not issue multiple classes of shares.”

Response 5.     The
disclosure will be revised in response to this comment.

    2

Comment 6.          With
respect to the answer to the question “What are the differences between an ETF and a mutual fund?” in the “Questions
and Answers” section, please revise the disclosure to state that (i) an investor may pay significantly more or receive significantly
less than NAV during periods when there is a significant premium or discount; and (ii) an active trading market for an Acquiring
Fund’s shares may not develop or be maintained.

Response 6.     The
disclosure will be revised accordingly.

Comment 7.          Please
revise the answer to the question “How will the Reorganizations affect me as a shareholder?” in the “Questions and
Answers” section to state that shareholders of an ETF may bear certain costs with respect to maintaining brokerage accounts that
shareholders of a mutual fund do not incur.

Response 7.     The
disclosure will be revised accordingly.

Comment 8.          The
answer to the question “What will happen if I do not have a brokerage account that can accept Acquiring Fund Shares at the time
of the Reorganizations?” in the “Questions and Answers” section states that “[i]n some cases, the liquidation
of your investment and return of cash, or the transfer of your investment, may be subject to fees and expenses and may also
be subject to tax.” Please consider revising this disclosure so that the potential tax implications are discussed in a separate
sentence.

Response 8.     The
disclosure will be revised accordingly.

Comment 9.         In
the answer to the question “Are the fees and expenses of an Acquiring Fund expected to be lower than the fees and expenses of the
corresponding Acquired Fund?” in the “Questions and Answers” section, please consider revising the disclosure to include
a cross-reference to the “Comparison of the Funds’ Fees and Expenses” section of the combined Proxy Statement and Prospectus.

Response 9.     The
disclosure will be revised accordingly.

    3

Comment 10.       Please
consider relocating the questions “Are there other benefits that I will experience as a shareholder of an Acquiring Fund?”
and “Will I be subject to additional ETF-specific structural risks as a shareholder of an Acquiring Fund?” in the “Questions
and Answers” section to appear immediately after or combined with the question “What are the differences between an ETF and
a mutual fund?” Please refer to Comment 4 above. The Staff notes that the current disclosure is duplicative.

Response 10.     The
disclosure will be revised accordingly.

Comment 11.       With
respect to the answer to the question “Will I be subject to comparable investment risks as a shareholder of an Acquiring Fund?”
in the “Questions and Answers” section, please revise the disclosure to include a brief description of the material differences
between the principal risks of each Acquired Fund and its corresponding Acquiring Fund or state that there are no such material differences.

Response 11.     The
disclosure will be revised accordingly.

Comment 12.       Please
supplementally confirm that the Acquiring Funds’ prospectuses are not incorporated by reference into the combined Proxy Statement
and Prospectus.

Response 12.     The
Trust so confirms.

Comment 13.       Please
consider removing the following statement on the third page of the combined Proxy Statement and Prospectus as it is not required
and is duplicative of the disclosure on the cover page: “This combined Proxy Statement and Prospectus is dated [November 1],
2023.”

Response 13.     The
disclosure will be revised accordingly.

Comment 14.       With
respect to the answer to the question “How will the Reorganizations affect me?” in the “Summary” section of the
combined Proxy Statement and Prospectus, please revise the third paragraph to state that shareholders of an ETF may bear certain costs
with respect to maintaining brokerage accounts that shareholders of a mutual fund do not incur.

Response 14.     The
disclosure will be revised accordingly.

    4

Comment 15.       In
the answer to the question “What are the differences between an ETF and a mutual fund?” in the “Summary” section
of the combined Proxy Statement and Prospectus, please revise the first bullet point to state that “[a] mutual fund may offer multiple
share classes with different sales charges, expenses, and/or minimum investments. The Acquiring Funds will not issue multiple classes
of shares.”

Response 15.     The
disclosure will be revised in response to this comment.

Comment 16.       With
respect to the answer to the question “What are the differences between an ETF and a mutual fund?” in the “Summary”
section of the combined Proxy Statement and Prospectus, please consider revising the third bullet point to include a brief description
of the types of entities that generally qualify as authorized participants.

Response 16.     The
disclosure will be revised accordingly.

Comment 17.       Please
supplementally confirm that significant portfolio repositioning is not expected in connection with either Reorganization.

Response 17.     The
Trust so confirms.

Comment 18.       With
respect to the answer to the question “What are the distribution arrangements for the Funds?” in the “Summary”
section of the combined Proxy Statement and Prospectus, please revise the disclosure to state that the Board of Trustees of the Acquiring
Funds has approved a 12b-1 plan with respect to each Acquiring Fund and that 12b-1 fees may be implemented in the future without shareholder
approval. Alternatively, consider including a cross-reference to the “Comparison of the Funds’ Fees and Expenses” section
of the combined Proxy Statement and Prospectus.

Response 18.     The
disclosure will be revised accordingly.

Comment 19.       Please
revise the first sentence in the answer to the question “What are the quorum and approval requirements for the Reorganizations?”
in the “Summary” section of the combined Proxy Statement and Prospectus to more clearly state that the quorum requirement
for the Meeting with respect to each Reorganization is 40% of the shares entitled to vote.

Response 19.     The
disclosure will be revised accordingly.

    5

Comment 20.       With
respect to the “Comparison of the Funds’ Risks” section of the combined Proxy Statement and Prospectus, please consider
removing or relocating the risk comparison chart to an appendix. Please also consider relocating the principal risk disclosures to an
appendix.

Response 20.     The
risk comparison chart and principal risk disclosures will be relocated to appear in Appendix B of the combined Proxy Statement and Prospectus.

Comment 21.       In
the “Comparison of the Funds’ Fees and Expenses” section of the combined Proxy Statement and Prospectus, please add
a footnote to the Annual Fund Operating Expenses table with respect to each Reorganization stating that the Board of Trustees of the
Acquiring Funds has approved a 12b-1 plan with respect to each Acquiring Fund and that 12b-1 fees may be implemented in the future without
shareholder approval.

Response 21.     The
disclosure will be revised to include the following as a footnote to the Annual Fund Operating Expenses tables: “The Board of Trustees
of the Acquiring Fund has approved a Rule 12b-1 plan for the Fund. Accordingly, Rule 12b-1 fees may be imposed in the future
without shareholder approval.”

Comment 22.       In
the “Comparison of the Funds’ Fees and Expenses” section of the combined Proxy Statement and Prospectus, please add
a footnote to the Annual Fund Operating Expenses table relating to the Core Plus Fixed Income Reorganization stating that the contractual
management fee rate for the Acquiring Fund is higher than that of the Acquired Fund with respect to assets exceeding $1 billion. Please
consider stating whether the Acquired Fund’s asset level has ever exceeded $1 billion.

Response 22.     The
disclosure will be revised to include the following as a footnote to the Annual Fund Operating Expenses table for the Core Plus Fixed
Income Reorganization: “The contractual management fee rate for the Acquiring Fund is lower than the contractual advisory fee rate
of the Acquired Fund with respect to assets not exceeding $1 billion, but is higher than that of the Acquired Fund with respect to assets
exceeding $1 billion. As of October 20, 2023, the Core Plus Fixed Income Portfolio had approximately $523 million in net assets.”

Comment 23.       With
respect to the footnotes to the fee tables describing the fee waivers in place for the Acquired Funds in the “Comparison of the
Funds’ Fees and Expenses” section of the combined Proxy Statement and Prospectus, please state supplementally whether the
Adviser may recoup fees waived, and if so, please revise the disclosure to state that this is the case.

Response 23.     The
Trust confirms that the Adviser will not recoup fees waived in prior years.

    6

Comment 24.       In
the “Comparison of the Funds’ Investment Objectives and Principal Investment Strategies” section of the combined Proxy
Statement and Prospectus, please revise the disclosure to describe the material differences between the principal investment strategies
of each Acquired Fund and its corresponding Acquiring Fund. The Staff notes that the tables describing each Fund’s principal investment
strategies could be revised to include an additional column describing the material differences between the principal investment strategies
of each Acquired Fund and its corresponding Acquiring Fund. In addition, consider relocating such tables to an appendix.

Response 24.     The
paragraphs immediately preceding the tables describing each Fund’s principal investment strategies will be revised to state with
respect to each Reorganization that “There are no material differences between the principal investment strategies of the Acquiring
Fund and the Acquired Fund.” Accordingly, the tables describing each Fund’s principal investment strategies have not been
revised to include a discussion of the material differences between an Acquired Fund’s and its corresponding Acquiring Fund’s
principal investment strategies as there are no such material differences.

Comment 25.       In
the “Comparison of the Funds’ Management” section of the combined Proxy Statement and Prospectus, please consider revising
the presentation of the effective advisory fee rates to more clearly state that the effective fee rates reflect the impact of the fee
waivers that are currently in place for the Acquired Funds.

Response 25.     The
disclosure will be revised to include the following as a footnote to the table with the Acquired Funds’ effective advisory fee
rate: “The effective advisory fee rates reflect the impact of the fee waivers that are currently in place for the Acquired Funds.”

Comment 26.       Please
supplementally confirm that the Eaton Vance Short Duration Municipal Income ETF will not invest more than 25% of its total assets in
municipal obligations backed only by the assets and revenues of non-governmental users.

Response 26.     The Eaton Vanc