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August 27, 2025

Christopher
Bellacicco

Division
of Investment Management

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

RE:
GraniteShares ETF Trust (the “Trust” or the “Registrant”) File Nos. 333-214796, 811-23214

Dear
Mr. Bellacicco:

On
June 23, 2025, GraniteShares ETF Trust (the “Trust” or “Registrant”), on behalf of GraniteShares YieldBOOST QQQ
3x Income ETF, GraniteShares YieldBOOST SPY 3x Income ETF, GraniteShares YieldBOOST Small Cap 3x Income ETF, GraniteShares YieldBOOST
Biotech 3x Income ETF, GraniteShares YieldBOOST Financials 3x Income ETF, GraniteShares YieldBOOST Gold Miners 2x Income ETF, GraniteShares
YieldBOOST Semiconductor 3x Income ETF, GraniteShares YieldBOOST Technology 3x Income ETF, GraniteShares YieldBOOST China 3x Income ETF,
GraniteShares YieldBOOST 20Y+ Treasuries 3x Income ETF, GraniteShares YieldBOOST Bitcoin 2x Income ETF, GraniteShares YieldBOOST AAPL
2x Income ETF, GraniteShares YieldBOOST AMD 2x Income ETF, GraniteShares YieldBOOST AMZN 2x Income ETF, GraniteShares YieldBOOST BABA
2x Income ETF, GraniteShares YieldBOOST COIN 2x Income ETF, GraniteShares YieldBOOST META 2x Income ETF, GraniteShares YieldBOOST MSFT
2x Income ETF, GraniteShares YieldBOOST NVDA 2x Income ETF and GraniteShares YieldBOOST TSLA 2x Income ETF (the “Funds”)
filed a Post-Effective Amendment #95 to the Trust’s Registration Statement (the “Amendment”). The Amendment was filed
pursuant to Rule 485(b) under the Securities Act of 1933, as amended, to register the Funds.

In
a telephone conversation on August 8, 2025, you provided comments to the Amendment. Below, please find those comments and the Registrant’s
responses, which the Registrant has authorized Thompson Hine LLP to make on its behalf. Please note that added language to a Fund’s
prospectus is in italics and deleted language appears struck through.

SUMMARY
PROSPECTUS

ALL
FUNDS

Note
that the Registrant decided to remover the term “2x Income” or “3x Income” from the fund names. The proposed
fund names are now the following: GraniteShares YieldBOOST QQQ ETF, GraniteShares YieldBOOST SPY ETF, GraniteShares YieldBOOST Small
Cap ETF, GraniteShares YieldBOOST Biotech ETF, GraniteShares YieldBOOST Financials ETF, GraniteShares YieldBOOST Gold Miners ETF, GraniteShares
YieldBOOST Semiconductor ETF, GraniteShares YieldBOOST Technology ETF, GraniteShares YieldBOOST China ETF, GraniteShares YieldBOOST 20Y+
Treasuries ETF, GraniteShares YieldBOOST Bitcoin ETF, GraniteShares YieldBOOST AAPL ETF, GraniteShares YieldBOOST AMD ETF, GraniteShares
YieldBOOST AMZN ETF, GraniteShares YieldBOOST BABA ETF, GraniteShares YieldBOOST COIN ETF, GraniteShares YieldBOOST META ETF, GraniteShares
YieldBOOST MSFT ETF, GraniteShares YieldBOOST NVDA ETF and GraniteShares YieldBOOST TSLA ETF.

Investment
Objective

Comment
1: The Fund’s investment strategy indicates that operations will be written on the Underlying Leveraged ETF, not the index.
To the extent options will be written on the index, please revise the investment strategy disclosure accordingly, and, if options will
be written on the Underlying Leveraged ETF, than revise the investment objective accordingly.

Response:
The investment objectives have been revised.

The
proposed Investment objective for GraniteShares YieldBOOST QQQ ETF, GraniteShares YieldBOOST SPY ETF, GraniteShares YieldBOOST Small
Cap ETF, GraniteShares YieldBOOST Biotech ETF, GraniteShares YieldBOOST Financials ETF, GraniteShares YieldBOOST Gold Miners ETF, GraniteShares
YieldBOOST Semiconductor ETF, GraniteShares YieldBOOST Technology ETF, GraniteShares YieldBOOST China ETF, GraniteShares YieldBOOST 20Y+
Treasuries ETF is the following:

“The
Fund’s investment objective is to achieve [2 or3] times ([200% or 300%]) the income generated from selling options on [Underlying
Index] (the “Underlying Index”) by selling options on leveraged exchange-traded funds designed to deliver [2 or 3] times
([200% or 300%]) the daily performance of the Underlying Index (the “Underlying Leveraged ETF”). The Fund’s secondary
investment objective is to gain exposure to the performance of the Underlying Leveraged ETF, subject to a cap on potential investment
gains. A downside protection may be implemented which could affect the net income level.”

The
proposed Investment objective for GraniteShares YieldBOOST Bitcoin ETF is the following:

“The
Fund’s investment objective is to achieve 2 times (200%) the income generated from selling options on bitcoin (the “Underlying
Asset”) by selling options on leveraged exchange-traded funds designed to deliver 2 times (200%) the daily performance of the Underlying
Asset (the “Underlying Leveraged ETF”). The Fund’s secondary investment objective is to gain exposure to the performance
of the Underlying Leveraged ETF, subject to a cap on potential investment gains. A downside protection may be implemented which could
affect the net income level.”

The
proposed Investment objective for GraniteShares YieldBOOST AAPL ETF, GraniteShares YieldBOOST AMD ETF, GraniteShares YieldBOOST AMZN
ETF, GraniteShares YieldBOOST BABA ETF, GraniteShares YieldBOOST COIN ETF, GraniteShares YieldBOOST META ETF, GraniteShares YieldBOOST
MSFT ETF, GraniteShares YieldBOOST NVDA ETF and GraniteShares YieldBOOST TSLA ETF is the following:

Response:
The investment objective has been revised to: “The Fund’s investment objective is to achieve 2 times (200%) the income
generated from selling options on [Underlying Stock] (the “Underlying Stock”) by selling options on leveraged exchange-traded
funds designed to deliver 2 times (200%) the daily performance of the Underlying Stock (the “Underlying Leveraged ETF”).
The Fund’s secondary investment objective is to gain exposure to the performance of the Underlying Leveraged ETF, subject to a
cap on potential investment gains. A downside protection may be implemented which could affect the net income level.”

Principal
Investment Strategies

Comment
2:

(A)
Please explain supplementally how a Fund achieves either 3x of 2x income if the Fund is received income on premiums. Please explain where
the 3x comes from.

Response:
The marked wording below has been added:

“The
Fund is an actively managed exchange-traded fund (“ETF”) that seeks to pay weekly distributions by selling put options on
the Underlying Leveraged ETF, which provides exposure to 2 times the daily performance of the Underlying [Index/Asset/Stock]. It is expected
that the implied volatility on the Underlying Leveraged ETF to be twice the level of the Underlying [Index/Asset/Stock’s] implied
volatility and selling options on the Underlying Leveraged ETF to generate, over the same time horizon and for the same strike levels,
twice the premium generated by selling options on the Underlying [Index/Asset/Stock]. There is no guarantee that the Fund will generate
twice the level of premium that would be generated by selling options on the Underlying [Index/Asset/Stock].”

(B)
Please add a disclosure that explains what “net of the costs associated with a downside protection” in the investment objective
means.

Response:
The marked wording below has been added:

“The
Fund is subject to the losses from the Underlying Leveraged ETF. In case a Put Spread Strategy (as defined under the section “The
Fund’s Use of the Underlying Leveraged ETF Derivatives Contracts”) is implemented, the Fund may benefit from a limited downside
protection against a negative price variation in the Underlying Leveraged ETF. Such protection will negatively affect the Fund’s
overall income level. A put spread strategy with a narrow spread (the difference between the strikes of the put option sold and put option
bought) may provide better protection but will have a higher negative impact on the Fund’s income level. A put spread strategy
with a large spread will provide a lower protection but may have less negative impact on the Fund’s income level. (…)”

(C)
The Staff notes that the 3x/2x appears to relate to efforts to achieve 3x the income. Please add to the disclosure explaining over what
time period a Fund aims to achieve 300%/200% income and whether the 300%/200% is guaranteed.

Response:
Please refer to the response to comment #2(A) where the following wordings have been added:

 - “over
                                            the same time horizon”

 - “There
                                            is no guarantee that the Fund will generate twice the level of premium that would be generated
                                            by selling option on the Underlying [Index/Asset/Stock].”

(D)
Please explain supplementally how the term “3x” or “2x” in the Fund name is not misleading as terms such as “3x”
or “2x” typically refer to a 3x or 2x leveraged ETF that is passively management.

Response:
It is proposed for the fund names to not refer to “2x” or “3x” anymore.

Response:

Comment
3: Please clarify (a) if the 3x or 2x refers to a comparable option in the underlying stock (such as with the same strike and tenor)
and what would cause deviations and (b) how the netting of the downside protection will impact the 3x or 2x income with a disclosure
on frequency and magnitude.

Response:

 (a) Please
                                            refer to the response to Comment 2 (A) where the wording “over the same time horizon
                                            and for the same strike levels” has been added. It is not expected that there will
                                            be significant deviations for the periods over which the options will be written.

 (b) The
                                            impact on the downside protection on the income level is difficult to predict, as the volatility
                                            curve of an Underlying Stock is not constant over time and different strike levels may be
                                            impacted differently.

The
following term added in response to Comment 2 “Such protection will negatively affect the Fund’s overall income level.
A put spread strategy with a narrow spread (the difference between the strikes of the put option sold and put option bought) may provide
better protection but will have a higher negative impact on the Fund’s income level. A put spread strategy with a large spread
will provide low protection but may have a less negative impact on the Fund’s income level.”

Comment
4: Please address the following comments relating to the first sentence of the first paragraph under the “Principal Investment
Strategies” heading.

(A)
Please add a disclosure explaining how the Fund’s investment strategy will permit it to pay weekly distributions given that it
sells monthly.

Response:
The following disclosure has been added: “The premium received by the Fund from selling options will be distributed at least
partially before the maturity of the options. This allows the Fund to make distributions on a weekly basis even if the options sold have
longer maturity (such as monthly maturity for instance). This approach may result in the distributions being treated fiscally as return
of capital (see “Distribution Risk” under the section “Principal Risks of Investing in the Fund”).”

(B)
Please explain if the Fund expects that there will be weeks with no distributions or that the distributions will be all or primarily
a return of capital.

Response:

 - No
                                            distributions: The Registrant believes that the existing disclosure “There is no
                                            guarantee that the Fund’s investment strategy will be properly implemented or pay weekly
                                            distributions (…).” addresses the point that distributions are not guaranteed.

 - Return
                                            of Capital: The following sentence has been added: “Even when the Fund makes a distribution
                                            it could be treated fiscally as return of capital (see “Distribution Risk” under
                                            the section “Principal Risks of Investing in the Fund”)”

Comment
5: In the third sentence of the first paragraph under the “Principal Investment Strategies” heading, please explain
the meaning of “if any” as the investment objective suggests that the Fund will have downside protection.

Response:
Please refer to the response to comment 2 (B) where the term “any” has been removed.

Comment
6: For the first two bullet points under the first paragraph under the “Principal Investment Strategies” heading,
please add a disclosure that explains (a) if, and how, the income from the options premium is different from the Fund’s participation
in gain, and, if they are the same, then the language should be revised to reflect that, and (b) downside protections against losses.

Response:
The bullet points have been removed as they were deemed repetitive with the paragraph above them.

Comment
7: In prong (6) in the paragraph that begins with “[t]he Fund cash balance may be invested in the following instruments…”,
please explain in further detail what types of U.S. equities the Fund may investment and how they fit into the Fund’s principal
investment strategy.

Response:
The sentence has been removed

Comment
8: To the extent the Fund exceeds regulatory thresholds, as described in the fifth paragraph under the “Principal Investment
Strategies” heading, please provide the value at risk (VAR) for back test data based on three years of historical data using
a 99% confidence level with a 20-day time horizon over a 3-year period.

Response:
 Detail about VAR is available in the Appendix A

Comment
9: For the first two bullet points under the sub-heading “[a]n Investment in the Fund is not an investment in the Underlying
Leveraged ETF,” please provide clarification regarding premium income and underlying stock gain.

Response:
The first two bullet points have been modified and now read as:

 - “The
                                            Fund’s strategy will cap its potential gain to the premium received from selling options
                                            on the Underlying Leveraged ETF,

 - The
                                            Fund’s strategy is exposed to all potential losses if the Underlying Leveraged ETF’s
                                            share decline, subject to a potential downside protection if a put spread strategy is used.
                                            The potential losses may not be offset by the premium received by the Fund,”

Comment
10: For the third bullet point under the same sub-heading, please explain how this statement reconciles with the secondary investment
objective of gaining exposure to the Underlying Leveraged ETFs and clarify that objective if necessary.

Response:
As described in the first paragraph under the investment strategy section, “The Fund is an actively managed exchange-traded
fund (“ETF”) that seeks to pay weekly distributions by selling put options on the Underlying Leveraged ETF”. When
the Fund sells put options on the Underlying Leveraged ETF, it is exposed to the performance of the Underlying Leveraged ETF even though
it does not directly invest or hold it.

Comment
11: In the first sentence of the paragraph discussing the “Put Spread Strategy,” please add disclosure that this net
premium will not be 3x the income generated from selling options on the Underlying Leveraged ETF.

Response:
The following disclosure has been added: “Buying a put option contract results in a cost that negatively affects the Fund’s
income level. It is unlikely for a put spread strategy to generate twice the level of income that would be obtained by selling options
on the Underlying [Index/Asset/Stock] directly.”

The
disclosure has not been added at the end of the first sentence. The Registrant believes the