SecProbe.io

CORRESP
 1
 filename1.htm

 July
15, 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
May 23, 2025, GraniteShares ETF Trust (the "Trust" or "Registrant"), on behalf of GraniteShares 2x Long ABNB
Daily ETF, GraniteShares 2x Long APP Daily ETF, GraniteShares 2x Long CVNA Daily ETF, GraniteShares 2x Long KO Daily ETF, GraniteShares
2x Long CRWV Daily ETF, GraniteShares 2x Long CEG Daily ETF, GraniteShares 2x Long COST Daily ETF, GraniteShares 2x Long ETOR Daily ETF,
GraniteShares 2x Long GLXY Daily ETF, GraniteShares 2x Long HIMS Daily ETF, GraniteShares 2x Long ISRG Daily ETF, GraniteShares 2x Long
MCD Daily ETF, GraniteShares 2x Long MELI Daily ETF, GraniteShares 2x Long NBIS Daily ETF, GraniteShares 2x Long NKE Daily ETF, GraniteShares
2x Long OKLO Daily ETF, GraniteShares 2x Long PM Daily ETF, GraniteShares 2x Long RGTI Daily ETF, GraniteShares 2x Long SNAP Daily ETF,
GraniteShares 2x Long SPOT Daily ETF, GraniteShares 2x Long SBUX Daily ETF, GraniteShares 2x Long UNH Daily ETF, GraniteShares 2x Long
WMT Daily ETF and GraniteShares 2x Long BULL Daily ETF (the "Funds") filed a Post-Effective Amendment #93 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 July 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

 GRANITESSHARES
2X LONG NBIS DAILY ETF

 Comment
1 : Please confirm that the Fund is able to invest in ADRs of Nebius Group NV. Please revise the disclosure throughout the summary
prospectus accordingly if the Fund is unable to invest in ADRs of Nebius Group NV.

 Response :
It is confirmed that the fund can invest in the ADRs of Nebius Group N.V.

 July
15, 2025

 Page
2

 GRANITESSHARES
2X LONG RGTI DAILY ETF

 Comment
2: Rigetti Computing, Inc. is described as a "full-stack computing company." Please describe in plain English what a "full-stack
computing company" is.

 Response :
The disclosure has been revised in the following way: " Rigetti Computing, Inc. develops and provides all the necessary components
for quantum computing including hardware, software and cloud solution (also referred to as a "full-stack quantum computing"
solution). "

 If
you have any questions, please call the undersigned at (216) 566-5706.

 Very
 truly yours,

 /s/
 Andrew Davall a

 Andrew
 Davalla

 GRANITESHARES
FUNDS

 Prospectus

 August
06, 2025

 GRANITESHARES FUNDS

 TICKER SYMBOL

 GraniteShares 2x Long ABNB Daily ETF

 ABNL

 GraniteShares 2x Long APP Daily ETF

 LOVL

 GraniteShares 2x Long CVNA Daily ETF

 CVLL

 GraniteShares 2x Long KO Daily ETF

 KKLL

 GraniteShares 2x Long CRWV Daily ETF

 CORL

 GraniteShares 2x Long CEG Daily ETF

 CEGL

 GraniteShares 2x Long COST Daily ETF

 COSL

 GraniteShares 2x Long ETOR Daily ETF

 ETRL

 GraniteShares 2x Long FSLR Daily ETF

 FSLL

 GraniteShares 2x Long GLXY Daily ETF

 GALL

 GraniteShares 2x Long HIMS Daily ETF

 HIML

 GraniteShares 2x Long ISRG Daily ETF

 ISUL

 GraniteShares 2x Long MCD Daily ETF

 MCDL

 GraniteShares 2x Long MELI Daily ETF

 MELL

 GraniteShares 2x Long NBIS Daily ETF

 NBIL

 GraniteShares 2x Long NKE Daily ETF

 NKEL

 GraniteShares 2x Long OKLO Daily ETF

 OKU

 GraniteShares 2x Long PM Daily ETF

 PMOL

 GraniteShares 2x Long RGTI Daily ETF

 RGTL

 GraniteShares 2x Long SNAP Daily ETF

 SNPL

 GraniteShares 2x Long SPOT Daily ETF

 SPOL

 GraniteShares 2x Long SBUX Daily ETF

 SBXL

 GraniteShares 2x Long UNH Daily ETF

 UNHL

 GraniteShares 2x Long WMT Daily ETF

 WMTL

 GraniteShares 2x Long BULL Daily ETF

 BULX

 The
Securities and Exchange Commission has not approved or disapproved these securities or passed upon the adequacy of this prospectus. Any
representation to the contrary is a criminal offense.

 GraniteShares
Funds are advised by GraniteShares Advisors LLC.

 The
Funds seek daily leveraged investment results and are intended to be used as short-term trading vehicles. Each Fund attempts to provide daily investment results that correspond to the respective long leveraged multiple of the performance
of an underlying stock (each a Leveraged Long Fund).

 The
Funds are not intended to be used by, and are not appropriate for, investors who do not intend to actively monitor and manage their portfolios.
The Funds are very different from most mutual funds and exchange-traded funds. Investors should note that:

 (1)
The Leveraged Long Funds pursue daily leveraged investment objectives, which means that the Funds are riskier than alternatives that
do not use leverage because the Funds magnify the daily performance of their underlying stock.

 (2)
 Seeking to replicate daily performances of
an underlying stock means that the return of a Fund for a period longer than a full trading day will be the product of a series of daily
returns for each trading day during the relevant period.

 As
a consequence, especially in periods of market volatility, the volatility of the underlying stock may affect a Fund's return as
much as, or more than, the return of the underlying stock. Further, the return for investors that invest for periods less than a full
trading day is likely to be different from an underlying stock's performance for the full trading day. During periods of high volatility,
the Funds may not perform as expected and the Funds may have losses when an investor may have expected gains if the Funds are held for
a period that is different than one trading day.

 The
Funds are not suitable for all investors. The Funds are designed to be utilized only by sophisticated investors, such as traders and
active investors employing dynamic strategies. Investors in the Funds should:

 (a)
 understand
 the risks associated with the use of and leverage strategies;

 (b)
 understand the consequences
 of seeking daily leveraged investment results;

 (c)
 intend to actively monitor
 and manage their investments.

 Investors
who do not understand the Funds, or do not intend to actively manage their funds and monitor their investments, should not buy the Funds.

 There
is no assurance that any Fund will achieve its investment objective and an investment in a Fund could lose money. No single Fund is a
complete investment program.

 For
the Leveraged Long Funds with a 2-time leverage exposure, if the underlying stock drops by more than 50% on a given trading day, the
Fund's investors could lose all of their money.

 TABLE
OF CONTENTS

 Page

 GraniteShares 2x Long ABNB Daily ETF – Summary
 1

 GraniteShares 2x Long APP Daily ETF – Summary
 10

 GraniteShares 2x Long CVNA Daily ETF – Summary
 19

 GraniteShares 2x Long KO Daily ETF – Summary
 28

 GraniteShares
 2x Long CRWV Daily ETF - Summary
 37

 GraniteShares 2x Long CEG Daily ETF – Summary
 46

 GraniteShares 2x Long COST Daily ETF – Summary
 55

 GraniteShares 2x Long ETOR Daily ETF – Summary
 64

 GraniteShares 2x Long FSLR Daily ETF – Summary
 73

 GraniteShares 2x Long GLXY Daily ETF – Summary
 82

 GraniteShares 2x Long HIMS Daily ETF – Summary
 93

 GraniteShares 2x Long ISRG Daily ETF – Summary
 102

 GraniteShares 2x Long MCD Daily ETF – Summary
 111

 GraniteShares 2x Long MELI Daily ETF – Summary
 120

 GraniteShares 2x Long NBIS Daily ETF – Summary
 129

 GraniteShares 2x long NKE Daily ETF – Summary
 138

 GraniteShares 2x long OKLO Daily ETF – Summary
 147

 GraniteShares 2x Long PM Daily ETF – Summary
 156

 GraniteShares 2x Long RGTI Daily ETF – Summary
 165

 GraniteShares 2x Long SNAP Daily ETF – Summary
 174

 GraniteShares 2x Long SPOT Daily ETF – Summary
 183

 GraniteShares 2x Long SBUX Daily ETF – Summary
 192

 GraniteShares 2x Long UNH Daily ETF – Summary
 201

 GraniteShares 2x Long WMT Daily ETF – Summary
 210

 i

 GraniteShares 2x Long BULL Daily ETF – Summary
 219

 Additional Information about the Funds' Investment Objectives, Strategies and Risks
 228

 FUND WEBSITE AND DISCLOSURE OF PORTFOLIO HOLDINGS
 258

 Fund Management
 258

 Buying and Selling Shares
 259

 Dividends, Distributions, and Taxes
 261

 Distribution of Fund Shares
 263

 Premium/Discount Information
 263

 Fund Service Providers
 263

 Financial Highlights
 264

 GraniteShares ETF Trust
 264

 ii

 GraniteShares
2x LONG ABNB Daily ETF – Summary

 Important
Information Regarding the Fund

 The
GraniteShares 2x Long ABNB Daily ETF (the "Fund") seeks daily investment results of 2 times (200%) the daily percentage change
of the common stock of Airbnb Inc. (Nasdaq: ABNB) (the "Underlying Stock"). Because the Fund seeks daily leverage investment
results, it is very different from most other exchange-traded funds. It is also riskier than alternatives that do not use a leverage
strategy. The return for investors that invest for periods longer or shorter than a trading day should not be expected to be 200% of
the performance of the Underlying Stock for the period. The return of the Fund for a period longer than a trading day will be the result
of each trading day's compounded return over the period, which will very likely differ from 200% the return of the Underlying Stock
for that period. Longer holding periods, higher volatility of the Underlying Stock and leverage increase the impact of compounding on
an investor's returns. During periods of higher underlying stock volatility, the volatility of the Underlying Stock may affect
the Fund's return as much as, or more than, the return of the Underlying Stock.

 The
Fund is not suitable for all investors. The Fund is designed to be utilized only by knowledgeable investors who understand the potential
consequences of seeking daily leverage (2X) investment results, understand the risks associated with the use of leverage, and are willing
to monitor their portfolios frequently. The Fund is not intended to be used by, and is not appropriate for, investors who do not intend
to actively monitor and manage their portfolios. For periods longer than a single day, the Fund will lose money if the Underlying Stock's
performance is flat, and it is possible that the Fund will lose money even if the Underlying Stock's performance increases over
a period longer than a single day. An investor could lose the full principal value of his/her investment within a single day.

 Investment
Objective

 The
Fund seeks daily investment results, before fees and expenses, of 2 times (200%) the daily percentage change of the common stock of Airbnb
Inc. (Nasdaq: ABNB).

 Fund
Fees and Expenses

 This
table describes the fees and expenses that you may pay if you buy, hold, and sell shares of the Fund ("Shares"). The fees
are expressed as a percentage of the Fund's average daily net assets. Investors may pay other fees, such as brokerage commissions
and other fees to financial intermediaries, which are not reflected in the table and example below.

 Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)

 Management Fee
 1.30 %

 Distribution and/or Service (12b-1) Fees
 - %

 Other Expenses (1)
 0.20 %

 Total Annual Fund Operating Expenses (2)
 1.50 %

 Fee Waver/Reimbursements (3)
 - %

 Net Annual Fund Operating Expenses After Fee Waiver/Reimbursements (1), (2), (3)
 1.50 %

 (1)
 Other Expenses are estimated
 for the Fund's initial fiscal year.

 (2)
 The
 cost of investing in swaps, including the embedded cost of the swap and the operating expenses of the referenced assets, is an indirect
 expense that is not included in the above fee table and is not reflected in the expense example. The total indirect cost of investing
 in swaps, including the embedded cost of the swap and the operating expenses of the referenced assets, is estimated to be 2.00%
 for the fiscal year ending June 30, 2026.

 (3)
 GraniteShares
 Advisors LLC has contractually agreed to waive its fees and/or pay for operating expenses of the Fund to ensure that total annual
 fund operating expenses (exclusive of any (i) interest, (ii) brokerage fees and commission, (iii) acquired fund fees and expenses,
 (iv) fees and expenses associated with instruments in other collective investment vehicles or derivative instruments (including for
 example options and swap fees and expenses), (v) interest and dividend expense on short sales, (vi) taxes, (vii) other fees related
 to underlying investments (such as option fees and expenses or swap fees and expenses), (viii) expenses incurred in connection with
 any merger or reorganization or (ix) extraordinary expenses such as litigation) will not exceed 1.50%. This agreement is effective
 until December 31, 2026, and it may be terminated before that date only by the Trust's Board of Trustees. GraniteShares Advisors
 LLC may request recoupment of previously waived fees and paid expenses from the Fund for three years from the date such fees and
 expenses were waived or paid, if such reimbursement will not cause the Fund's total expense ratio to exceed the expense limitation
 in place at the time of the waiver and/or expense payment and the expense limitation in place at the time of the recoupment.

 1

 Example

 This
Example is intended to help you compare the cost of investing in the Fund with the cost of investing in mutual funds and other exchange-traded
funds.

 The
Example assumes that you invest $10,000 in the Fund for the time periods indicated and then sell all of your Shares at the end of those
periods. The Example also assumes that your investment has a 5% return each year and that the Fund's operating expenses remain
the same. The figures shown would be the same whether or not you sold your Shares at the end of each period.

 Although
your actual costs may be higher or lower, based on these assumptions your costs would be:

 1
 Year

 3
 Years

 $
 156

 $
 511

 Portfolio
Turnover

 The
Fund pays transaction costs, such as commissions, when it buys and sells securities (or "turns over" its portfolio). A higher
portfolio turnover rate may indicate higher transaction costs and may result in higher taxes when Shares are held in a taxable account.
These costs, which are not reflected in annual fund operating expenses or in the Example, affect the Fund's performance. The Fund
does not have any portfolio turnover because it has not yet been launched.

 Principal
Investment Strategies

 The
Fund is an actively managed exchange traded fund that attempts to replicate 2 times (200%) daily percentage change of the Underlying
Stock by entering financial instruments such as swaps and options on the Underlying Stock as well as directly purchasing the Underlying
Stock. At the end of each trading day, the notional exposure against the Underlying Stock obtained through the combination of these instruments
will be approximately 200% of the Fund's net asset value. The Fund aims to generate 2 times the daily performance of the Underlying
Stock for a single day. A "single day" is defined as being calculated "from the close of regular trading on one trading
day to the close on the next trading day."

 The
Fund will aim to primarily obtain its notional exposure against the Underlying Stock through swap agreements. In case the Fund faces
restriction in increasing its swap notional exposure, it may use option contracts on the Underlying Stock or buy the Underlying Stock
directly.

 Swaps:

 The
Fund may enter into one or more swap agreements with major financial institutions for a specified period ranging from a day to more than
one year whereby the Fund and the financial