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Tidal Trust III

234 West Florida Street, Suite 203

Milwaukee, Wisconsin 53204

October 15, 2024

VIA EDGAR TRANSMISSION

Mr. David Mathews

Division of Investment Management, Disclosure Review Office

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

  Re:
  Tidal Trust III (the “Trust”)

  Post-Effective Amendment No. 50 to
the Trust’s Registration Statement on Form N-1A (the “Amendment”)

  File Nos. 811-23312; 333-221764

Dear Mr. Mathews:

This correspondence responds to comments
the Trust received from the staff of the U.S. Securities and Exchange Commission (the “Staff” or the “Commission”)
on September 24, 2024, with respect to the Registration Statement and the Trust’s proposed two new series, the Ninepoint Energy
ETF and Ninepoint Energy Income ETF (each, a “Fund,” and together, the “Funds”). For your convenience, the comments
have been reproduced with responses following each comment. Capitalized terms not otherwise defined have the same meaning as in the Registration
Statement.

PROSPECTUS

Fees and Expenses

 1. Please supplementally provide the Staff with a completed Fee Table for
each Fund pre-effectively. In correspondence please confirm that there is no fee waiver, reimbursement, or recoupment arrangement for
either Fund. If there are, please describe the waivers, reimbursements and/or recoupments in a footnote.

    Response: The Funds’ completed Fees and Expenses table and Expense
                              Example are as shown in the attached Appendix A. The Trust further confirms that there are currently no
                              fee waivers or reimbursements in place.

 2. Please confirm in correspondence whether the Fund intends to engage in
borrowing, short sales, or make investments in other investment companies and, if so, add additional expense table line items. If so,
please add any additional strategy disclosure or risk factors.

    Response: The Trust confirms that the Funds do not initially intend
                              to engage in, borrowing, short sales, or make investments in other investment companies.

Principal Investment Strategies

 3. Please provide examples or additional details as to the types of related
energy resource sector activities that companies in which the Fund invests will be involved in.

    Response: The Trust confirms that the Prospectus has been revised to
                              include such examples.

 4. The Staff notes that the description of Energy Companies in the summary
appears focused on traditional energy sources, whereas the more detailed description in Item 9 includes renewable or alternative energy
sources. Please briefly revise the summary to clarify the scope of the Energy and Resources sector so that it is consistent with how it
is described in Item 9. Also, consider adding a cross-reference to the additional details in Item 9.

    Response: The Trust confirms the foregoing changes have been made to
                              the Prospectus. Specifically, (i) the description of Energy Companies in the summary has been revised to
                              clarify that it includes both traditional and renewable/alternative energy sources, aligning with the more
                              detailed description in Item 9, and (ii) a cross-reference to Item 9 has been added.

 5. Briefly explain the terms about a company’s “free cash flow
yield” and “enterprise value to free cash flow ratio” to help investor’s understanding of the process.

    Response: The Trust confirms that brief explanations of the foregoing
                              terms have been added to the Prospectus.

 6. Please further tailor the Fund’s strategy to address how the Sub-Adviser
considers energy companies specifically. For example, it is unclear whether “inventory depth” is a reference to reserves and
whether the Sub-Adviser favors specific types of reserves and/or their locations when evaluating companies.

    Response: The Trust confirms that the Prospectus has been revised accordingly.

 7. For the Ninepoint Energy ETF, please clarify what “financial instruments”
other than equity securities of energy companies the Fund intends to invest for purposes of its 80% policy and ensure such instruments
are adequately disclosed in the strategy disclosure and risk sections.

    Response: The Fund does not intend to invest in financial instruments
                              other than the equity securities of energy companies. Accordingly, the reference to "financial instruments"
                              in the Fund’s 80% policy has been removed.

 8. Please explain in correspondence, how the Funds will count investments
in other investment companies and investments in derivatives for purposes of complying with its 80% policy to invest in Energy Companies.

    Response: For both Funds, compliance with the 80% policy is determined
                              by including direct investments in energy companies and any exposure gained through other investment companies
                              and derivatives. When investing in other funds, the Funds apply a look-through approach, counting the portion
                              of the underlying holdings that are invested in energy companies. For derivatives, the Fund use the notional
                              value to account for the full exposure those instruments provide. Bloomberg’s AIM system is used
                              to monitor and track these exposures.

 9. For the Ninepoint Energy Income ETF, to ensure investors understand the
geographic focus of this Fund’s strategy, please define the scope of North America. For example, is it intended to include or exclude
all central American and Caribbean companies? Also describe how a company is considered to be located in North America, such as by headquarters,
source of revenue, etc. We note that the risk factor regarding investing in North America only refers to the US, Canada, and Mexico.

    Response: For the purposes of the Fund’s strategy, North America
                              refers only to the United States, Canada, and Mexico, and does not include Central American or Caribbean
                              countries. A company is considered to be located in one of these countries based on the primary location
                              of its operations. The Fund’s principal investment strategy has been clarified accordingly.

 10. With respect to the Ninepoint Energy Income ETF’s target distributions:

 a. Will the Fund potentially borrow or invest in investments not described
in its principal strategy description in order to achieve its intended distribution target? If so, add disclosure of any such borrowing
or such investments for this purpose, including any additional associated risks or tax impacts.

 b. In correspondence, please advise the Staff whether the Fund intends to
report a distribution rate and, if so, how will it be reported? If reported in sales literature, indicate whether it will be accompanied
by the 30-day SEC yield calculation per Item 26(b)(4) of Form N-1A and explain how it will be calculated.

  Response:

 (a) No, the Fund has no current intention to borrow or invest in investments
not described in its principal strategy description in order to achieve its intended distribution target.

 (b) The Trust notes that the Fund plans to report distribution rates, which
will be made available on the Fund’s website and included in other sales materials. Any such reported distribution rates in sales
materials will be accompanied by the Fund’s 30-Day SEC yield. The distribution rate will reflect the annual yield an investor would
receive if the most recent distribution, which includes option income, were to remain consistent. This rate will be calculated by multiplying
the Fund’s most recent distribution per Share by twelve (12) and dividing the result by the Fund’s most recent NAV.

 11. With respect to the Ninepoint Energy Income ETF’s Covered Call
Writing Strategy, please supplementally confirm that the strategy will be fully covered, or if not, explain why describing the strategy
as covered is appropriate. Please describe or provide examples of the other types of financial instruments, other than securities, on
which the Sub-Adviser may employ its covered call strategy.

    Response: The Trust confirms that the Fund’s strategy will be
                              fully covered – it will only write call options on securities that the Fund holds in its portfolio.
                              The Fund will not employ the covered call strategy on any other financial instruments aside from the securities
                              held by the Fund.

 12. For the Ninepoint Energy Income ETF, describe in the disclosure how liquid
options contracts actually minimize slippage and how slippage would otherwise impact income from option premiums and/or impact potential
benefits from appreciation of the underlying asset as a result of the covered call writing strategy.

    Response: The Trust confirms that the Prospectus has been revised to
                              include the aforementioned disclosures.

 13. For the Ninepoint Energy Income ETF, please provide an estimated percentage,
if practicable, of portfolio assets that may be invested outside of North America.

    Response: The Trust confirms that the Prospectus has been revised to
                              provide such estimated percentage.

 14. For the Ninepoint Energy Income ETF’s 80% policy, please defined
how the Fund determines that a company’s level of involvement in the energy and resource sector is sufficient to be deemed to be
an Energy Company.

    Response: The Trust confirms that the Fund’s 80% policy has been
                              supplemented with such definitions.

Item 9

 15. Please confirm the accuracy of the Principal Investment Risks chart.
In particular, confirm the foreign securities risk sub-bullet points are accurate.

    Response: The Trust confirms that the Principal Investments Risks chart
                              has been revised to reflect its accuracy.

 16. The Item 9 Counterparty Risk recites only one of the Fund’s counterparty
risk disclosures. However, the Funds’ risks disclosures differed. Please revise as appropriate.

    Response: The Trust confirms that the Item 9 Counterparty Risk disclosure
                              has been updated accordingly.

Related Performance

 17. Please confirm the accuracy of the names of the similarly managed accounts
in the disclosure as the Staff notes that the Sub-Adviser’s website lists its series as only Series F and Series ETF for both Funds.

    Response: The Trust confirms the accuracy of the names of the similarly
                              managed accounts in the revised disclosure included in the Prospectus.

 18. With respect to the Ninepoint Energy Income ETF, the Staff found the
disclosure regarding the two separate series of the Canadian mutual fund used to illustrate past performance hard to follow due to the
naming conventions (as noted above) and also because representations as to differences in expenses, diversification, tax restrictions,
and investment limitations were only made with respect to the ETF Series, but not made with respect to Series F. Please revise the disclosure
to clarify.

    Response: The Trust confirms that the aforementioned language has been
                              revised to clarify the foregoing issues.

 19. The Staff notes that both Canadian mutual funds referenced in this section
have a Series A, a Series ETF, and a Series F share class, however, the Fund presents only Series ETF and Series F of the Energy Fund,
and only Series ETF of the Income Fund as substantially similar accounts. Please explain in correspondence why the series not being presented
were excluded, and represent to the Staff that the exclusion of such other series does not materially affect the performance being presented
or cause the presentation to be misleading. Also in correspondence, explain why the differences between the similar accounts and the Funds
as described in the disclosure do not alter the conclusion that the accounts are substantially similar to the Funds.

    Response: The Trust confirms that the related performance information
                              has been revised to reflect all series of each of the Canadian Funds.

    Further, the Trust acknowledges that there are certain differences between
                              the Canadian Funds and the Funds, as described in the disclosure. Despite these distinctions, the Trust
                              believes that the differences do not alter the conclusion that the Canadian Funds and the Funds are substantially
                              similar. The core investment strategy, portfolio management, and overall risk-return profile of each of
                              the two sets of accounts remain aligned. The performance results provided for the Canadian Funds, while
                              potentially impacted by the noted differences, still offer a reasonable and relevant basis for understanding
                              the potential performance of the Funds. The Trust has accounted for these variances in the disclosure and
                              believes that the performance history of the Canadian Funds is representative of the broader investment
                              strategies employed by the Funds.

 20. With respect to the presentation of related performance for both Funds
please also revise the disclosure or provide representations as follows:

 a. Disclose that the various differences described between the similar accounts
and the Fund are not material, would not have a material impact on the disclosed performance, and do not alter the conclusion that the
accounts are substantially similar.

 b. State clearly whether the performance shown is subject to all actual
fees and expenses, including sales loads of the similar accounts.

 c. State that performance would have been different if similar accounts
were denominated in US dollars rather than Canadian dollars.

 d. Clarify that the performance presented is the average annual total return
of the similar accounts.

 e. In correspondence, confirm that the standardized SEC method was used
to calculate the related performance. If it was not, then revise the disclosure to describe how the performance was calculated and state
that the method differs from the standard SEC method.

 f. Represent in correspondence that the Fund has, and will maintain, the
records necessary to support calculation of the performance as required by Rule 204-2)(a)16 of the Advisers Act and provide the Staff
supplementally with completed performance tables in advance of filing the 485(b).

  Response: The Trust acknowledges the Staff’s comments regarding
                                    the presentation of related performance for both Funds and confirms that it will address each sub-item
                                    as follows:

  a. The Trust will revise the disclosure to state that the various differences described
               between the similar accounts and the Funds are not material, would not have a material impact on the disclosed performance,
               and do not alter the conclusion that the accounts are substantially similar.

  b. The Trust will clarify in the disclosure whether the performance shown is subject
               to all actual fees and expenses, including whether it reflects any sales loads of the similar accounts.

  c. The Trust will revise the disclosure to state that performance would have been different
               if the similar accounts were denominated in U.S. dollars rather than Canadian dollars.

  d. The Trust will