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CORRESP
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Tidal
Trust III

234
West Florida Street, Suite 203

Milwaukee,
Wisconsin 53204

January
2, 2025

VIA
EDGAR TRANSMISSION

Rebecca
Marquigny

U.S.
Securities and Exchange Commission

Division
of Investment Management

100
F Street NE

Washington,
DC 20549

 Re: Tidal
Trust III (the “Trust”)

Post-Effective
Amendment No. 73 to the Trust’s Registration Statement on Form N-1A (the “Amendment”)

File
Nos. 811-23312; 333-221764

Dear
Ms. Marquigny:

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 December 12, 2024, with respect to the Registration Statement and the Trust’s proposed new
series, the TH GARP Global Rising Leaders ETF (the “Fund”). 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

Cover
Page

 1. Please
                                            supplementally confirm that the prospectus cover will be updated to include the exchange
                                            upon which shares will trade by the prospectus effective date.

Response:
The Trust responds supplementally by confirming that the prospectus cover will be updated accordingly.

Fees
and Expenses

 2. Please
                                            supplementally provide the Staff with a completed Fee Table pre-effectively. Also, supplementally
                                            confirm that the Fund’s expenses are not subject to any reimbursement arrangement,
                                            or alternatively, reflect the arrangement in a footnote to the fee table, and present the
                                            excluded expenses in the fee table’s other expenses line, if greater than 1 bps.

Response:
The Fund’s completed Fees and Expenses table and Expense Example are as shown in the attached Appendix A. The Trust responds supplementally
by confirming that the Fund will initially not be subject to a fee waiver or expense reimbursement arrangement.

 3. With
                                            respect to footnote 1 to the fee table, will the Adviser waive its management fee when investing
                                            in affiliated underlying funds? If not, disclose conflicts that the Adviser has relating
                                            to such investment choices. Also, where it references dividends and other expenses on securities
                                            should short, if appropriate please break that expense out as a sub line-item for Other Expenses
                                            or explain why it does not need to be.

Response:
The Trust responds supplementally by confirming that the Fund’s principal investment strategies do not involve investing in affiliated
underlying funds or engaging in short sale activities. Accordingly, no revisions have been made in response to this comment.

 4. With
                                            respect to the Example, please state that the numbers only reflect reimbursed or waived expenses
                                            for the first year, or supplementally, confirm the expenses reflect related reimbursements
                                            only for the contractual waiver period.

Response:
The Trust responds by referring the Staff to its response to comment 2 above where the Trust confirms that the Fund will initially not
be subject a fee waiver or expense reimbursement arrangement.

Principal
Investment Strategies

 5. Please
                                            revise to more clearly identify the Fund’s investment universe.

Response:
Appropriate revisions have been made as presented in the revised disclosure provided to the Staff under separate cover.

 6. Where
                                            it states that the Fund’s strategy seeks a combination of “consistent revenue
                                            growth, rising free cash flow, and reasonable valuations,” please revise to clarify
                                            the meaning of consistent, rising and reasonable, in objective terms, and indicate the time
                                            periods involved. Is this on an absolute basis or relative to industry peers or prior periods?
                                            Revise to disclose.

Response:
Appropriate revisions have been made to the Item 9 section of the prospectus as presented in the revised disclosure provided to the Staff
under separate cover.

 7. Regarding
                                            the first set of bullets on page 2, please provide some understanding of how the Sub-Adviser
                                            weights the stated criteria and indicate the relevance, if any, of capitalization size.

Response:
Appropriate revisions have been made as presented in the revised disclosure provided to the Staff under separate cover.

 8. Regarding
                                            the sentence stating that “[t]he Sub-Adviser may also seek to actively engage with
                                            portfolio companies’ management, both before and after the Fund invests in such companies,
                                            to propose and recommend actions to improve their operations and growth,” in item 9,
                                            please explain the Sub-Adviser’s active engagement strategy in greater detail. How
                                            will the Sub-Adviser factor the company’s response to such engagement into decisions
                                            whether to keep or sell a portfolio constituent.

Response:
Appropriate revisions have been made to the Item 9 section as presented in the revised disclosure provided to the Staff under separate
cover.

 9. Regarding
                                            the “Investment Process for Bonds” section, what is the Sub-Adviser’s anticipated
                                            percentage allocation of equities versus bonds? Please disclose any minimum or maximum range
                                            parameters. Clarify what the Sub-adviser views as shorter maturities for this purpose.

Response:
Appropriate revisions have been made as presented in the revised disclosure provided to the Staff under separate cover.

 10. Regarding
                                            the “Technical Analysis” section, does technical analysis mean that the Fund
                                            uses proprietary or third party predictive algorithms and data charting tools? If so, state
                                            this directly and indicate whether they are proprietary or purchased services.

Response:
The Trust responds supplementally by confirming that the Fund’s strategy does not involve the use of any third-party or proprietary
predictive algorithms.

 11. It
                                            states that Fund’s investments in any one sector may exceed 25% of its assets, and
                                            it is anticipated that the Fund will have such overweight exposure to the financials and
                                            technology sectors. If the Fund will concentrate its assets in any industry, state this directly,
                                            explain what concentration means, and include corresponding risk disclosure specific to concentration
                                            rather than just sector.

Response:
The Trust responds supplementally by stating that the Fund has adopted a fundamental policy, as disclosed in the SAI, to not concentrate
in any industry.

 12. Supplementally
                                            provide details related to the Fund’s anticipated India investments. Specifically,
                                            tell us about the Sub-Adviser’s experience and expertise with investing in India and
                                            whether it has resources there. Depending on the response the Staff may seek further disclosure.

Response:
The Trust responds supplementally by stating that the Fund’s sub-adviser includes personnel that have experience managing investment
portfolios, and conducting related research, of India companies. This includes Mr. Vivek Subramanyam, who is the Chief Investment Officer
of the sub-adviser. Mr. Subramanyam has over 24 years of experience in investment banking and equity investing. He is also the founder
and CEO of Technology Holdings, a global M&A and private equity advisory firm with investment banking and investment experience across
the Americas, Europe and Asia-Pacific. Additional members of the sub-adviser’s research team include.

 ● Suyog
                                            Kulkarni, CFA, has over 14 years of equity research and institutional sell side experience
                                            in Indian and global markets.

 ● Monil
                                            Shah has over 14 years of experience conducting technical analysis in Indian and global markets.

 ● Aditya
                                            Tikekar has over 9 years of experience conducting equity research in Indian and global markets.

 ● Alex Luthringer
                                            has over 8 years of experience conducting equity research and credit research in US and global
                                            market.

Suyog
Kulkarni, Monil Shah and Aditya Tikekar are each based out of India.

 13. Please
                                            clarify the percentage of assets the Fund may tactically allocate to cash, treasuries or
                                            money market instruments in circumstances that do not fall within the temporary defensive
                                            positions described in Form N-1A.

Response:
Appropriate revisions have been made as presented in the revised disclosure provided to the Staff under separate cover.

 14. In
                                            the “Holdings” section or in Item 9, describe the Fund’s use of derivatives
                                            in greater detail.

Response:
Appropriate revisions have been made as presented in the revised disclosure provided to the Staff under separate cover.

 15. Please
                                            rewrite the last paragraph before the “Principal Investment Risks” section in
                                            plain English. Tell investors why, as a practical matter, all the acronyms are relevant to
                                            the share value and the investors interests overall. Currently this is not clear from the
                                            disclosure provided.

Response:
Appropriate revisions have been made as presented in the revised disclosure provided to the Staff under separate cover.

Principal
Investment Risks

 16. With
                                            respect to “Management Risk,” please directly discuss the role of human error
                                            by individual portfolio managers. Specifically, the portfolio managers may make poor choices
                                            and incorrect decisions. They may also rely on poorly chosen, ineffective investment techniques,
                                            and risk analyses, or apply poor judgement to otherwise effective investment and analysis
                                            methods.

Response:
Appropriate revisions have been made as presented in the revised disclosure provided to the Staff under separate cover.

Additional
Information About the Fund

 17. The
                                            strategy disclosure in this section is limited. Please realign the item 9 strategy disclosures
                                            with the applicable requirements of Form N-1A. Incorporate responses to item 4 in the revised
                                            item 9 strategy.

Response:
Revisions have been made to the Item 9 section as presented in the revised disclosure provided to the Staff under separate cover, which
serve to provide additional detail that is not included in the Item 4 disclosure.

 18. Please
                                            confirm supplementally that the Fund will ensure consistency with the names rule in the event
                                            of a change in the policy.

Response:
The Trust confirms supplementally that the Fund will ensure consistency with the names rule in the event of a change in the policy.

STATEMENT
OF ADDITIONAL INFORMATION

 19. There
                                            are several references to “The Companies Act, 2013.” Is this a defined term or
                                            the full name? Revise as necessary.

Response:
The Trust will revise such references to reflect “The Companies Act 2013 (No. 18 of 2013).”

If
you have any questions or require further information, please contact John Hadermayer at (262) 318-8236 or jhadermayer@tidalfg.com.

Sincerely,

/s/
John Hadermayer

John
Hadermayer

SVP
Legal Services

Tidal
Investments LLC

Appendix
A

TH
GARP Global Rising Leaders ETF

Fees
and Expenses of the Fund

This
table describes the fees and expenses that you may pay if you buy, hold, and sell shares of the Fund (“Shares”). You 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
    Fees(1)

    0.75%

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

    0.00%

    Other
    Expenses(2)

    0.00%

    Total
    Annual Fund Operating Expenses

    0.75%

    (1)
    The Fund’s
    investment adviser, Tidal Investments LLC (the “Adviser”), will pay, or require a sub-adviser to pay, all of the Fund’s
    expenses, except for the following: advisory and sub-advisory fees, interest charges on any borrowings, dividends and other expenses
    on securities sold short, taxes, brokerage commissions and other expenses incurred in placing orders for the purchase and sale of
    securities and other investment instruments, acquired fund fees and expenses, accrued deferred tax liability, distribution fees and
    expenses paid by the Fund under any distribution plan adopted pursuant to Rule 12b-1 under the Investment Company Act of 1940, as
    amended (the “1940 Act”), and litigation expenses, and other non-routine or extraordinary expenses.

    (2)
    Based on estimated amounts
    for the current fiscal year.

Expense
Example

This
Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other funds. The Example assumes
that you invest $10,000 in the Fund for the time periods indicated and then hold or redeem 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 Example does not take into account brokerage commissions that you may pay on your purchases and sales of Shares. Although your actual
costs may be higher or lower, based on these assumptions your costs would be:

    1
    Year
    3
    Years

    $77
    $240