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CORRESP
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December
15, 2025

Emily
Rowland

U.S.
Securities and Exchange Commission

Division
of Investment Management

Disclosure
Review & Accounting Office

100
F Street, N.E.

Washington,
D.C. 20549

    Re:
    Gabelli ETFs Trust (the “Trust”)

Post-Effective
Amendment No. 23 to the Registration Statement on Form N-1A (the “Amendment”)

File
Nos.: 333-271700 and 811-23872

Dear
Ms. Rowland:

This
follow-up correspondence responds to certain additional comments received by the undersigned from the staff of the U.S. Securities and
Exchange Commission (the “Staff” of the “Commission”), with respect to the Amendment relating to
the Gabelli Growth Innovators ETF, Gabelli Love Our Planet & People ETF, Gabelli Global Technology Leaders ETF, Gabelli Commercial
Aerospace and Defense ETF (each a “Fund” and collectively, the “Funds”), each a series of the Trust.
For your convenience, your comments have been summarized with responses following each comment. Capitalized terms not otherwise defined
have the same meaning as in the Amendments.

Global
Technology Leaders ETF

 1. Comment:
                                            With respect to the Fund’s Principal Investment strategy, please supplementally explain
                                            how the Fund’s investment in five countries outside of the United States without noting
                                            a specific percentage of investment would result in a significant investment given that the
                                            Fund is a global fund.

Response:
The Registrant has amended the disclosure as follows:

As
a “global” fund, the Fund invests in securities of issuers, or related investments thereof, located in at least three countries
outside of the U.S., and at least 40% of the Fund’s total net assets are invested in securities of non-U.S. issuers or, if market
conditions are not favorable, the Fund will invest at least 25% of the Fund’s assets outside the U.S.

Statement
of Additional Information (“SAI”)

 2. Comment:
                                            In the SAI, with respect to the Fund’s policy on concentration, it is incorrect for
                                            an adviser not to look through the investments of unaffiliated investment companies if the
                                            Registrant knew or should have known the fund’s underlying positions.

Response:
The Registrant respectfully declines to further amend the Fund’s disclosure.

KAREN A. ASPINALL
● PARTNER

11300 Tomahawk Creek Pkwy,
Suite 310 ● Leawood, KS 66211 ● p: 949.629.3928

Practus, LLP ●
Karen.Aspinall@Practus.com ● Practus.com

If
you have any questions regarding the above responses, please do not hesitate to contact Karen Aspinall at 949.629.3928 or Karen.Aspinall@practus.com.

Sincerely,

/s/
Karen Aspinall

Karen
Aspinall

Partner

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