SecProbe.io

CORRESP
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(212) 318-6095

thomaspeeney@paulhastings.com

October 24, 2025

Ms. Yoon Choo

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549

Re:  Gabelli ETFs Trust

                                            File Numbers: 333-238109; 811-23568

Dear Ms. Choo:

On behalf of Keeley Dividend ETF
(the “Fund”), a series of Gabelli ETFs Trust, a Delaware statutory trust (the “Trust”), we hereby file with the
staff (the “Staff”) of the Division of Investment Management of the Securities and Exchange Commission (the “Commission”)
this letter in response to the Staff’s recent oral comments to the undersigned received on September 24, 2025, in relation to Post-Effective
Amendment No. 16 to the Trust’s Registration Statement on Form N-1A (the “Registration Statement”) (Accession Number
0001829126-25-006200). As requested, the Fund has filed this letter at least five business days prior to the effectiveness of the Registration
Statement in accordance with ADI 2019-07, after which the Fund will file a post-effective amendment (the “Amendment”) to the
Registration Statement that will include appropriate revisions in response to the Staff’s comments.

For convenience of reference,
the Staff’s comments have been reproduced herein. All capitalized terms used but not defined in this letter have the meanings given
to them in the Registration Statement. Where the Fund has revised certain disclosure in the Registration Statement in response to a comment,
additions are underlined and deletions are struck.

General Comments

Comment 1: Please be reminded that the company
and its management are responsible for the accuracy and adequacy of their disclosures notwithstanding any review, comments, actions, or
absence of actions by the Commission.

Response: The Fund respectfully
acknowledges the comment.

Comment 2: Please provide your responses to
the Staff’s comments at least five business days prior to the filing’s effective date. Also, where a comment is made with
respect to disclosure in the filing, it will apply to all similar disclosures found elsewhere.

Response: The Fund respectfully
acknowledges the comment and confirms that the Fund shall furnish responses at least five business days in advance of the effective date.

    October 24, 2025
 Page 2

PROSPECTUS

Comment 3: On page 2 of the Prospectus, under
the heading “Fees and Expenses of the Fund,” the last two line items under “Annual Fund Operating Expenses” are
“Less Fee Waiver and/or Expense Reimbursement” and “Total Annual Fund Operating Expenses After Fee Waiver.” In
order to be shown in the fee table, the waiver must last at least one year from the effective date of the Fund’s registration statement
and may not be capped as indicated in footnote 2. See Instruction 3(e) to Item 3 of Form N-1A. Please revise the waiver to
apply for at least one year for all of the Fund’s assets, or revise the fee table to remove the fee waiver line and show the full
management fee under “Total Annual Fund Operating Expenses.” If the waiver agreement is amended to comply with Instruction
3(e) to Item 3, please add to the footnote whether the Adviser can recoup waived fees and, if so, the conditions of any recoupment.

Response: The Fund respectfully
acknowledges the comment and has revised the disclosure to state that the fee waiver agreement will continue for at least one year from
the effective date of the Fund’s Registration Statement. The Fund has also revised footnote 2 to disclose that the Adviser is not
permitted to recoup waived fees.

Comment 4: On page 2 of the Prospectus, under
the heading “Fees and Expenses of the Fund,” footnote (1) states that the investment advisory agreement provides that the
Adviser will pay all operating expenses of the Fund, except, among other things, distribution fees or expenses. Please supplementally
explain whether the Fund pays distribution expenses and, if so, please explain how the Fund is able to pay distribution expenses without
an effective Rule 12b-1 plan.

Response:
The Fund respectfully acknowledges the comment and notes that, as disclosed in the SAI, although the Board has adopted a Rule 12b-1 plan
for the Fund, the Fund does not impose Rule 12b-1 fees and has no plans to impose such fees in the future.

Comment 5: Unless the fee waiver agreement
is amended to comply with Instruction 3(e) to Item 3 of Form N-1A, please revise the figures in the “Expense Example” on page
2 to reflect the full management fee.

Response: The Fund respectfully
acknowledges the comment and notes that, because the Fund has revised the fee waiver agreement to comply with Instruction 3(e) to Item
3 of Form N-1A (as indicated in the response to Comment 3 above), the Fund has not revised the figures in the “Expense Example.”

Comment 6: On page 3 of the Prospectus, under
the heading “Principal Investment Strategies,” the disclosure states that the Fund seeks to achieve its investment objective
by investing at least 80% of its net assets in “in equity securities of companies that pay dividends (or are expected to do so in
the near term) (‘dividend-paying stocks’).” Does this mean (i) “equity securities that pay dividends” or
(ii) “equity securities of companies that are paying dividends” regardless of whether the equity securities in which
the Fund is investing is paying dividends? Please consider revising the disclosure to clarify.

Response: The Fund respectfully
acknowledges the comment and has revised the disclosure as follows:

“The Fund seeks to achieve its investment
objective by investing, as a principal strategy, at least 80% of its net assets (plus the amount of any borrowings for investment purposes)
in common stocks and other equity-type securities (such as preferred stock,
convertible debt securities and warrants) of dividend-paying companies equity securities of companies
that pay dividends (or are expected to do so in the near term) (‘dividend-paying stocks’), as defined below.
Equity securities include common and preferred stock; rights, warrants or options to purchase common
or preferred stock; securities that may be converted into or exchanged for common or preferred stock (such as convertible preferred stock
and convertible debt); and other securities with equity characteristics. While the Fund expects to invest primarily in
small- and mid-cap companies, it may invest in companies of any market capitalization.

‘Dividend-paying companies stocks’
have one or more of the following characteristics: (i) attractive dividend yields that, in the opinion of the Adviser, are
relatively stable or expected to grow; (ii) that pay a small dividend, but could grow their dividend over the next few years; and
(iii) that pay no dividend, but may initiate a dividend or return cash to shareholders in other ways, such as a share repurchase
program. The Adviser believes that a track record of dividend increases is an excellent indicator of a company’s financial
health and growth prospects, and that over the long term, income can contribute significantly to total return. Dividends also can
help reduce the Fund’s volatility during periods of market turbulence and can help offset losses when stock prices are
falling.”

    October 24, 2025
 Page 3

Comment 7: On pages 2-3 of the Prospectus,
under the heading “Principal Investment Strategies,” the disclosure states that “equity securities” include investments
that are neither equity securities nor paying dividends, including rights, warrants and options. If accurate, please revise the 80% policy
to include investments in instruments that provide exposure to equity securities that pay dividends.

Response: The Fund respectfully
acknowledges the comment and has removed the reference to rights, warrants and options, as shown in the response to Comment 6 above.

Comment 8: On page 2 of the Prospectus, under
the heading “Principal Investment Strategies,” the disclosure states that the Fund seeks to achieve its investment objective
by investing in equity securities of companies that pay dividends (or are expected to do so in the near term).” (emphasis
added) Securities that are expected to pay dividends in the near term do not currently pay dividends. Please delete “(or are expected
to do so in the near term)” or supplementally explain why these securities should be considered dividend-paying stocks.

Response: The Fund respectfully
acknowledges the comment and has removed the referenced disclosure, as shown in the response to Comment 6 above.

Comment 9: On pages 2-3 of the Prospectus,
under the heading “Principal Investment Strategies,” the disclosure states that “equity securities” include, among
other things, “securities that may be converted into or exchanged for common or preferred stock (such convertible preferred stock
and convertible debt).” Convertible debt pays interest, not dividends. Please remove the reference to convertible debt from the
definition of “equity securities” for purposes of the Fund’s 80% policy.

Response: The Fund respectfully
acknowledges the comment and has removed the definition of “equity securities,” as shown in the response to Comment 6
above.

Comment 10: On pages 2-3 of the Prospectus,
under the heading “Principal Investment Strategies,” the disclosure states that “equity securities” include, among
other things, “other securities with equity characteristics.” If any investments under this catch-all may be principal investments
of the Fund, please disclose with specificity.

Response: The Fund respectfully
acknowledges the comment and has removed the definition of “equity securities,” as shown in the response to Comment 6 above.

Comment 11: On page 3 of the Prospectus,
under the heading “Principal Investment Strategies,” the disclosure states, “‘Dividend-paying stocks’
have one or more of the following characteristics: … (iii) that pay no dividend, but may initiate a dividend or return cash
to shareholders in other ways, such as a share repurchase program.” Such stocks may not be counted as “dividend-paying
stocks” for purposes of the Fund’s 80% policy. Stocks that “may initiate a dividend” do not currently pay
dividends, and the return of cash to shareholders “in other ways” are not dividends and may have very different tax
consequences for shareholders. Please delete or supplementally explain why these qualify as dividend-paying stocks.

    October 24, 2025
 Page 4

Response: The Fund respectfully
acknowledges the comment and has revised the 80% policy to refer to dividend-paying companies, rather than dividend-paying stocks,
as shown in the response to Comment 6 above.

Comment 12: On page 3 of the Prospectus, under
the heading “Principal Investment Strategies,” rights, warrants and options are listed as part of the Fund’s principal
investment strategies. Please disclose how the Fund intends to use these derivatives as part of the strategy.

Response: The Fund respectfully
acknowledges the comment and has removed the reference to rights, warrants and options, as shown in response to Comment 6 above.

Comment 13: Under the heading “Principal
Risks,” please add risk disclosure on those derivative instruments that are part of the Fund’s principal investment strategy.

Response: The Fund respectfully
acknowledges the comment and notes that derivative instruments are not part of the Fund’s principal investment strategy, as shown
in the response to Comment 6 above.

Comment 14: If “Foreign Securities Risk”
is a principal risk of the Fund, please add disclosure in the “Principal Investment Strategies” section on investments in
foreign securities, and disclose any limits on investments in foreign securities. In addition, “Eurozone Risk” is listed as
a principal risk of the Fund. Please add reference to investments in this region in the “Principal Investment Strategies”
section. “ADR Risk” is included as a principal risk. In the “Principal Investment Strategies” section, please
disclose that the Fund may invest in foreign securities through ADRs.

Response: The Fund respectfully
acknowledges the comment and has removed “Foreign Securities Risk,” “Eurozone Risk” and “American Depositary
Receipts (‘ADRs’) Risk” from the “Principal Risks” section.

Comment 15: In the “Principal Risks”
section, please add disclosure to “Market Trading Risk” and “Absence of an Active Market” indicating that these
risks may cause the bid/ask spread to widen.

Response: The Fund respectfully
acknowledges the comment and revised the “Market Trading Risk” and “Absence of an Active Market” risk factors
as follows:

Market Trading Risk. Individual Fund
shares may be purchased and sold only on a national securities exchange or alternative trading system through a broker-dealer, and
may not be directly purchased or redeemed from the Fund. There can be no guarantee that an active trading market for shares will
develop or be maintained, or that their listing will continue unchanged. Buying and selling shares may require you to pay brokerage
commissions and expose you to other trading costs. Due to brokerage commissions and other transaction costs that may apply, frequent
trading may detract from realized investment returns. Trading prices of shares may be above, at, or below the Fund’s NAV, will
fluctuate in relation to NAV based on supply and demand in the market for shares and other factors, and may vary significantly from
NAV during periods of market volatility. The return on your investment will be reduced if you sell shares at a greater discount or
narrower premium to NAV than when you acquired shares. In addition,
the market price of shares includes a “bid-ask spread” charged by the market makers or other participants that trade the
shares. The spread of the Fund’s shares varies over time based on the Fund’s trading volume and market liquidity and may
increase if the Fund’s trading volume, the spread of the Fund’s underlying securities, or market liquidity
decrease.

Where
all or a portion of the Fund’s underlying securities trade in a foreign market that is closed when the domestic market in which
the Fund’s shares are listed and trading is open, there may be changes between the last quote from the closed foreign market and
the value of such underlying security during the Fund’s domestic trading day. This could lead to differences between the market
price of the Fund’s shares and the underlying value of the shares.

[…]

Absence of an Active Market. Although shares
of the Fund are listed for trading on one or more stock exchanges, there can be no assurance that an active trading market for such shares
will develop or be maintained by market makers or Authorized Participants. Authorized Participants are not obligated to execute purchase
or redemption orders for Creation Units. Because this is a novel and unique structure, this could influence
the number of entities willing to act as Authorized Participants. In periods of market volatility, market makers and/or
Authorized Participants may be less willing to transact in Fund shares. The absence of an active market for the Fund’s shares may
lead to wider bid-ask spreads and may contribute to the Fund’s
shares trading at a premium or discount to NAV. If a shareholder purchases Fund shares at a time when the market price is at a premium
to the NAV or sells Fund shares at a time when the market price is at a discount to the NAV, the shareholder may sustain losses.”

    October 24, 2025
 Page 5

Comment 16: In the “Principal Risks”
section, in “Absence of an Active Market,” the disclosure states, “Because this is a novel and unique structure, this
could influence the number of entities willing to act as Authorized Participants.” The ETF structure is well established and commonly
used. Please delete this sentence.

Response: The Fund respectfully
acknowledges the comment and has deleted the referenced sentence, as shown in the response to Comment 15 above.

Comment 17: On page