SecProbe.io

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(212) 318-6095

thomaspeeney@paulhastings.com

December 16, 2025

Ms. Emily Rowland

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. Rowland:

On behalf of Gabelli Opportunities
in Live and Sports 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 November
25, 2025, in relation to Post-Effective Amendment No. 21 to the Trust’s Registration Statement on Form N-1A (the “Registration
Statement”) (Accession Number 0001829126-25-008045). 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
acknowledges the Staff’s 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
acknowledges the Staff’s comments and confirms that the Fund shall furnish responses at least five business days in advance of the
effective date.

December 16, 2025

Page 2

PROSPECTUS

Comment 3: The Fund’s name contains
two terms that are subject to Rule 35d-1 (the “Names Rule”) under the Investment Company Act of 1940, as amended: “live”
and “sports.” Please revise the Fund’s 80% policy to reflect both terms.

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

“The Fund is an actively managed exchange-traded
fund (“ETF”). Under normal market conditions, the Fund invests at least 80% of the value of its net assets in securities of
companies principally engaged in the group of industries comprising the live
media and entertainment and sports sectors sector.
As a fundamental policy, the Fund will concentrate (invest at least 25% of the value of its net assets) in the securities of companies
principally engaged in the group of industries comprising the live media
and entertainment and sports sectors sector.
The Fund may invest in the equity securities of such companies, such as common stock, or preferred stock of such companies in accordance
with the foregoing 80% policy. The Fund may also invest in foreign securities, including, but not limited to, direct investments in securities
of foreign issuers and investments in American Depositary Receipts that represent indirect investments in securities of foreign issuers.
The Fund may invest in companies without regard to market capitalization. In
addition, the Fund may invest up to 10% of the value of its net assets in option contracts in accordance with Rule 18f-4 under the 1940
Act.

The
Fund considers a company to be principally engaged in the live media and entertainment sector if it devotes a significant portion of its
assets to or derives at least 50% of its revenues from the development, production or distribution of live media and entertainment. Live
media and entertainment include, but are not limited to, television and radio stations, motion picture companies, print publishing and
providers of internet content, as well as satellite service providers, cable service providers and advertising service providers.

The Fund considers a company to be principally
engaged in the group of industries comprising the sports sector if it devotes a significant portion of its assets to or
, derives at least 50%
a significant portion of its revenues from, or has substantial
economic exposure to sports-related activities. Sports-related activities include,
but are not limited to, the following: (i) the direct operation
or ownership of sports teams or leagues; (ii) the development or monetization of sports-related real estate (e.g., stadiums, sports
resorts, or experiential venues such as golf and ski destinations)); (iii) the sale of sports-related products or services (e.g.,
athletic apparel, equipment, or ticketing); and (iv) sports media and content distribution. A company with indirect or adjacent exposure
to a sports-related activity—such as an event promoter, live entertainment company, or large conglomerate with
business lines that own or operate that owns or operates sports assets—may
also qualify for investment if the Adviser believes the sports-related component represents a meaningful portion of the company’s
business value.”

Comment 4: On page 3 of the Prospectus,
the disclosure states that, “[t]he Fund considers a company to be principally engaged in the group of industries comprising the
sports sector if it devotes a significant portion of its assets to, derives a significant portion of its revenues from, or has substantial
economic exposure to sports-related activities.” Please revise the “revenue” test to indicate that the portion of the
company’s revenues derived from sports-related activities must be greater than 50%, rather than a “significant portion.”
Please also delete “substantial economic exposure” test or explain in the disclosure how it differs from the “assets”
and “revenue” tests and how it would have a significant nexus to the Fund’s name.

Response: The Fund
respectfully acknowledges the comment and has revised the disclosure as shown in the response to Comment 3 above.

December 16, 2025

Page 3

Comment 5: On page 3 of the Prospectus,
the disclosure states, “[a] company with indirect or adjacent exposure to a sports-related activity—such as an event promoter,
live entertainment company, or large conglomerate that owns or operates sports assets—may also qualify for investment if the Adviser
believes the sports-related component represents a meaningful portion of the company’s business value.” Please revise this
disclosure to reflect that the term “live” will be treated the same way the term “sports” is treated with respect
to the Names Rule. Please also explain how a “large conglomerate” qualifies as “sports-related” or “live,”
and expand on how the Adviser would determine whether the “sports-related component represents a meaningful portion of the company’s
business value.”

Response: The Fund
respectfully acknowledges the comment and has revised the disclosure as shown in response to Comment 3 above.

Comment 6: In the “Investment Objectives,
Investment Strategies, and Related Risks” section of the Prospectus, on page 9, the “Concentration Risk” disclosure
includes “Communication Services Risk” and “Professional Sports Risk.” Please add summaries of those risks to
the “Concentration Risk” disclosure in the “Principal Risks” section on page 4 of the Prospectus.

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

“Concentration Risk. The Fund concentrates
its assets (i.e., invests 25% or more of its net assets) in securities of companies in the live
media and entertainment and sports sectors sector,
and, as a result, the Fund may be subject to greater volatility with respect to its portfolio securities than a fund that is more broadly
diversified. Accordingly, the Fund is subject to the risk that its performance may be hurt disproportionately by the poor performance
of relatively few securities. Risks associated with investments in the
live media and entertainment and sports sectors include, among others:

 • Communication Services Risk.
The Fund’s investments include securities issued by companies that conduct business in the communication services sector. The communication
services sector consists of, among other things, companies in the media and entertainment industry. Companies in the media and entertainment
industry group encompass a variety of services and products including television broadcasting, gaming products, social media, networking
platforms, online classifieds, online review websites and Internet search engines. The communication services sector is often subject
to extensive government regulation. The costs of complying with governmental regulations, delays or failure to receive required regulatory
approvals, or the enactment of new regulatory requirements may negatively affect the business of communications companies. Companies in
the communication services sector may encounter distressed cash flows due to the need to commit substantial capital to meet increasing
competition, particularly in developing new products and services using new technology. Communication services companies are particularly
vulnerable to the potential obsolescence of products and services due to technological advancement and the innovation of competitors.
While all companies may be susceptible to network security breaches, certain companies in the communication services sector may be particular
targets of hacking and potential theft of proprietary or consumer information or disruptions in service, which could have a material adverse
effect on their businesses. The Fund’s investments in the communication services sector include companies in the media and entertainment
industry, which are subject to risks that include competition, particularly with respect to products and services using new technologies;
high costs of production, research and development for new content, products and services; cyclicality of revenues and earnings; changing
consumer tastes and preferences; and decreases in the discretionary income of targeted consumers.

 • Professional
Sports Risk. Professional sports teams depend on the performance and/or popularity of their franchises, and they compete with
other sporting events, which are delivered through the Internet and online services (e.g., streaming), mobile applications, television
networks, radio and other sources. Professional sports teams also depend on attracting attendance to competitions at their home venues,
and they compete with other leisure-time activities and entertainment options such as television shows, motion pictures, concerts and
other live performances, restaurants, nightlife venues, Internet websites and other online applications such as social media and social
networking platforms, and other sources of entertainment. Economic downturns and other adverse conditions, such as suspension of sports
events or limitations on in-person attendance at such events, can negatively affect professional sports companies’ operations. Professional
sports companies also depend on the on-field success of their teams, which is affected by the teams’ ability to develop, obtain
and retain talented players.”

December 16, 2025

Page 4

Comment 7: Please tailor the “Communication
Services Risk” disclosure to the types of investments that the Fund will make.

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

“Communication Services Risk. The
Fund’s investments include securities issued by companies that conduct business in the communication services sector. The
communication services sector consists of, among other things,
both companies in the telecommunication services industry
as well as those in the media and entertainment industry. Companies in the media and entertainment industry group encompass
a variety of services and products including television broadcasting, gaming products, social media, networking platforms, online classifieds,
online review websites and Internet search engines. The communication
communications services sector of a country’s
economy is often subject to extensive government regulation. The costs of complying with governmental regulations, delays
or failure to receive required regulatory approvals, or the enactment of new regulatory requirements may negatively affect the business
of communications companies. Companies in the communication services sector may encounter distressed cash flows due to the need to commit
substantial capital to meet increasing competition, particularly in developing new products and services using new technology. Communication
services companies are particularly vulnerable to the potential obsolescence of products and services due to technological advancement
and the innovation of competitors. While all companies may be susceptible to network security breaches, certain companies in the communication
services sector may be particular targets of hacking and potential theft of proprietary or consumer information or disruptions in service,
which could have a material adverse effect on their businesses. The Fund’s
investments in the communication services sector include companies in the media and entertainment industry, which are subject to risks
that include competition, particularly with respect to products and services using new technologies; high costs of production, research
and development for new content, products and services; cyclicality of revenues and earnings; changing consumer tastes and preferences;
and decreases in the discretionary income of targeted consumers.”

Comment 8: On page 4 of the Prospectus,
the “New Fund Risk” disclosure states, “[h]owever, the fee waiver in place limits this risk for the periods that such
fee waiver is effective.” Please clarify which risks the fee waiver is limiting.”

Response: The Fund
respectfully acknowledges the comment and has deleted the referenced disclosure, as follows:

“New Fund Risk. The Fund is a new
fund with no operating history and may have higher expenses. There can be no assurance that the Fund will grow to or maintain an economically
viable size. The Fund could cease operations, and investors may be required to liquidate or transfer their assets at a loss. However,
the fee waiver in place limits this risk for the periods that such fee waiver is effective.”

Comment 9: Given the inclusion of “Growth
Stock Risk” and “Value Investing Risk” as principal risks, please add growth stocks and value stocks in the discussion
of the Fund’s principal investment strategies.

Response: The Fund
respectfully acknowledges the comment. With respect to “Value Investing Risk,” the Fund notes that its principal investment
strategies disclosure states:

“The Adviser’s investment philosophy
with respect to buying and selling equity securities is to identify assets that are selling in the public market at a discount to their
private market value (‘PMV’). The Adviser defines PMV as the value informed purchasers are willing to pay to acquire assets
with similar characteristics. … Further, the Adviser looks for a catalyst, something indigenous to the company, its industry or
geographic positioning that may surface additional value, including, but not limited to, industry developments, regulatory changes, changes
in management, sale or spin-off of a division, or the development of a profitable new business.”

The Fund believes this disclosure addresses the
Adviser’s approach to value investing and the corresponding ri