SecProbe.io

CORRESP
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November 15, 2023

VIA EDGAR
==========
Samantha Brutlag
Division of Investment Management
Securities and Exchange Commission
Filing Desk
100 F Street, N.E.
Washington, DC 20549

 RE: Zacks Trust; File Nos. 333-232634 and 811-23435

Dear Ms. Brutlag,

On September 1, 2023, Zacks Trust (the “Trust”
or the “Registrant”) filed a registration statement on Form N-1A (the “Registration Statement”) with respect to
the Zacks India ETF (the “Fund”). On October 11, 2023, you provided oral comments to the Registration Statement. Please find
below a summary of those comments and the Registrant's responses, which the Registrant has authorized us to make on behalf of the Registrant.

Prospectus:

Summary

Comment 1. Please provide a completed
fee table and expense example at least 5 days before the effectiveness of the Registration Statement.

Response. The Registrant has provided
the completed fee information below.

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”). Investors purchasing or selling Shares in the secondary
market may be subject to costs (including customary brokerage commissions) charged by their broker. These costs are not included in the
expense example below.

    Annual
    Fund Operating Expenses

    (ongoing expenses that you pay each year as a percentage of the value of your
    investment)

    Management Fees
    0.60%

    Distribution and Service (12b-1) Fees
    0.00%

    Other Expenses1
    1.02%

    Acquired Fund Fees and Expenses1
    0.01%

    Total Annual Fund Operating Expenses
    1.63%

    Fee Waiver and/or Expense Limitation2
    (0.87)%

    Net Annual Fund Operating Expenses
    0.76%

  Greenberg
Traurig, LLP n Attorneys
at Law n WWW.GTLAW.COM

3333 Piedmont Rd NE, Suite 2500 n
Atlanta, GA n
Tel 678.553.2432

 1. Estimated for the current fiscal year.

 2. The Fund’s adviser, Zacks Investment Management, Inc. (the “Advisor”) has contractually
agreed to reduce its fees and/or absorb expenses of the Fund, until at least April 1, 2026, to ensure that total annual fund operating
expenses after fee waiver and/or reimbursement (exclusive of any front-end or contingent deferred loads, taxes, brokerage fees and commissions,
borrowing costs (such as interest and dividend expense on securities sold short), acquired fund fees and expenses, fees and expenses associated
with investments in other collective investment vehicles or derivative instruments (including for example option and swap fees and expenses),
or extraordinary expenses such as litigation) will not exceed 0.75% of the Fund’s net assets. These fee waivers and expense reimbursements
are subject to possible recoupment from the Fund in future years (within the three years from the date the fees have been waived or reimbursed),
if such recoupment can be achieved within the lesser of the foregoing expense limits or those in place at the time of recapture. This
agreement may be terminated only by the Trust’s Board of Trustees on 60 days’ written notice to the Advisor.

Example. You may also incur usual and customary
brokerage commissions and other charges when buying or selling shares of the Fund, which are not reflected in the example that follows.
This example is intended to help you compare the cost of owning shares of 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 sell 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 includes the Fund’s contractual expense limitation until April 1, 2026.

Although your
actual costs may be higher or lower, based on these assumptions, your costs would be:

    One Year
    Three Years

    $78
    $339

Comment 2. The fee table indicates that
there will be an expense limitation agreement in place for the Fund. Please confirm that this agreement will be in place for at least
a year from the date of the Prospectus.

Response. The Registrant so confirms.

Comment 3. In “Principal Investment
Strategies”, in the second paragraph, please revise to be in plain English and clarify whether the higher growth rate over decades
to come is compared to now or compared to other countries.

Response. The Registrant has revised
the disclosure as requested. The Adviser has confirmed to the Registrant that the growth rate is compared to other emerging market countries.

Comment 4. In the section “Principal
Investment Strategies”, in the third paragraph, please clarify what a higher capacity for investment means.

Response. The Registrant has revised
the disclosure.

Additional Information About the Fund’s
Investment Objectives, Principal Investment Strategies, and Risks

Comment 5. In “Investment Objectives”
please reconcile the disclosure with Item 4.

Response. The Registrant has corrected
the error in the Item 9 disclosure.

*	*	*

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If you have any questions or comments, please
contact the undersigned at 678.553.2432. Thank you in advance for your consideration.

Sincerely,

/s/ Tanya L. Boyle

Tanya L. Boyle

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