SecProbe.io

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JOHN H. LIVELY, Managing Partner

john.lively@practus.com

11300 Tomahawk Creek Pkwy., Suite 310

Leawood, KS 66211

(913) 660-0778

August 23, 2023

Ms. Karen Rossotto

Senior Counsel

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: ETF Opportunities Trust (File Nos. 333-234544 and 811-23439)

REX IncomeMax AMD Strategy ETF

REX IncomeMax AMZN Strategy ETF

REX IncomeMax TSLA Strategy ETF

REX IncomeMax BIIB Strategy ETF

REX IncomeMax DIS Strategy ETF

REX IncomeMax EEM Strategy ETF

REX IncomeMax GDXJ Strategy ETF

REX IncomeMax GOOG Strategy ETF

REX IncomeMax META Strategy ETF

REX IncomeMax MSFT Strategy ETF

REX IncomeMax MSTR Strategy ETF

REX IncomeMax PYPL Strategy ETF

REX IncomeMax SLV Strategy ETF

REX IncomeMax SMH Strategy ETF

REX IncomeMax SNOW Strategy ETF

REX IncomeMax TLRY Strategy ETF

REX IncomeMax V Strategy ETF

Dear Ms. Rossotto:

This letter provides the responses
of ETF Opportunities Trust (the “Trust” or the “Registrant”) to the comments of the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) that you provided to Practus, LLP on July 31, 2023. The
comments related to Post-Effective Amendment (“PEA”) No. 60 to the registration statement of the Trust, which was filed on
July 10, 2023, pursuant to Rule 485(a) under the Securities Act of 1933, as amended (the “1933 Act”). The PEA was filed to
register shares of seventeen (17) new series of the Trust (as identified above) (each a “Fund”, and together the “Funds”).
For your convenience, I have summarized the comments in this letter and provided the Trust’s response below each comment. Capitalized
terms not defined in this letter shall have the same meaning ascribed to such term in the PEA. It is intended that any revisions to the
disclosures contained in the Funds’ prospectus and statement of additional information that are made in response to the comments contained herein will be reflected in another
post-effective amendment filing to the Trust’s registration statement this filed pursuant to Rule 485(b) under the 1933 Act (the
“485(b) filing”).

    	Ms. Karen Rossotto

U.S. Securities and Exchange Commission

August 23, 2023

Preliminary
or General Comments

 • Please file this comment response letter on EDGAR at least five
days prior to making the 485(b) filing and also send via email to Ms. Rossotto, marked pages of revised disclosure.

 • Please also apply any new or revised disclosure in one section
to similar disclosure in other sections throughout the registration statement for all Funds.

Response: As requested, the Trust will file
this comment response letter on EDGAR and send via email marked pages of the revised disclosure to Ms. Rossotto. The Trust intends that
new or revised disclosure that is similar to all Funds will be applied consistently to each Fund’s disclosure.

 Prospectus

 1. Comment: Please
                                            demonstrate that each underlying issuer is a domestic company eligible to use Form S-3 for
                                            a primary offering of non-investment grade securities pursuant to General Instruction I.B.1
                                            of that form.

Response:	Whether an underlying
issuer meets the conditions for filing a shelf registration statement on Form S-3 is a legal determination for the underlying issuer
and Registrant does not have all of the relevant facts to make this determination. Although the Registrant is not able to confirm that
the underlying issuers are eligible to use Form S-3, it is noted that each underlying issuer has filed a Form S-3 with the Commission,
except for iShares MSCI Emerging Markets ETF and Van Eck Junior Gold Miners ETF which each file a registration statement on Form N-1A,
and Snowflake, Inc. which files a registration statement on Form S-1.

 2. Comment:	In recent months, the staff
                                            has provided the Trust comments relating to other REX IncomeMax ETF filings using a similar
                                            strategy but with different reference issuers. Please confirm the Trust has considered the
                                            staff’s prior comments and has conformed, or intends to conform, the disclosure for
                                            all similar products.

Response:
The Trust has considered the Staff’s prior comments and intends to conform the disclosure, as necessary and applicable, to all
similar products.

 3. Comment:	Please
                                            provide a completed fee table prior to going effective in a Rule 485(b) filing. Please also
                                            confirm that expenses related to short sales are included in the Portfolio Turnover line
                                            item.

Response: Attached
as requested are the revised completed fee tables, which will be included in the full prospectus. The Funds do not engage in short sales.

2

    	Ms. Karen Rossotto

U.S. Securities and Exchange Commission

August 23, 2023

Principal
Investment Strategies

General Note to the Staff: The Trust believes
that the formatting of headers in the section titled “Principal Investment Strategies” may have caused some confusion on
the placement of disclosure in the prospectus and therefore, the formatting for the headers has been adjusted.

 4. Comment:
                                            In the section titled “Principal Investment Strategies” in the prospectus, please
                                            explain the meaning of: “while maintaining the opportunity for exposure to the share
                                            price.” Later in the same paragraph, the disclosure states the Fund “uses a synthetic
                                            covered call strategy to provide income and exposure to the share price returns.” To
                                            the extent these two sentences are inconsistent, please reconcile the disclosure.

Response:	 The Trust is not adjusting
the disclosure to address the Staff’s comment as the Trust, in consultation with the investment adviser to the Funds, believes
the statements identified in the comment are not inconsistent.

 5. Comment:	In
                                            the section titled “Principal Investment Strategies” in the prospectus, “The
                                            Fund will seek to employ its investment strategy as it relates to AMD regardless of whether
                                            there are periods adverse market, economic, or other conditions and will not seek to take
                                            temporary defensive positions during such periods.” Please explain how this is consistent
                                            with an actively managed ETF.

Response:	The Trust has added
the following disclosure to address the Staff’s comment: “While solely maintaining exposure to the underlying issuer, the
Fund will use derivatives to generate income in addition to seeking exposure to the underlying issuer, as such, over time, the Fund’s
performance is expected to differ from the underlying issuer’s performance. Premium income generated from the Fund’s derivatives
investments will be invested in U.S. Treasury securities and other money market instruments.”

 6. Comment:
                                            The Fund should include an 80% policy pursuant to Rule 35d-1 under the Investment Company
                                            Act of 1940.

Response:	The
Trust has added the following disclosure to the “Principal Investment Strategies” section in the prospectus: “The Fund,
under normal circumstances, invests in options contracts that provide exposure to [name of security] equal to at least 80% of its
net assets (plus the amount any borrowings for investment purposes).”

 7. Comment:
                                            In the section titled “Principal Investment Strategies” in the prospectus,
                                            explain in more detail in this discussion the synthetic covered call strategy.

Response:	The Trust
has added the following disclosure to the “Principal Investment Strategy” section in the prospectus: “As part of the
Fund’s synthetic covered call strategy, the Fund will purchase and sell a combination of standardized exchange-traded and/or FLexible
EXchange® (FLEX) call and put option contracts that are based on the value of he price returns of [the applicable
underlying stock], which is explained in more detail below.”

3

    	Ms. Karen Rossotto

U.S. Securities and Exchange Commission

August 23, 2023

 8. Comment:	In
                                            the section titled “Principal Investment Strategies” in the prospectus, please
                                            explain what a “premium” is and how it provides income to the Fund in the discussion
                                            that states the Fund’s “options contracts provide: … current income from
                                            the option premiums.”

Response:
The Trust has added the following disclosure to the “Principal Investment Strategy” as concerns income from options premiums:
“The Fund receives premiums from call option contracts sold. In selling call option contracts, the Fund sells an option in exchange
for a premium (i.e., income). Therefore, these premiums generate income for the Fund.”

 9. Comment:	In
                                            the section titled “Principal Investment Strategies” in the prospectus, the disclosure
                                            states the Fund does not invest directly in AMD. Please explain this statement considering
                                            the later disclosure concerning options contracts which states the Fund will be given “the
                                            right or obligation to receive or deliver shares of AMD.”

Response:
The Trust notes that the Funds’ investment adviser will “cash settle” its options contracts and the Fund does not
expect to receive or deliver shares of the underlying stock. The Trust has added clarifying disclosure to address the Staff’s comment.

 10. Comment:
                                            Please explain and disclose the types of instruments the Fund will use as stated in the sentence
                                            “However, in a synthetic covered call strategy, the investor (the Fund) does not own
                                            the underlying security, but rather seeks to synthetically replicate 100% of the price movements
                                            of the underlying security through the use of various investment instruments.”

Response:	The
Trust has added the following disclosure to the “Principal Investment Strategy”: “As further described herein, the
Fund pursues a strategy to provide income and to provide synthetic exposure to the share price of the [underlying stock]. In doing so,
the Fund invests in a combination of put and call options.”

 11. Comment:
                                            In the section of the prospectus titled: “Synthetic Covered Call Strategy,”
                                            please explain the meaning of the statement “allows the Fund to seek to participate….”in
                                            the first bullet point which states: “Synthetic long exposure to AMD, which allows
                                            the Fund to seek to participate in the changes, up or down, in the price of AMD’s stock.”
                                            Clarify if the Fund will have long exposure to AMD and through which instruments.

Response:	The
Trust has added the following disclosure to the section of the prospectus titled “Synthetic Covered Call Strategy”: “As
described in more detail below, the Fund will seek to provide synthetic long exposure to the [underlying stock] through the use of call
options and put options.”

4

    	Ms. Karen Rossotto

U.S. Securities and Exchange Commission

August 23, 2023

 12. Comment:
                                            In the section of the prospectus titled “Fund’s Return Profile vs AMD”,
                                            the disclosure states: “the combination of these investment instruments provides investment
                                            exposure to AMD equal to at least 100% of the Fund’s total assets.” Please clarify
                                            whether this is notional exposure and in the Principal Investments section, please explain
                                            the meaning of notional exposure. Please also explain how the 25% asset diversification test
                                            applicable to a RIC is consistent with 100% exposure.

	Response:	The
Trust has revised the disclosure to address the Staff’s comment.

 13. Comment:	Please
                                            remove the statement in the section titled “Principal Investment Strategies”
                                            in the prospectus (bolded text) that the adviser “has not made any due diligence inquiry
                                            with respect to the DBMF ETF.” Such a disclaimer is overbroad and inconsistent with
                                            an adviser’s fiduciary duties.

	Response:	The
Trust has revised the disclosure to address the Staff’s comment.

 14. Comment:
                                            In the section titled “Principal Investment Risks - Semiconductor Industry Risk”
                                            in the prospectus, please consider whether risk disclosure should be added regarding the
                                            U.S. dependence on Taiwan and U.S. and China relations.

Response:
The Trust has considered the need to include the disclosure and has determined that it is not needed at this time.

 15. Comment:	In
                                            the section titled “Principal Investment Risks - Price Participation Risk” in
                                            the prospectus, the disclosure states: “The value of the options contracts is affected
                                            by changes in the value and dividend rates of AMD…”. Please explain why and
                                            how dividend rates would impact the value of the options.

Response:	The
Trust has added the following disclosure to the section of the prospectus titled “Principal Investment Risks - Price Participation
Risk”: “Generally, options are valued taking into consideration a number of factors, including dividends paid by the
underlying issuer. The market will account for projected dividends receivable in the coming weeks and months up to the options expiration
date. Dividends impact the two types of options, calls and puts, in different ways. Put options tend to be more expensive since the exchange
automatically drops the stock price by the amount of the dividend. Call options tend to be cheaper due to the anticipated drop in the
price of the stock. Put options generally gain value as the price of the stock goes down. When the underlying stock goes ex-dividend,
call options will decline and put options will increase in value as the stock price reflects the dividend to be paid. High cash dividends
generally imply lower call premiums and higher put premiums.”

 16. Comment:
                                            In the section titled “Principal Investment Risks - Recent Market Events Risk”
                                            in the prospectus, please tailor the risks associated with the un