SecProbe.io

CORRESP
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November
7, 2023

Mr.
Raymond Be

Attorney-Adviser

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)

Tuttle
Capital 2X Long AI ETF

Tuttle
Capital 2X Inverse AI ETF

Dear
Mr. Be:

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. The comments related to Post-Effective Amendment (“PEA”) No. 67 to the registration statement of the Trust,
which was filed on August 2, 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 two new series of the Trust (as identified above) (each the “Fund” and collectively,
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”).

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 Mr. Be marked
pages of the revised disclosure.

 ● Please
be prepared to file BXT delaying amendments to resolve any comments from the SEC staff, in particular regarding the VaR calculations.

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

 ● Response: As
requested, the Trust will file this comment response letter on EDGAR and send via email to Mr. Be marked pages of the revised disclosure.
The Registrant acknowledges the Staff’s comment and will endeavor to work with the Staff to resolve all comments before going effective
on the Registration Statement. The Trust intends that new or revised disclosure that is similar to disclosure in other sections will
be applied consistently throughout the registration statement.

JOHN
H. LIVELY ● MANAGING PARTNER

11300
Tomahawk Creek Pkwy ● Ste. 310 ● Leawood, KS 66211
● p: 913.660.0778 ● c: 913.523.6112

Practus,
LLP ● John.Lively@Practus.com ● Practus.com

 Prospectus

1. Comment: Please
                                            add the word “Daily” to each Fund’s name in light of its objective to seek
                                            daily investment results that magnify (+/-200%) the daily performance of the underlying reference
                                            exchange-traded fund.

Response: Each
Fund has added “Daily” in its name. The Funds’ revised names are: “Tuttle Capital Daily 2X Long AI ETF”
and “Tuttle Capital Daily 2X Inverse AI ETF.”

2. Comment: Regarding
                                            the reference to swaps in footnote 3 of the Fee Table, please supplementally advise on the
                                            estimated costs of the swaps before going effective.

Response: The
total indirect cost of investing in swaps, including the embedded cost of the swaps, is estimated to be 0.196% for each Fund’s
first fiscal year.

Principal
Investment Strategies

3. Comment: The
                                            Fund’s name suggests that the Fund focuses on investments that provide 2X exposure
                                            to companies in AI-related industries (or index). Please adopt an 80% policy with respect
                                            to the Fund’s exposure to (or 80% of its assets in) investments that have twice the
                                            performance of the securities or referenced assets in the artificial intelligence-related
                                            industries.

Response: The
Funds’ investment objective is to seek daily investment results, before fees and expenses, of 200% (or -200%) of the daily performance
of the Syntax Emerging AI Leaders Index. The prospectus language has been revised to consistently state each Fund’s investment
objective and an 80% policy has been added.

4. Comment:
                                             The bolded text on Edgar page 3 appears to be taken from single-stock company ETFs.
                                            The staff notes it does not usually see this disclosure for ETF indices; at the very least,
                                            move this disclosure out of the Item 4 disclosure section and consider the appropriateness
                                            given the Fund is following an index.

Response: The
Registrant has deleted the text referenced by the Staff.

5. Comment: Please
                                            provide supplementally the white paper for the Emerging AI Leader Index, as well as a model
                                            portfolio identifying the issuer, index weight, country industry market-cap, and primary
                                            exchange listing. Please provide this information for the top 20 holdings based on the index
                                            methodology.

Response: The
Syntax Rulebook for the Syntax Emerging AI Leaders Index and a spreadsheet showing all of the current components of the Index are being
provided to the Staff supplementally.

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6. Comment: On
                                            page 4 in the section titled: “About the Syntax Emerging AI Leaders Index”, please
                                            disclose a reasonable definition to define the securities that comprise an industry; in particular,
                                            clarify in more detail the meaning of “principally engaged”. In addition, in
                                            the three AI industry business segments, discuss any thresholds regarding the extent to which
                                            companies “derive revenues” from certain activities in those business segments.

Response: The
disclosure has been revised consistent with the Staff’s comment.

7. Comment: The
                                            disclosure appears to only discuss the potential universe of investments. Please clarify
                                            how the index selects individual securities for inclusion.

Response: The
disclosure has been expanded consistent with the Staff’s comment.

8. Comment: Please
                                            advise and provide supplementally hypothetical VaR calculations demonstrating how the fund
                                            anticipates being able to achieve its objective while remaining in compliance with the VaR
                                            test under Rule 18f-4 (“Rule 18f-4”) under the Investment Company Act of 1940,
                                            as amended (“1940 Act”). In responding to this comment, please disclose: (i)
                                            the designated reference portfolio (DRP) that the funds plan to use, and (ii) how the DRP
                                            meets the definition of a designated reference portfolio and is in accordance with the requirements
                                            under Rule 18f-4.

Response:
 Under separate cover, the Registrant is providing the Staff with hypothetical VaR calculations based on each Fund’s anticipated
portfolio construction. Each Fund will use the S&P Kensho Moonshots Index (“Kensho Index”) as a designated reference
portfolio for purposes of the relative VaR calculations. The Kensho Index is an equity index that is designed to measure the performance
of 50 U.S.-listed companies with the highest Early-Stage Composite Innovation Score, subject to market capitalization and liquidity criteria,
that produce the products and services shaping the future. The Early-Stage Composite Innovation Score is based on a combination of the
resources a company allocates to innovation and the degree to which the company stresses an innovative culture and mission, as determined
by S&P Dow Jones Indices, the index provider for the Kensho Index. The Kensho Index 1) is not actively managed, 2) it not leveraged,
and 3) was not constructed specifically for this test. The Kensho Index has historical market data available for more than 3 years, and
reflects the markets or asset classes in which the Funds invest.

9. Comment:
                                            In the section titled “Derivatives Risk” under “Swap Agreement Risk,”
                                            are any of these swaps traded or individually negotiated? Please customize or tailor the
                                            disclosure to the fund’s particular situation to the extent the Fund will invest in
                                            non-traded swaps.

Response: The
Registrant believes that the disclosure referenced by the Staff clearly states that the swaps are not traded. No changes to the disclosure
are being made.

10. Comment: Given
                                            the Fund’s index is a bespoke, new index, please advise how many counterparties the
                                            Fund expects to use;

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 (a) Please
                                            advise as to how many counterparties the Fund expects to use and what percentage of the Fund’s
                                            assets and investment exposure are expected to be related to each of these counterparties.

 (b) If
                                            exposure to a particular counterparty is deemed to be material, please identify the counterparty
                                            in the prospectus and file the agreement with the counterparty as an exhibit to the registration
                                            statement.

 (c) If
                                            the notional exposure to a particular counterparty is likely to exceed 20% of the notional
                                            value of the Fund’s assets, if applicable, please disclose:

 (i) that
                                            the counterparty is subject to the informational requirements of the Exchange Act of 1934
                                            and in accordance with such requirements, files such reports and other information with the
                                            SEC; and

 (ii) the
                                            name of any national securities exchange on which the counterparty’s securities are
                                            listed, stating that reports (and where counterparty is subject to Sections 14(a) and 14(c)
                                            of the Exchange Act (proxy information statements) and other information concerning counterparty
                                            can be inspected at such exchanges.

If
the foregoing is not applicable, please advise how investors will be provided with similar information.

 (iii) For
any counterparties that are subsidiaries of any publicly traded companies for which there is sufficient market interest and publicly
available information, please disclose whether the debts of such counterparty will be recourse to the parent.

Response: The
Adviser intends to negotiate with at least six swap counterparties and initially expects to trade with at least three swap counterparties
for the Funds, each subject to the terms and conditions of an ISDA Master Agreement published by the International Swaps and Derivatives
Association and applicable Schedule and Credit Support Annex (“ISDA Agreement”). The Adviser will evaluate and monitor the
creditworthiness of the Funds’ counterparties in accordance with its counterparty due diligence policies and procedures.

The
Trust does not believe there will be a material concentration of investments (on a mark-to-market basis) in any specific swap counterparty.
The Trust expects that some of its swap counterparties will not be securities related issuers subject to Rule 12d3-1 under the 1940 Act
and therefore will not be subject to the 5% limit. However, each Fund will limit its mark-to-market exposure to any single swap counterparty
to 25% or less on a given day. Additionally, each Fund’s exposure will be fully collateralized each day, to the extent provided
for under its ISDA Agreements, to limit counterparty risk. For any swap counterparties that are deemed to be securities related issuers,
each Fund will comply with section (b) of Rule 12d3-1 and its mark-to-mark exposure will not exceed 5% of its total assets in any such
single securities related issuer. As such, the Trust does not believe any agreement with any such counterparty will rise to the level
of materiality requiring it to be filed as an exhibit to the Registration Statement.

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It
is likely that notional exposure to a particular counterparty will exceed 20% of a Fund’s total assets, however, Registrant believes
that the appropriate way to measure counterparty exposure is by limiting the mark-to-market exposure to the counterparty. As stated above,
the Adviser will evaluate and monitor the creditworthiness of counterparties, and mark-to-market exposure to any counterparty will be
limited to 25% or less, or, if the counterparty is a securities related issuer, 5% or less of the Fund’s total assets.

Registrant
does not believe that disclosure of its counterparties’ registration status under the Securities Exchange Act of 1934, and the
other information available on a national securities exchange on which a counterparties’ securities are listed, is material to
a shareholder because shareholders will rely upon the Adviser’s due diligence process and monitoring of counterparties, and shareholders
will have no way to evaluate the exposure to a given counterparty on a regular basis. Furthermore, the Staff has not identified any requirement
to include such disclosures regarding counterparties. The obligations of counterparties will be without recourse to the parent company,
whether or not the counterparty is a subsidiary of a public company.

11. Comment: Please
                                            advise whether the Adviser has had discussions with potential swap counterparties and what
                                            type of margin requirements are being considered. Include an analysis of any impact margin
                                            requirements are expected to have on the ability of each Fund to implement its strategies.

Response: As
noted in the response to the previous comment, the Adviser has been negotiating with potential swap counterparties and has discussed,
among other things, the margin requirements that will be required. As is standard under the Credit Support Annex of ISDA Agreements,
margin will be posted on a daily basis by the out of the money party, subject to certain rounding and threshold amounts. The Adviser
expects that each Fund could be required to post approximately 35% of its total assets as margin, but that amount could go higher depending
on market conditions. In any event, the Adviser does not expect margin requirements to have a material effect on each Fund’s ability
to implement its strategy because a very high percentage of each Fund’s assets will be in highly liquid inve