SecProbe.io

CORRESP
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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

December 13, 2024

Ms. Rebecca Marquigny

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)

  Tuttle Capital Congressional Trading ETF

Dear Ms. Marquigny:

This letter provides the responses
of ETF Opportunities Trust (the “Trust” or the “Registrant”) to the additional comments of the staff of the U.S.
Securities and Exchange Commission (the “Commission”) that you provided to Practus, LLP on December 10, 2024. The comments
related to Post-Effective Amendment (“PEA”) No. 139 to the registration statement of the Trust, which was filed on June 11,
2024, under Rule 485(a) of the Securities Act of 1933, as amended. The PEA was filed to register shares of a new series of the Trust,
the Tuttle Capital Congressional Trading ETF (the “Fund”). 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.

1. Comment:	In second paragraph under “Principal
                                       Investment Strategies,” the phrase “best returns over time” is used. How does
                                       the Adviser determine the best returns over time given the various tenures of the members of Congress?

  Response:	Registrant believes that the phrase “best returns over time”
               in the context in which it is used is clear. The prospectus states that the Adviser will obtain and utilize information
               from PTRs filed for the past three years, and that information reported in a PTR relates to a Congressperson’s trades
               while a member of Congress. In addition, the paragraph following the paragraph in which the language noted by the staff
               appears, clearly states that “equity securities acquired by Congressperson prior to his or her taking office are
               not considered when creating the initial portfolio.” As a result, Registrant believes that no changes in the prospectus
               disclosure is necessary to clarify that only trades made by a Congressperson while a member of Congress are considered
               in selecting securities for the Fund’s portfolio.

  The
disclosure has been revised to replace “best returns” with “highest total returns.”

2. Comment:	In the fourth paragraph of the second
                                       page of the prospectus, which discusses the adjustment of holdings, please address the following:
                                       How often does the Fund revisit the top 50 Congresspersons and otherwise adjust the 50 to 75 holdings
                                       throughout time.

  Response:	The disclosure has been revised to state that in addition to monitoring
               PTR filings after the establishment of an initial portfolio, the Adviser will periodically, the frequency of which is
               in the Adviser’s discretion, adjust the portfolio utilizing the same process as was used to create the initial portfolio.

Ms.
Rebecca Marquigny

U.S. Securities and Exchange Commission

December 13, 2024

3. Comment:	Best performance page 2, paragraph
                                            5 sentence one. How will best performance be determined?

  Response:	Best performance will be determined by ranking each Congressperson’s
               total return on their portfolio. The disclosure has been revised to replace “best performance” with “highest
               total return.”

4. Comment:	For clarity, please revise the second
                                       sentence in the fifth paragraph on page two of the prospectus. Specifically, it states “the
                                       estimated portfolio holdings of these Congresspersons are then used to rank the aggregate holdings
                                       of those congresspersons weighted based on the holdings of each security in each Congress person's
                                       portfolio compared to the aggregate holdings of the selected Congressperson.” (emphasis
                                       added)

  Response:	 This sentence has been revised to read as follows:

  The
portfolio holdings of these Congresspersons are then aggregated to determine the aggregate holdings of each security held by these Congresspersons
as a group, which are ranked by the total market value of the aggregate holdings.

  In
addition, a new sentence has been added to this paragraph as follows:

  The
weightings in the Fund’s portfolio of each security selected are determined by dividing the total market value of the aggregate
holdings of that security held by the selected Congresspersons as a group, by the total market value of the aggregate holdings of all
securities held by the selected Congresspersons as a group that were selected for inclusion in the Fund’s portfolio.

* 	*	 *

Please contact me at (913) 660-0778
regarding the responses contained in this letter.

  Sincerely,

  /s/ John H. Lively

  John H. Lively