SecProbe.io

CORRESP
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January 3, 2024

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)

T-Rex 2X Long Apple Daily Target ETF

T-Rex 2X Inverse Apple Daily Target ETF

T-Rex 2X Long Alphabet Daily Target ETF

T-Rex 2X Inverse Alphabet Daily Target ETF

T-Rex 2X Long Microsoft Daily Target ETF

T-Rex 2X Inverse Microsoft Daily Target 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. 103 to the registration statement of the Trust, which was filed on October 25, 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 six 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”).

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.

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

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 as early as possible
prior to the current effective date. The Trust notes that given the substantial similarity in disclosures contained in the PEA relative
to similar disclosures for other funds following a similar strategy and advised by the same adviser as filed by the Trust, and in light
of certain commercial objectives associated with launching these Funds, the Trust is not able to file the comment response letter five
days in advance of effectiveness. 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.

 1. Comment:	Please advise on the following:

 (a) Approximately how many counterparties does the fund expect 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, 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;

 (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. 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 each Fund, 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.

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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.

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. 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 the counterparty is a subsidiary
of a public company or not.

 2. 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 investments.

 3. Comment:	Please disclose how the swap counterparties are
likely to hedge their exposure and what will occur if a counterparty terminates the relationship and there are only a few counterparties.
Please ensure that all material features of the contemplated swap agreements have been disclosed.

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Response:	The
Adviser expects the swap counterparties, which are major global financial institutions, to hedge their exposure after entering into swap
agreements with the Fund as they deem appropriate. While the methods and means by which any hedging activity is conducted falls within
the purview and discretion of the counterparty, generally the Adviser suspects that a swap counterparty would simultaneously hedge its
exposure to the contracts with a Fund by entering into positions that provide offsetting economic exposure to the underlying issuer in
the swap, with a profit for the respective counterparty equal to the difference between the margin payment received by the Fund and the
cost of this hedge.

If a counterparty terminates its relationship
with a Fund, the Adviser expects to be able to turn to other counterparties to sufficiently absorb the requisite exposure required by
the Fund to achieve its investment objective. In the event a Fund is unable to obtain investment exposure pursuant to its stated investment
objective due to an insufficient number of counterparties, the Adviser will make a recommendation to the Trust’s Board of Trustees,
and the Board of Trustees will determine the appropriate course of action for the Fund that is in the best interest of shareholders, which
may include, but is not limited to, a recommendation to change the investment objective of the Fund or the liquidation of the Fund.

The Registrant believes that all material
features of the contemplated swap agreements have been adequately disclosed.

 4. Comment:	Please revise your Item 9 disclosure to more
fully explain how the adviser determines the swaps’ notional exposure for a particular day, the impact that notional exposure would
have on fund returns, and the potential costs associated with rolling.

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

 5. Comment:	Please advise and provide supplementally
hypothetical VaR calculations demonstrating how each 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 each Fund plans 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. The Staff
also requests that the Funds’ effectiveness be delayed until the Staff has reviewed and resolved its review of the hypothetical
VaR calculations.

Response: 	The Registrant acknowledges
the Staff’s comment and will endeavor to work with the Staff to resolve all comments to the VaR calculations before going effective
on the Registration Statement.

Under separate cover, the
Registrant is providing the Staff with hypothetical VaR calculations based on each Fund’s anticipated portfolio construction. Each
of the Funds will use the Solactive FANG Innovation Index (“Index”) as a designated reference

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portfolio for purposes of
the relative VaR calculations. The Index is an equity index consisting of 15 technology stocks. The Index is intended to reflect the “FAANG”
(and other innovative peers) group of stocks. There are 8 core-components in the Index: Apple (AAPL), Amazon (AMZN), Meta Platforms (META),
Alphabet (GOOGL), Microsoft (MSFT), Netflix (NFLX), NVIDIA (NVDA), and Tesla (TSLA). Each of the 8 “core” holdings in the
portfolio are recognizable “FAANG” (or adjacent) technology names, with mega-market capitalizations, and domiciled in the
United States. These names were picked by Solactive for their track record of innovation in rapidly growing industries, such as e-commerce,
semiconductors, cloud computing and online streaming. The remaining 7 “non-core” components within the Index are determined
from the top traded U.S. technology stocks across a universe of these FactSet Industries: Semiconductors, Electronic Components, Electronic
Equipment/Instruments, Telecommunications Equipment, Computer Processing Hardware, Computer Peripherals, Computer Communications, Electronic
Production Equipment, Data Processing Services, Information Technology Services, Packaged Software, and Internet Software/Services. These
non-core holdings are meant to reflect the potential evolution of investor demand in the market; they are reconstituted quarterly according
to market capitalization and trading volumes and may change from time to time.

The Index rebalances monthly and reconstitutes
quarterly. The Index’s underlying composition is equally weighted across all stocks, providing a unique benchmark that allows for
a uniform performance-driven approach to investing. The Index 1) is not actively managed, 2) it not leveraged, and 3) was not constructed
specifically for this test. The Index has historical market data available for more than 3 years, and reflects the markets or asset classes
in which the Funds invest.

 6. Comment:	In the “Principal Risks” section
of the prospectus relating to the AAPL Funds, it does not appear that there is a risk factor related to the risk of investment exposure
to AAPL. Given these Funds’ high dependence on the performance of AAPL, please add a risk factor relating to investing in AAPL.

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

 7. Comment:	In the risk factor entitled “Intra-Day
Investment Risk,” Registrant discloses that an investor that purchases shares intra-day may experience performance that is greater
than, or less than, the Fund’s stated multiple of the underlying security. Supplementally advise, with a view toward improving the
disclosure, how an investor will know what exposure the Fund will provide to the underlying security on any given day, when the exposure
is not 2x.

Response:	As
stated in the disclosure, the Fund seeks leveraged investment results from the close of the market on a given trading day until the close
of the market on the subsequent trading day. As a result, if an investor purchases shares intra-day at a market price that differs from
the prior days’ net asset value, the investor’s return will differ from the Fund’s net asset value return. The Registrant
believes that the disclosure adequately addresses this risk.

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 8. Comment:	For the GOOG Funds, the “Principal Investment
Strategies” section of the prospectus states that GOOG is currently assigned to the Communication Services sector and Interactive
Media & Services industry, however, the Principal Risks section includes “Internet Company Industry Risk” and “Technology
Sector Risk” but not “Communication Services Sector Risk” or “Interactive Media & Services Industry Risk.”
Please harmonize the “Principal Investment Strategies” and “Principal Risks” sections of the prospectus with respect
to these Funds.

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

 9. Comment:	In the risk disclosures of the inverse Funds,
it appears that the risk factors that are disclosed would positively affect the inverse Funds’ performance. G