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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

September 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 MSTR Daily Target ETF

T-Rex 2X Inverse MSTR 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 on August 23, 2024. The
comments related to Post-Effective Amendment (“PEA”) No. 146 to the registration statement of the Trust, which was filed on
June 27, 2024, 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 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 as correspondence on EDGAR.

 · 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 as early as possible prior to the current effective date. 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 Registrant will file 485BXT amendment(s) as may be necessary. 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

 1. 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. 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 BITA Tactical Exposure US Blockchain Index (“Index”) as a designated reference portfolio for purposes of the
relative VaR calculations. The Index tracks companies involved in the development of blockchain technologies and related cryptocurrency
activities, including trading, banking, and mining platforms.. 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 it reflects the markets
or asset classes in which the funds invest.

 2. 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.

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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:      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.

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 intends to 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.

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 3. Comment:      Please advise whether you have had discussions
with potential swap counterparties and what sort 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 45% 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 the Funds’ assets will be in highly liquid investments.

 4. 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.

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.

 5. Comment:      Please revise your Item 9 disclosure in the prospectus
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
disclosure has been revised in the prospectus consistent with the Staff’s comment.

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 6. Comment:      If a Fund gets sufficiently large, please advise whether and how its size could impact
trading in the underlying single stock and the resulting impacts on the Fund.

Response:      The
Trust does not currently expect that the Funds will have a material impact on the trading of the underlying issuers based on the anticipated
size of the Funds.

MSTR has significant market cap and trading
volume such that the trading resulting from the Funds’ counterparties hedging their positions is not expected to reach a level that
impacts the underlying.

 7. Comment:       Please demonstrate that each underlying issuer
meets the conditions for filing a shelf registration statement on Form S-3 given the Fund’s concentrated exposure to a single underlying
issuer.

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.

 8. Comment:      In the section of the prospectus titled, Principal
Risks – Effects of Compounding and Market Volatility Risk, briefly discuss how the underlying issuers have traded historically and
its context within the market. For example, has the security been volatile relative to the market as a whole, either in the long or short
term, or in response to particular events? If particular events, what sort of events have contributed to daily volatility rates.

Response:      The
Registrant has included the disclosures in the prospectus that are intended to be responsive to the Staff’s comment.

 9. Comment:      We note that the registration statement has significant
disclosures missing (e.g., blanks in historical daily volatility rate). To the extent that the Registrant provides these disclosures in
a Rule 485(b) filing, please provide your analysis for why Rule 485(b) allows for such disclosures to be added via that mechanism.

Response:      
Disclosures such as historical volatility rates are meaningful data points for investors, however, the Registrant does not believe this
information to be material, and ultimately, the Registrant is of the view that such disclosure is not absolutely necessary or required.
Accordingly, the Registrant is of the view that this information is not material and the lack of having this information in the PEA (filed
pursuant to Rule 485(a)) does not render the upcoming filing in which such information will be provided ineligible for filing under Rule
485(b). These disclosures will be included in the Rule 485(b) filing for investors as part of the final prospectus.

 10. Comment:      In the prospectus, under the section titled,
Principal Risks – Leverage Risk, the disclosure states that: To the extent that the instruments utilized by the Fund are thinly
traded or have a limited market, the Fund may be unable to meet its investment objective due to a lack of available investments or counterparties.
During such periods, the Fund’s ability to issue additional Creation Units
may be adversely affected. As a result, the Fund’s shares could trade at a premium or discount to their net asset value and/or the
bid-ask spread of the Fund’s shares could widen. Under such
circumstances, the Fund may increase its transaction fee, change its investment objective by, for example, seeking to track an alternative
security, reduce its leverage or close. Discuss briefly what notices or other actions will be taken in such circumstances.

Response:      In
the circumstances referenced in the Staff's comment, the Fund’s investment adviser will consult with counsel to the Registrant
and its Board of Trustees, and if determined to be necessary, the Fund will amend its prospectus as promptly as feasible under the circumstances
to in