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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 13, 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 AMC DAILY TARGET ETF
    T-REX 2X INVERSE AMC DAILY TARGET ETF

    T-REX 2X LONG GME DAILY TARGET ETF
    T-REX 2X INVERSE GME DAILY TARGET ETF

    T-REX 2X LONG HOOD DAILY TARGET ETF
    T-REX 2X INVERSE HOOD DAILY TARGET ETF

    T-REX 2X LONG SMCI DAILY TARGET ETF
    T-REX 2X INVERSE SMCI DAILY TARGET ETF

    T-REX 2X LONG DJT DAILY TARGET ETF
    T-REX 2X INVERSE DJT DAILY TARGET ETF

    T-REX 2X LONG MARA DAILY TARGET ETF
    T-REX 2X INVERSE MARA DAILY TARGET ETF

    T-REX 2X LONG RBLX DAILY TARGET ETF
    T-REX 2X INVERSE RBLX DAILY TARGET ETF

    T-REX 2X LONG PLTR DAILY TARGET ETF
    T-REX 2X INVERSE PLTR DAILY TARGET ETF

    T-REX 2X LONG VKTX DAILY TARGET ETF
    T-REX 2X INVERSE VKTX DAILY TARGET ETF

    T-REX 2X LONG ARM DAILY TARGET ETF
    T-REX 2X INVERSE ARM DAILY TARGET ETF

    T-REX 2X LONG SHOP DAILY TARGET ETF
    T-REX 2X INVERSE SHOP DAILY TARGET ETF

    T-REX 2X LONG AMD DAILY TARGET ETF
    T-REX 2X INVERSE AMD DAILY TARGET ETF

    T-REX 2X LONG NFLX DAILY TARGET ETF
    T-REX 2X INVERSE NFLX DAILY TARGET ETF

    T-REX 2X LONG BA DAILY TARGET ETF
    T-REX 2X INVERSE BA DAILY TARGET ETF

    T-REX 2X LONG SNOW DAILY TARGET ETF
    T-REX 2X INVERSE SNOW DAILY TARGET ETF

    T-REX 2X LONG AVGO DAILY TARGET ETF
    T-REX 2X INVERSE AVGO DAILY TARGET ETF

    T-REX 2X LONG PANW DAILY TARGET ETF
    T-REX 2X INVERSE PANW DAILY TARGET ETF

    T-REX 2X LONG TSM DAILY TARGET ETF
    T-REX 2X INVERSE TSM DAILY TARGET ETF

    T-REX 2X LONG SQ DAILY TARGET ETF
    T-REX 2X INVERSE SQ DAILY TARGET ETF

    T-REX 2X LONG TLRY DAILY TARGET ETF
    T-REX 2X INVERSE TLRY DAILY TARGET ETF

    T-REX 2X LONG AI DAILY TARGET ETF
    T-REX 2X INVERSE AI DAILY TARGET ETF

    T-REX 2X LONG COIN DAILY TARGET ETF
    T-REX 2X INVERSE COIN 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. 142 to the registration statement of the Trust, which was filed on
June 18, 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 forty-four 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”). This letter also responds to an additional comment received from the Staff
on September 13, 2024, which is included as comment #26 below.

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

Please be advised that each
of the following Funds included in the PEA will not be included in the Trust’s subsequent 485(b) filing under the 1933 Act, and
accordingly, these Funds will not become effective thereunder, and will not be offered or commence operations. Further, each such Fund’s
series and class IDs on the EDGAR system will be removed.

 - T-REX 2X LONG AMC DAILY TARGET ETF

 - T-REX 2X INVERSE AMC DAILY TARGET ETF

 - T-REX 2X LONG TLRY DAILY TARGET ETF

 - T-REX 2X INVERSE TLRY DAILY TARGET ETF

 - T-REX 2X LONG VKTX DAILY TARGET ETF

 - T-REX 2X INVERSE VKTX DAILY TARGET ETF

 - T-REX 2X INVERSE AI DAILY TARGET ETF

 - T-REX 2X INVERSE RBLX DAILY TARGET ETF

 - T-REX 2X INVERSE DJT DAILY TARGET ETF

 - T-REX 2X INVERSE SMCI DAILY TARGET ETF

 - T-REX 2X INVERSE ARM DAILY TARGET ETF

 - T-REX 2X INVERSE GME DAILY TARGET ETF

 - T-REX 2X INVERSE HOOD DAILY TARGET ETF

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.

 1. Comment: We note the large number of Funds you are submitting
in this filing. Supplementally advise us with the anticipated launch schedule for all of the series.

Response:	The
Registrant will undertake to advise the Staff of the launch date for each Fund. The investment adviser to the Funds has advised that
in the near term, it is anticipated that 3-5 Funds will commence operations.

 2. 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. Below are the Designated Reference Portfolios (DRP):

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 1. BITA Tactical Exposure US Blockchain Index: This index tracks companies
involved in the development of blockchain technologies and related cryptocurrency activities, including trading, banking, and mining platforms.

Respective Funds:

 o T-REX 2X LONG GME DAILY TARGET ETF

 o T-REX 2X LONG COIN DAILY TARGET ETF

 o T-REX 2X INVERSE COIN DAILY TARGET ETF

 o T-REX 2X LONG MARA DAILY TARGET ETF

 o T-REX 2X INVERSE MARA DAILY TARGET ETF

 o T-REX 2X LONG SQ DAILY TARGET ETF

 o T-REX 2X INVERSE SQ DAILY TARGET ETF

 o T-REX 2X LONG HOOD DAILY TARGET ETF

 2. BITA Tactical Exposure US Semiconductors Index: This index tracks
companies involved in the manufacturing of semiconductors, semiconductor equipment, and related products.

Respective Funds:

 o T-REX 2X LONG AMD DAILY TARGET ETF

 o T-REX 2X INVERSE AMD DAILY TARGET ETF

 o T-REX 2X LONG SMCI DAILY TARGET ETF

 o T-REX 2X LONG ARM DAILY TARGET ETF

 o T-REX 2X LONG TSM DAILY TARGET ETF

 o T-REX 2X INVERSE TSM DAILY TARGET ETF

 o T-REX 2X LONG AVGO DAILY TARGET ETF

 o T-REX 2X INVERSE AVGO DAILY TARGET ETF

 3. BITA Tactical Exposure US Social Media Index: This index tracks companies
within the social media sector, which provide platforms and services for social networking, user-generated content, digital advertising,
and user engagement.

Respective Funds:

 o T-REX 2X LONG NFLX DAILY TARGET ETF

 o T-REX 2X INVERSE NFLX DAILY TARGET ETF

 o T-REX 2X LONG RBLX DAILY TARGET ETF

 o T-REX 2X LONG DJT DAILY TARGET ETF

 4. BITA Tactical Exposure US Airlines and Aerospace Index: This index
tracks companies engaged in the operation of airlines and the manufacturing, maintenance, and support of aerospace technology, including
commercial and defense aircraft, spacecraft, and related systems and components.

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Respective Funds:

 o T-REX 2X LONG BA DAILY TARGET ETF

 o T-REX 2X INVERSE BA DAILY TARGET ETF

 5. BITA Tactical Exposure US Artificial Intelligence Index: Companies engaged in the development, application, and provision of artificial intelligence technologies,
including machine learning, natural language processing, computer vision, robotics, and other AI-driven solutions that enable automation,
data analysis, and intelligent decision-making across various industries.

Respective Funds:

 o T-REX 2X LONG PANW DAILY TARGET ETF

 o T-REX 2X INVERSE PANW DAILY TARGET ETF

 o T-REX 2X LONG AI DAILY TARGET ETF

 o T-REX 2X LONG PLTR DAILY TARGET ETF

 o T-REX 2X INVERSE PLTR DAILY TARGET ETF

 o T-REX 2X LONG SNOW DAILY TARGET ETF

 o T-REX 2X INVERSE SNOW DAILY TARGET ETF

 6. BITA Tactical Exposure US Software Technology and Services Index: Companies involved in the development
and provision of software technology and services, including software development, IT consulting, cloud computing, and other technology-related
services that support digital transformation and enterprise solutions.

Respective Funds:

 o T-REX
2X LONG SHOP DAILY TARGET ETF

 o T-REX
2X INVERSE SHOP DAILY TARGET ETF

The Funds will
use the above indices (“the Indices”) as DRPs for relative VaR calculations. These Indices aim to capture the performance
of publicly traded companies highly responsive to market movements within their respective sectors. They provide targeted exposure to
innovative sectors and themes by tracking stocks expected to exhibit significant reactions to market changes. The selection and weighting
of companies are based on the historical variance of their returns, ensuring the indices include stocks with the highest sensitivity to
sector-specific market dynamics and allowing for tactical market trend capture.

Each Index consists
of five components with market capitalizations greater than $50 million and a 3-month average daily trading volume (ADTV) exceeding $1
million. The Indices: 1) are not actively managed, 2) are not leveraged, and 3) were not specifically constructed for this test. They
have historical market data available for more than three years and reflect the markets and asset classes in which the Funds invest. Additionally,
each underlying reference asset is or has been a component in its respective Index (most cases).

Based on these factors, the
Funds’ derivatives risk manager believes the Indices accurately reflect the markets and asset classes in which each Fund invests.
Each Fund will adopt the Indices as its designated reference index prior to commencing operations.

 3. 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.

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 (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.

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.

The Registrant believes that it is unlikely
that notional exposure to a particular counterparty will exceed 20% of a Fund’s total assets.  However, in the circumstance that
notional exposure to a particular counterparty exceeds 20% of a Fund’s total assets, the 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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 4. 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