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

March 25, 2025

Ms. Jaea Hahn

Ms. Kalkidan Ezra

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)

Dear Ms. Hahn and Ms. Ezra:

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 February 25, 2025. The
comments related to Post-Effective Amendment (“PEA”) No. 209 to the registration statement of the Trust, which was filed on
January 10, 2025, under Rule 485(a) of the Securities Act of 1933, as amended. The PEA was filed to register shares of ten new series
of the Trust, the Tuttle Capital AAPL 0DTE Covered Call ETF, Tuttle Capital GOOGL 0DTE Covered Call ETF, Tuttle Capital META 0DTE Covered
Call ETF, Tuttle Capital TSLA 0DTE Covered Call ETF, Tuttle Capital NVDA 0DTE Covered Call ETF, Tuttle Capital AMZN 0DTE Covered Call
ETF, Tuttle Capital MSFT 0DTE Covered Call ETF, Tuttle Capital MSTR 0DTE Covered Call ETF, Tuttle Capital COIN 0DTE Covered Call ETF,
and Tuttle Capital IBIT 0DTE Covered Call ETF (each a “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.

General Comments

 ● Please
file this comment response letter on EDGAR such that the Staff has at least five business days to review. Email redlines of changed pages.

 ● Please
also apply any new or revised disclosure in one section to similar disclosure in other sections throughout the registration statement.
Identify and explain any variations in the disclosures.

 ● Fill
in any bracketed language, placeholder language, charts or tables that are missing any information prior to going effective.

Response: The Trust acknowledges
the points made above in the “General Comments.”

    Jaea Hahn and Kalkidan Ezra
 U.S. Securities and Exchange Commission
 March 25, 2025

Prospectus

 1. Comment: It is the Staff’s understanding that 0DTE options on the asset referenced
by each series, for example, Apple, Meta, or IBIT, are not currently available to invest in. Please revise the Principal Investment Strategies
disclosure to reflect how each Fund will implement its strategy at the launch date of the Funds. The Staff requests that the Registrant
BXT until 0DTE options are available. Provide the staff a redline of the proposed revisions.

Response:
The Trust has revised the disclosure in response to the Staff’s comment. The Trust notes that each Fund is currently able to write
or purchase 1DTE FLEX Options on each Underlying Security except for IBIT. When the Fund purchases 1DTE FLEX Options on the Underlying
Security, it is then able to purchase 0DTE Flex Options on that Underlying Security the next day to achieve the 0DTE exposure.

Investment Objective

 2. Comment: The Staff notes that the covered call strategy provides exposure to the underlying
security subject to a cap, as applicable. Please clarify the secondary investment objective which states that the second objective is
to provide capital appreciation.

Response:
The Trust declines to make any changes to the Fund’s secondary investment objective. The Trust has revised the secondary investment
objective disclosure in the principle investment strategies section.

Fees and Expenses
of the Fund

 3. Comment: Provide completed fee tables and expense examples for Staff review.

Response:
The completed fee table and expense examples are below.

    Annual Fund Operating Expenses

(expenses that you pay each year as a percentage of the value of your investment)

    Management Fee(1)
    0.95%

    Distribution (12b-1) and Service Fees
    0.00%

    Other Expenses(2)
    0.00%

    Total Annual Fund Operating Expenses
    0.95%

 (1) Under the Investment Advisory Agreement, Tuttle Capital Management,
LLC (the “Adviser”), at its own expense and without reimbursement from the Fund, pays all of the expenses of the Fund, excluding
the advisory fees, interest expenses, taxes, acquired fund fees and expenses, brokerage commissions and any other portfolio transaction-related
expenses and fees arising out of transactions effected on behalf of the Fund, credit facility fees and expenses, including interest expenses,
and litigation and indemnification expenses and other extraordinary expenses not incurred in the ordinary course of the Fund’s
business.

 (2) Other Expenses are based on estimated amounts for the current
fiscal year.

   2

    Jaea Hahn and Kalkidan Ezra
 U.S. Securities and Exchange Commission
 March 25, 2025

Example

This example is intended to help you compare the
cost of investing in the Fund with the cost of investing in other funds. The example assumes that you invest $10,000 in the Fund for the
time periods indicated and then redeem all of your shares at the end of those periods. The example also assumes that your investment has
a 5% return each year and that the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower,
based on these assumptions your costs would be:

    Name of Fund
    1 Year
    3 Years

    Tuttle Capital AAPL 0DTE Covered Call ETF
    $97
    $303

Principal
Investment Strategies

 4. Comment: The Staff notes that these are all single
stock strategies or single asset strategies, please clarify if true:

 ● Investment
in the fund, is not an investment in the underlying security, if true;

 ● The
Fund’s strategy will cap its potential gain if the underlying security share and increase in value;

 ● The
Fund’s strategy is subject to potential losses in the underlying security decreases in value, which may not be offset by any income
received by the Fund; and

 ● The
Fund’s shareholders are not entitled to the underlying security’s dividends.

Response:
The Trust has revised the disclosure to address the Staff’s comment.

 5. Comment:  Please clarify that the exposure
to the price return of Apple is capped. Additionally, and in the appropriate section of the filing, please explain how price return differs
from total return.

Response:
The Trust has revised the disclosure to address the Staff's comment. The Trust notes that the capital appreciation is not “capped,”
but is rather partially offset depending on the specific options used and current market conditions. The Trust has added the following
disclosure in this regard:

Although
the Fund will seek capital appreciation through the purchase of in-the-money call options on the Underlying Security or through investing
directly in the Underlying Security, any participation in gains achieved through the increase in value of the Underlying Security will
be offset to a degree by the Fund’s net short exposure to the Underlying Security through its sale of call options on the Underlying
Security.

   3

    Jaea Hahn and Kalkidan Ezra
 U.S. Securities and Exchange Commission
 March 25, 2025

 6. Comment: Please clarify what percentage of its assets
the Fund intends to invest directly in each Underlying Security. In your response, please explain how the Funds’ intended strategies
are and will be consistent with 140 under the 1933 Act. Alternatively, please delete references to the Fund directly purchasing the underlying
security.

Response:
The Trust declines to include a percentage limitation or description regarding the Fund’s direct investment in the Underlying Security
as that can change based on market conditions.

Regarding Rule 140, the Trust does not
believe Rule 140 is applicable to the Funds. Rule 140 is not applicable in circumstances where the primary issuer (here, the Funds) is
not an “underwriter” of the underlying securities. The primary issuer cannot be an underwriter of the underlying securities
where the underlying securities are not purchased from the issuer (or an affiliate of the issuer) of the underlying securities. Rule 140
is a definitional rule that further defines when a person is engaged in a “distribution” as the term is used in Section 2(a)(11)
of the Securities Act, which defines the term “underwriter.” In other words, a person cannot be “engaged in a distribution”
under Rule 140 unless such person first fits within the definition of underwriter.

Rule 140 provides that—the

[a] person, the chief part of
whose business consists of the purchase of the securities of one issuer, or of two or more affiliated issuers, and the sale of its own
securities, . . . is to be regarded as engaged in the distribution of the securities of such issuer or affiliated issuers within the meaning
of Section 2(11) of the [Securities] Act.

Section
2(a)(11) under the Securities Act defines an “underwriter” as “any person who has purchased from an
issuer with a view to, or offers or sells for an issuer in connection with, the distribution of
any security, or participates or has a direct or indirect participation in any such undertaking, or participates or has a participation
in the direct or indirect underwriting of any such undertaking . . . .”

As a definitional rule, Rule 140 itself
does not impose any requirements. However, the Staff has interpreted the rule to mean that when a person is deemed to be “engaged
in a distribution” for purposes of Rule 140, the issuer of the underlying securities purchased by such person implicating Rule 140
is deemed a “co-issuer” and must sign the registration statement of such other person.

The
purpose of Rule 140 is to curb the abuses by persons who may underwrite securities through the issuance of their own securities, “and
using the proceeds of the sale of those securities to purchase the securities of another issuer, without disclosing to the purchasers
of their securities information with respect to the issuer of such securities.”1 The
rule thus serves to prevent issuers from benefitting indirectly through the sale of securities that may otherwise not comply with the
Securities Act of 1933.

 1 See Merrill Lynch Mortgage Investors,
Inc., SEC No-Action Letter (April 18, 1988).

   4

    Jaea Hahn and Kalkidan Ezra
 U.S. Securities and Exchange Commission
 March 25, 2025

There is no basis under the Securities
Act or Rule 140 to subject the issuer of the underlying securities to Securities Act liability for an offering that does not benefit such
issuer, as is the case with the Fund’s offering. Section 2(a)(11) requires that in order to meet the definition of an underwriter,
the securities must be purchased directly from an issuer or such sale must be for an issuer. Here, each Fund will only hold the Underlying
Security either generally contributed to it in-kind from Authorized Participants or pursuant to a Fund exercising its call options, and
where such Underlying Security were acquired by the Authorized Participants or other investors in the secondary market, meaning that the
issuer of the Underlying Security does not benefit from the Fund’s offering whatsoever. Therefore, the Fund cannot be engaged in
the distribution of the convertible bonds under section 2(a)(11) of the Securities Act or Rule 140 and it would serve no purpose to require
the issuer of the underlying securities to sign the Fund’s registration statement.

 7. Comment: Please clarify whether daily 0DTE options
are currently available for the Underlying Security, and if not revise the discussion to clarify how the Funds’ Principal Investment
Strategies will be implemented at launch.

Response:
The Trust has revised the disclosure to address the Staff’s comment.

 8. Comment: If accurate, please disclose that there can
be no guarantee that daily 0DTE options will be available for each underlying security on Cboe or another exchange.

Response:
The Trust has revised the disclosure to address the Staff’s comment.

 9. Comment: To the extent that the Funds intend to use
FLEX options to mimic 0DTE options, please so state.

Response:
The Trust has revised the disclosure to address the Staff’s comment.

 10. Comment: What are the expected target maturities for
the different option contracts that the Fund invests in other than 0DTE sold call options.

Response:
The Trust has revised the disclosure to address the Staff’s comment.

 11. Comment: As the option contracts the Fund holds are
exercised or expired will it enter into new option contracts, for example, engage in “rolling” if so, please disclose that
the rolling of options may result in high portfolio turnover.

Response:
The Trust has revised the disclosure to address the Staff’s comment.

 12. Comment: Please confirm supplementally if synthetic
covered call strategy will be fully covered. If not, please explain why calling the strategy covered is appropriate. If you are going
to invest in underlying securities, how will holding the underlying securities and synthetic puts work?

Response:
The Trust confirms that the covered call strategy will be fully covered. The Funds will use a combination of the Underlying Security and
synthetic long position, which can be FLEX Options or standardized listed options and will be writing calls using both FLEX Options and
standardized listed options.

   5

    Jaea Hahn and Kalkidan Ezra
 U.S. Securities and Exchange Commission
 March 25, 2025

 13. Comment: Please clarify whether the Funds will use
leverage.

Response:
The Funds do not intend to use leverage.

 14. Comment: Disclose whether losses may be offset by
premiums and if not, please clarify that premiums might not offset all losses.

Response:
The Trust has revised the disclosure to address the Staff’s comment.

 15. Comment: Please explain notional value and strike
price in plain English as these option terms are not described in the filing.

Response:
The Trust has revised the disclosure to address the Staff’s comment.

 16. Comment: The Fund suggests it’s going to make
monthly distribution payments. Disclose whether any portion of the monthly distribution payment will be return of capital and, if so,
please add corresponding disclosure.

Response:
The Trust has revised the disclosure to address the Staff’s comment.

Principal
Risks of Investing in the Fund

 17. Comment: The Staff notes in that the last sentence
of the 0DTE Options Risk states, “To the extent that the OCC enacts new rules relating to 0DTE options that make it impracticable
or impossible for the Fund to utilize 0DTE options to effectuate its investment strategy, it may instead utilize options with the shortest
remaining maturity available or it may utilize swap agreements to provide the desired exposure.” Please add this sentence to the
Principal Investment Strategies above. The Staff notes, the disclosure currently suggests that FLEX options can be used to effect the
0DTE strategies with no discussion of the use of swaps.

Response:
The Trust has revised the disclosure to address the Staff’s comment.

 18. Comment: The Staff notes in the Liquidity Risk, that
the size of positions increase the risk of liquidity. Please clarify that the large size of positions as well as the focus on a single
underlying security, may increase liquidity risk.

Response:
The Trust has revised the disclosure to address the Staff’s comment.

   6

    Jaea Hahn and Kalkidan Ezra
 U.S. Securities and Exchange Commission
 March 25, 2025

Investment
Risks of the Underlying Security

 19. Comment: Please consider identifying other risks that
may apply to the underlying security, such as large cap company risk.

Response:
The Trust has revised the disclosure to address the Staff’s comment.

 20. Comment: Generally, please consider the following:

 1. Adding a risk relating to price participati