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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

June 10, 2025

Mr. Brent J. Fields

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 Mr. Fields:

As requested by the Staff,
this letter is being resubmitted on June 18, 2025, to make certain modifications to the Trust’s responses. This letter provides
the response of ETF Opportunities Trust (the “Trust” or the “Registrant”) to the additional comments of the staff
(the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) that you provided to Practus,
LLP, via EDGAR on May 30, 2025, and on a conference call on June 6, 2025. The comments relate to Post-Effective Amendment (“PEA”)
No. 285 to the registration statement of the Trust, which was filed on May 30, 2025, under Rule 485(b) of the Securities Act of 1933,
as amended (the “1933 Act”). PEA 285 was filed to register shares of two new series of the Trust, the REX-OspreyTM
ETH + Staking ETF and REX-OspreyTM SOL + Staking ETF (each a “Fund” and collectively, the “Funds”).1
We have summarized your correspondence below and supplemented it with certain additional points pertaining to our discussions. Capitalized
terms not defined in this letter shall have the same meaning ascribed to such term in the PEA.

Comment: On April 30, 2025, the Staff
filed a letter via EDGAR that conveyed the Staff’s concerns with the PEA (the “Staff Letter”) – a copy of the
Staff Letter is attached hereto as Exhibit A. Among other things, the Staff Letter indicated that the Staff had unresolved questions
whether the Funds, if structured and operated as proposed, would be able to meet the definition of “investment company” under
the Investment Company Act of 1940, as amended (the “1940 Act”). The Staff Letter requested a response and inclusion of an
email that was sent to the Staff on May 29, 2025 – a copy of the May 29, 2025 email is attached hereto as Exhibit B.

1. PEA No. 213 was initially filed to register shares
of seven new series of the Trust, the Rex-Osprey TRUMP ETF, Rex-Osprey ETH ETF, Rex-Osprey BTC ETF, Rex-Osprey SOL ETF, Rex-Osprey XRP
ETF, Rex-Osprey BONK ETF, and Rex-Osprey DOGE ETF. As we previously advised you in the Prior Response, the naming convention for the new
series with ETH and SOL as the Reference Asset will be the REX-OspreyTM ETH + Staking ETF and REX-OspreyTM SOL + Staking ETF. As we have
advised you in e-mail communications, the Rex-Osprey series that are the subject of PEA No. 213, other than the Funds, are being delayed,
as requested by the Staff.

On June 6, 2025, we had a call with the Staff
(the “June 6 Call”) seeking clarification of the Staff’s comments in the Staff Letter and to what specifically the Staff
wished for us to address in a response letter. On the June 6 Call, the Staff clarified its views that were conveyed in a call occurring
on May 29, 2025 (the “May 29 Call”) by confirming that the Funds must invest at least 40% of their assets in “investment
securities” (as defined in Section 3(a)(2) of the 1940 Act) to qualify as “investment companies” as defined in Section
3(a)(1)(C) of the 1940 Act.

Response: The Trust acknowledges the
Staff’s concerns set forth in the Staff Letter and clarified on the June 6 Call. Although the Trust still believes the Funds are
appropriately registered as investment companies, the Trust and the investment adviser to the Funds (the “Adviser”) are willing
to adjust the investment strategies of each Fund to address the Staff’s concerns. In doing so, the Trust and the Adviser will follow
the Staff’s guidance that the Funds would clearly qualify as investment companies under Section 3(a)(1)(C) if each Fund had 40%
of its assets in investment securities. Accordingly, each Fund’s principal investment strategy will be revised to disclose that
the Fund will invest at least 40% of its total assets in investment securities, which will include the securities issued by exchange-traded
funds (“ETFs”) and exchange-traded products (“ETPs”) that invest in or obtain exposure to ETH or SOL, as applicable.
Sample portfolios for each Fund are as follows:

  ETH + Staking ETF

 1. Non-US ETH + Staking ETPs: 80-89%

 2. ETH: 10-15%

 3. Liquid Staking Tokens): 1-5%

  SOL + Staking ETF Non-US SOL + Staking ETPs2: 40-45%

 1. SOL: 50-54%

 2. Liquid Staking Tokens (e.g., JitoSOL): 1-5%

For purposes of the definition of investment
company set forth in Section 3(a)(1)(C), the mix of investment securities to total assets will be calculated as follows:

 Ø The
                                            numerator will consist of securities of ETPs and ETFs3 that invest in the applicable
                                            Reference Asset (or have exposure to the applicable Reference Asset), and other securities
                                            as may be set forth in each Fund’s registration statement, as amended from time to
                                            time. Each Fund’s interest in its Cayman Sub, direct holdings in its Reference Asset,
                                            staking arrangements that are not securities, cash, and government securities will not be
                                            included in the numerator.

 Ø The denominator will include
all assets held by each Fund, excluding Government securities and cash items.

2. If the Adviser encounters capacity issues with respect to any non-US
ETPs, the Adviser intends to add US-listed investment companies to the portfolio.

3. The ETFs may include registered investment companies or foreign investment
companies. The ETPs will include exchange-traded products that are not registered under the Investment Company Act but whose shares are
registered under the Securities Act, or are exempt from registration under the Securities Act, including Regulation S. The ETPs will include
non-U.S. issuers and ETPs that trade on non-U.S. exchanges.

        2

    Mr. Brent J. Fields

Division of Investment Management

U.S. Securities and Exchange Commission

June 10, 2025

The mix of assets set forth above will make
the Funds investment companies under Section 3(a)(1)(C). We note that Section 3(b)(1) exempts issuers that inadvertently fall within the
definition of investment company under Section 3(a)(1)(C) that are engaged primarily in a business other than that of investing, reinvesting,
owning, holding or trading in securities. The Funds obviously do not wish to avail themselves of Section 3(b)(1) and do not believe Section
3(b)(1) is available in any event.

With respect to which assets will be held in
each Fund’s Cayman Subsidiary, each Cayman Subsidiary will hold the Reference Asset directly and LSTs, and any other asset that
must be held in the Cayman Subsidiary to satisfy the RIC requirements. However, as discussed in our prior response letters, the Cayman
Subsidiaries will not be utilized until the Funds convert to RICs. We also note that the Funds will hold investment securities directly
(and not through the Cayman Subsidiaries) in amounts sufficient to satisfy the 40% test under Section 3(a)(1)(C) of the 1940 Act.

With regard to the Staff’s comment regarding
Rule 6c-11, we note that in order for the Funds to be able to rely on Rule 6c-11 they must meet the definition of “exchange-traded
funds.” We assume the Staff is referring in the Staff Letter to the relevant portion of the definition which provides that an exchange-traded
fund is a “registered open-end management company.” As of May 30, 2025, when the Funds’ registration statement went
effective, the Funds are “registered” as “open-end management companies.” We also believe that any doubt with
respect to whether the Funds can rely upon Rule 6c-11 should be resolved by the Funds conclusively being investment companies under Section
3(a)(1)(C).

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

  Sincerely,

  /s/ John H. Lively

  John H. Lively

        3

    Mr. Brent J. Fields

Division of Investment Management

U.S. Securities and Exchange Commission

June 10, 2025

EXHIBIT A

Staff Letter

May 30, 2025

VIA E-mail

John H. Lively Practus, LLP

11300 Tomahawk Creek Parkway, Suite 310

Leawood, KS 66211

  Re:
  ETF Opportunities Trust

  Post-Effective Amendment on Form N-1A File Nos.

  333-234544, 811-23439

Dear Mr. Lively:

On January 21, 2025, ETF Opportunities Trust (the “Trust”)
filed a post-effective amendment pursuant to rule 485(a) under the Securities Act (the “PEA”) to register seven new ETF series,
including REX-Osprey ETH ETF and REX-Osprey SOL ETF (the “Funds”). Based upon our review of the PEA, the staff sent you a
comment letter dated March 7, 2025. On April 15, 2025, you filed on EDGAR a letter to respond to certain staff comments, as well as to
propose substantial changes to the Funds’ principal investment strategies, the Funds’ names, and to make corresponding revisions
to and add relevant disclosures in the Funds’ registration statement. On May 2, 2025, the staff provided you with additional comments
based on those responses. You filed a subsequent response letter on EDGAR on May 14, 2025, again proposing to make substantive changes
to the Funds’ principal investment strategies and prospectus disclosures. The staff issued another round of comments to you on
May 23, 2025, and you filed a response on May 27, 2025, responding to those comments. On May 28, 2025, the staff discussed with you our
outstanding concerns, to which you responded via email on May 29. The staff informed you later that day that we continue to have questions
and concerns about the Funds’ proposed structure and operations and requested that the Funds continue to delay effectiveness of
the registration statement. The Funds’ registration statement went effective May 30, 2025, without resolution of staff comments.

        4

    Mr. Brent J. Fields

Division of Investment Management

U.S. Securities and Exchange Commission

June 10, 2025

As we have
communicated to you on several occasions, Commission staff continues to have unresolved questions whether the Funds, if structured
and operated as proposed, would be able to meet the definition of “investment company” under the Investment Company
Act.1 We are, therefore, also concerned
that the Funds may have improperly filed their registration statement on Form N-1A and that disclosures in the registration statement
regarding the Funds’ status as investment companies may be potentially misleading. Furthermore, to the extent that the Funds are
not able to meet the definition of “investment company” under the Investment Company Act, the staff is concerned that the
Funds would not satisfy the applicable exchange’s generic listing standards for ETFs relying on rule 6c-11 under the Investment
Company Act. To the extent that these concerns remain unresolved, the Commission staff will consider the appropriate next steps to ensure
compliance with the federal securities laws.

*	*	*

A response to this
letter should be in the form of a supplemental correspondence filed on EDGAR. Please file your May 29th email submission as
correspondence on EDGAR, which will be made public consistent with the staff’s filing review process. We remind you that the Funds
and their management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action,
or absence of action by the staff.

Should you have any questions regarding this
letter, please contact me at (202) 551-6844.

  Sincerely,

  /s/ Brent J. Fields

  Brent J. Fields

   Associate

  Director

 cc: Stephen G. Topetzes, K&L Gates, Counsel to the Independent Trustees Natasha Vij Greiner, Director

    Kaitlin Bottock, Assistant Director

    Andrea Ottomanelli Magovern, Assistant
Director Kyle

    AhlgreAhlgren, Branch Chiefn, Branch Chief

    Asen Parachkevov, Branch Chief Jaea

    Hahn,
Senior Counsel

1
See Section 3(a)(1)(A) of the Investment Company Act, which defines “investment company” to include any issuer which
“is or holds itself out as being primarily engaged, or proposes to engage primarily, in the business of investing, reinvesting,
or trading in securities.” See also Section 3(a)(1)(C), which defines “investment company” to include any issuer
which “is engaged or propose to engage in the business of investing, reinvesting, owning, holding, or trading in securities, and
owns or proposes to acquire investment securities having a value exceeding 40 per centum of the value of such issuer’s total assets
(exclusive of Government securities and cash items) on an unconsolidated basis.”

        5

    Mr. Brent J. Fields

Division of Investment Management

U.S. Securities and Exchange Commission

June 10, 2025

EXHIBIT B

May 29 Email

As requested yesterday, set forth below are potential portfolios
for the ETFs.  Please note these are range-based estimated portfolios for the ETFs.  The Adviser reserves the right and has
absolute discretion to change the portfolio based on its view of the markets upon launch and during active management of the ETFs in consideration
of the Adviser’s fiduciary obligations and its desire to create the best product for fund shareholders.

  ETH + Staking ETF

 4. Non-US ETH + Staking ETPs (e.g., 3iQ’s ETHQ): 35-55%

 5. ETH: 40-60%

 6. Staked ETH: 15% (i.e.,15% of the whole ETF)

 7. Liquid Staking Tokens (e.g., LsETH): 1-5%

  SOL + Staking ETF

 3. Non-US SOL + Staking ETPs (e.g., 3iQ’s SOLQ): 5-15%

 4. SOL: 80-90%

 5. Staked SOL: 40-60% (i.e., 40-60% of the whole ETF)

 6. Liquid Staking Tokens (e.g., JitoSOL): 1-5%

We believe that the Funds meet the definition of investment
company under both of Section 3(a)(1)(A) and Section 3(a)(1)(C) (recognizing that either one or the other is sufficient but
are distinctly different). In addition, the Fund notes that Congress adopted the 1940 Act to protect investors and, for that reason, virtually
all guidance from the Commission that the Fund is aware of has been aimed at preventing companies from avoiding regulation by the 1940
Act. The Funds, by contrast, are not seeking to avoid regulation by the 1940 Act, but rather they are agreeing to comply with the
1940 Act and offer its investors the protections afforded thereby by affirmatively registering as an investment company thereunder.

These ranges noted above satisfy the quantitative
40% test set forth in Section 3(a)(1)(C).  This is so because it means the Funds will be proposing to engage in the
business of investing, reinvesting, owning, holding, or trading in securities, AND owns or proposes to acquire investment
securities having a value exceeding 40 percent of their total assets.  This takes into account that the interests in ETPs are securities,
that the staking arrangements may be investment contracts, the LSTs may be securities, and SOL may be a security under the 1940 Act.

        6

    Mr. Brent J. Fields

    Division of Investment Management

U.S. Securities and Exchange Commission

June 10, 2025

We also wish to reiterate that the quantitative test
under 3(a)(1)(C) should not be conflated with the “primarily engaged test” under 3(a)(1)(A).  In this regard, we note
that the Tonopah factors used to determine whether an issuer is “primarily engaged” in investing in securities is a facts
and circumstances test with no one factor being dispositive and that in considering these factors the Commission and courts look to see
how each factor impacts an investor’s view of the company’s purpose.

As mentioned in our second response, the first three
factors all support the Funds being primarily engaged in the business of investing in securities (even without assuming ETH and SOL are
securities) because: (i) the company’s historical development;