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

October 16, 2025

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. Kalkidan:

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. The comments relate to
Post-Effective Amendment (“PEA”) No. 339 to the registration statement of the Trust, which was filed on August 6, 2025, under
Rule 485(a) of the Securities Act of 1933, as amended (the “1933 Act”). PEA 339 was filed to register shares of three new
series of the Trust, the T-REX 2X Long FLY Daily Target ETF, T-REX 2X Inverse FIG Daily Target ETF, and T-REX 2X Inverse FIG Daily Target
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.

 · 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.

 · The Registrant is responsible for the adequacy and accuracy
of the disclosures in the filing and Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission
from taking any action with respect to the filing.

 · Prior to the effectiveness of the subsequent amendment,
please complete any missing or bracketed information contained in PEA 339.

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

 1. Comment:         Provide a ticker symbol for each of the Funds.

Response:        The ticker symbol for each Fund has been added.

Ms. Kalkidan Ezra

U.S. Securities and Exchange Commission

October 16, 2025

 2. Comment:        Supplementary explain what percentage of the T-REX 2X
Long FLY Daily Target ETF’s assets will be used to purchase call options on FLY and invest directly in the common stock of FLY and
the Fund’s intended strategy and disclosures are and will be consistent with Rule 140 under the
Securities Act of 1933 (“Securities Act”).

	Response:        The Fund intends to primarily gain exposure to FLY by entering into total return swaps, however, depending upon market conditions,
the Fund’s investment adviser, Tuttle Capital Management LLC (the “Adviser”), may seek exposure to FLY by, among other
things, investing in call options on FLY common stock or in FLY common stock directly. The extent to which the Fund may invest directly
in FLY is not expected to exceed 45% of the Fund’s assets, and it is not intended or expected that a direct investment in FLY will
be maintained for extensive periods of time. The Trust believes that the current disclosure is adequate to address these practices and
the associated risks and is consistent with Rule 140 under the Securities Act.

 3. Comment:        Supplementary explain what percentage
of a Fund’s assets will be used to purchase put options on FLY or FIG or by engaging in short sales on the common stock of FLY or
FIG and each Fund’s intended strategy and disclosures are and will be consistent with Rule 140 under the
Securities Act of 1933 (“Securities Act”).

Response:        Each
of these Funds intends to primarily gain inverse exposure to its underlying security by entering into total return swaps, however,
depending upon market conditions, the Adviser may seek inverse exposure to the underlying security by, among other things, investing in
put options on the underlying security or by entering into a short sale on the underlying security. The extent to which a Fund may invest
in put options on the underlying security or sell short the underlying security is not expected to exceed 45% of the Fund’s assets,
and it is not intended or expected that such investments will be maintained for extensive periods of time. The Trust believes that the
current disclosure is adequate to address these practices and the associated risks and is consistent with Rule 140 under the Securities
Act.

 4. Comment:        Please
clarify that the increased volatility in the underlying reference asset may lead counterparties to tighten up position limits or put in
place other restrictions that could prevent these Funds from achieving their investment strategy going forward.

Response:        The Adviser has advised the Trust that volatility in the reference security does not generally lead to reduced counterparty capacity
as the Staff has suggested in this comment. The Registrant declines to make revisions based upon the Staff’s comment.

 5. Comment:        In the Indirect Investment Risk, please supplementally confirm that
the fund shareholders will not have the right to receive dividends if the fund directly holds shares of an underlying security.

Response:        The Trust confirms that if a Fund directly holds shares of an underlying security, Fund shareholders will not have the right
to receive dividends (if any) paid by the company with respect to the underlying security, although Fund shareholders may receive dividends
or distributions from the Fund that are derived from dividends received by the Fund.

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

    Sincerely,

    /s/ John H. Lively

    John H. Lively

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