SecProbe.io

CORRESP
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December
29, 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, on a call on December 18, 2026. The comments relate to Post-Effective Amendment (“PEA”) No. 425 to the registration
statement of the Trust, which was filed on October 17, 2025, under Rule 485(b) of the Securities Act of 1933, as amended (the “1933
Act”). PEA 425 was filed to register shares of two new series of the Trust, the TSPY Lift ETF and TDAQ Lift 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.

 • Please
                                            complete any missing or bracketed information in the Prospectus and SAI.

 • 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.

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

 1. Comment:
                                            Please provide the ticker symbols for both series.

Response:
The ticker symbols for TSPY Lift ETF and TDAQ Lift ETF are TSYX and TDAX, respectively.

 2. Comment:
                                            Please provide a completed fee and expenses table and example numbers for the funds for the
                                            Staff’s review.

    Ms. Kalkidan Ezra

U.S. Securities and Exchange Commission

December 29, 2025

Response:
The fee and expenses table is set forth below:

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

    Management
    Fee(1)
    0.98%

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

    Other
    Expenses(2)
    0.00%

    Total
    Annual Fund Operating Expenses(3)
    0.98%

 (1) Under
                                            the Investment Advisory Agreement, Tapp Finance, Inc., d/b/a TappAlpha (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 estimated for the Fund’s initial fiscal year.

 (3) The
                                            cost of investing in swaps, including the embedded cost of the swap and the operating expenses
                                            of the referenced assets, is an indirect expense that is not included in the above fee table
                                            and is not reflected in the expense example. The total indirect cost of investing in swaps,
                                            including the embedded cost of the swap and the operating expenses of the referenced assets,
                                            is estimated to be 0.190% for the fiscal period ending December 31, 2026.

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 hold or redeem all of your shares at the end of those periods.
The example also assumes that your investment has a five percent (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

    TDAQ
    Lift ETF
    $100
    $312

Principal
Investments Strategies

 3. Comment:
                                            Please clarify that each Fund and TSPY and TDAQ are affiliates and consider including an
                                            appropriately tailored conflicts of interest disclosure referencing investments in affiliated
                                            funds.

Response:
The Trust has updated the disclosure in response to the Staff’s comment.

 4. Comment:
                                            The Staff references the second sentence of the first paragraph and requests that for both
                                            series, please supplementally explain what percentage of the Fund’s assets will be
                                            invested directly in TSPY or TDAQ shares and how the Fund’s intended strategy and disclosures
                                            are and will be consistent with Section 12(d)(1) under the 1940 Act.

Response:
The Funds will gain exposure to their respective reference assets through swaps and options. Neither Fund intends to invest directly
in the underlying investment company and the Trust has updated the disclosure accordingly. The Trust notes that Section 12(d)(1) is a
securities-ownership based restriction and is not implicated by indirect exposure to an underlying investment company through derivatives.

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    Ms. Kalkidan Ezra

U.S. Securities and Exchange Commission

December 29, 2025

 5. Comment:
                                             For both
                                            Series, the Staff notes the third sentence of the first paragraph states that the “Adviser
                                            will determine the allocation of the Fund’s investments in swap agreements, call options
                                            and direct investments in SPY shares based upon various factors.” However, the Staff
                                            notes the prior sentence only mentions options, while this sentence mentions swaps. If the
                                            fund does not expect to invest in swaps please reconcile to streamline the disclosure.

Response:
The Trust has updated the disclosure in response to the Staff’s comment. The relevant portion of the principal investment strategies
disclosure now reads as follows (including removing references to investing directly in underlying funds):

The Fund, under normal circumstances, invests at least 80% of its net assets (plus any borrowings
for investment purposes) in financial instruments that are designed to provide, in the aggregate, 120%
- 140% 130%
exposure to the price performance
of TSPY on a daily basis (with the Fund rebalancing to 130% exposure if the
exposure goes above or below 120% or 140%, respectively). The Fund
will primarily use swaps to obtain its desired exposure to TSPY but may also seek to achieve its investment objective by purchasing
call options on TSPY or by investing directly in the shares of SPDR S&P 500 ETF Trust (“SPY”).
The Adviser will determine the allocation of the Fund’s investments in swap agreements and,
call options and
direct investments in SPY shares based upon various factors including, but not limited to, counterparty capacity, financing
charges, liquidity, collateral availability, and overall market conditions for a particular instrument. Direct
investments in shares of SPY are typically less efficient than the use of swap agreements because direct investments in ETF shares do
not provide leveraged returns. This may result in the Fund not achieving its 130% daily investment objective.

 6. Comment:
                                            The Staff notes the reference in the sixth paragraph regarding the TappAlpha SPY Growth &
                                            Daily Income ETF and asks that the Trust please clarify the type of strategy that is being
                                            implemented and revise the disclosure accordingly, for example 0DTE covered call strategy.

Response:
The Trust has added the sub-header “Information about TSPY” to clarify that the referenced disclosure describes information
about the reference asset as the Fund’s exposure will be 130% to TSPY.

 7. Comment:
                                            The Staff notes the Funds intend to have 130% exposure to the price performance of TSPY and
                                            TDAQ, respectively. Please explain how the Adviser expects to implement the strategy and
                                            revise the disclosure accordingly. Additionally, please supplementally explain what happens
                                            if the underlying security declines in value and how it will affect investors.

        3

    Ms. Kalkidan Ezra

U.S. Securities and Exchange Commission

December 29, 2025

Response:
The Trust has updated the disclosure to clarify that each Fund will seek to achieve its investment objective primarily through the use
of swaps on TSPY and TDAQ, respectively, as noted above in response to comment 5. If the price of TSPY or TDAQ declines in value on a
given day, then the respective Fund will decline in value by 1.2x to 1.4x (depending on the exposure) the performance of the respective
underlying reference asset.

 8. Comment:
                                            Please review comments 6 and 7 issued above and revise the first sentence of the sixth paragraph
                                            accordingly.

Response:
The Trust declines to revise the first sentence of the 6th paragraph under each Fund’s principal investment strategies
because the referenced disclosure appropriately describes the investment objective and principal investment strategies of each respective
reference asset. As noted above in response to comment 6, the Trust has added a clarifying sub-header.

 9. Comment:
                                             The Staff
                                            notes the date referenced in the description of Si Katara as Portfolio Manager, please revise.

Response:
The Trust has updated the disclosure in response to the Staff’s comment.

Principal
Risk.

 10. Comment:
                                            The Staff notes that TDAQ has not yet commenced its IPO and has recently launched in September
                                            of 2025, please add appropriately tailored disclosure and any relevant risks.

Response:
The Trust has updated the disclosure in response to the Staff’s comment.

Additional
Information About Risks

 11. Comment:
                                            The Staff notes that both Funds have Large Cap Company Risk listed in each series’
                                            fund summaries, but it was not listed under combined risks. If this is a principal risk,
                                            please revise the disclosure accordingly.

Response:
The Trust has updated the disclosure in response to the Staff’s comment.

*    *    *

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    Ms. Kalkidan Ezra

U.S. Securities and Exchange Commission

December 29, 2025

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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