SecProbe.io

CORRESP
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    March 18, 2020

    Lisa N. Larkin

    Senior Counsel

    Division of Investment Management

    U.S. Securities and Exchange Commission

    100 F Street, N.E.

    Washington, D.C. 20549

Re:
Esoterica Thematic Trust; File Nos. 333-233633 and 811-23473

Dear Ms. Larkin:

On
March 13, 2020, Esoterica Thematic Trust (the “Fund”) filed Pre-Effective Amendment No. 2 to its registration statement
on Form N-1A (the “Registration Statement”). The Fund proposes to revise the disclosure in its Registration Statement
in response to the telephonic comments that we received from you on March 16, 2020, as indicated below. The Fund proposes to make
the revisions noted below in the final Prospectus and SAI filed pursuant to Rule 497 of the Securities Act of 1933, as amended.
Please find also below a reiteration of your comments and the Fund’s responses, which the Fund has authorized Thompson Hine
LLP to make on behalf of the Fund.

Capitalized
terms not defined herein have the meaning ascribed to them in the Prospectus and SAI.

Principal
Investment Strategies

 Comment 1. Please
                                         provide additional disclosures to the Fund’s Principal Investment Strategy and
                                         Risk Disclosures, as applicable, about the types of companies that the Fund may invest.
                                         Specifically, does the Fund intend to invest in 5G technology production companies, companies
                                         that will utilize and benefit from the use of 5G technology, or a combination of both
                                         types of companies?

 Response: The
                                         Fund will invest in both companies that are involved in the production of 5G technologies
                                         and companies that will utilize and may benefit from 5G technology. Companies that produce
                                         5G technology include semiconductor and software companies. Companies that utilize and
                                         benefit from 5G technology include, among other things, web vendor and e-commerce companies.
                                         The Fund has reviewed its existing risk disclosures and believes that the risks related
                                         to investments in companies that produce and utilize or benefit from 5G technology are
                                         adequately set forth therein. For example, the Fund refers to the following risk factors
                                         that captures these industries and industry sectors: (i) 5G Companies and Emerging Technologies
                                         Investment Risk, (ii) Computer Software/Services Companies Risk, (iii) Internet Companies
                                         Risk, (iv) Semiconductor Companies Risk, (v) Technology Sector Risk, (vi) Communications
                                         Services Sector Risk, (vii) Basic Materials Sector Risk, Consumer Discretionary Sector
                                         Risk and (viii) Communication Services Companies Risk.

    Owen.Pinkerton@thompsonhine.com   Phone: 202.263.4144

Ms. Lisa N. Larkin

March 18, 2020

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2

The Fund
will revise its Principal Investment Strategy as noted below in response to the Staff’s comment:

“Under
normal circumstances, at least 80% of the Fund’s assets will be invested in equity securities, including common stocks,
partnership interests, business trust shares and other equity investments or ownership interests in business enterprises, including
companies involved in the production of 5G technology and companies that may benefit from the use of 5G, such as companies engaged
in e-commerce or internet sales. The Fund’s investments will include micro-, small-, medium- and large-capitalization companies.
The Fund will invest at least 25% of its net assets in companies in the internet, computer, semiconductor and software group of
industries. The Fund’s investments in foreign equity securities will be in both developed and emerging markets. The Fund
may invest in foreign securities (including investments in American Depositary Receipts (‘‘ADRs’’) and
Global Depositary Receipts (‘‘GDRs’’)) and securities listed on local foreign exchanges. Outside of the
Fund’s 80% policy, the Fund may invest up to 20% of its net assets in cash and cash equivalents.”

Enclosed
please find all proposed marked edits to the Fund’s prospectus and SAI.

*	*	*

If you have any
questions, please call Ryan Wheeler at (513) 352-6693 or me at (202) 263-4144.

    Very truly yours,

    /s/ Owen J. Pinkerton

    Owen J. Pinkerton

 cc: JoAnn
                                         M. Strasser

Ryan S. Wheeler

Karan Trehan