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    David
    J. Baum
    Direct
    Dial:  202-239-3346
    Email:  David.Baum@alston.com

June
14, 2024

VIA
E-mail and EDGAR

United
States Securities and Exchange Commission

100
F Street, N.E.

Washington,
DC 20549

Attn:
Valerie J. Lithotomos

    Re:
    Kurv
                           ETF Trust (the “Trust” or “Registrant”)

    Post-Effective
    Amendment No. 11 to the Trust’s Registration Statement on Form N-1A, filed on March 22, 2024

    File
    Numbers 333-233633, 811-23473

Ladies
and Gentlemen:

This
letter is in response to the comments provided by the staff of the U.S. Securities and Exchange Commission (the “Staff”)
via video-call (the “Comments”) on May 8, 2024, relating to Post-Effective Amendment No. 11 (“PEA No. 10”) to
the Trust’s Registration Statement on Form N-1A filed on March 22, 2024, regarding the Kurv Enhanced Short Maturity ETF (the “Fund”),
a series of the Trust. The prospectus (the “Prospectus”) and statement of additional information (“SAI,” and
together with the Prospectus, the “Documents”) contained in the Registration Statement will be updated in response to the
Staff’s Comments and a revised post-effective amendment to the Registration Statement reflecting these changes will be filed subsequent
to this correspondence.

General
Comments

Comment
#1

The
Staff provides the following standard comments:

 a. Where
                                            a comment is made in one location it is applicable to all similar disclosures appearing elsewhere
                                            in the same registration statement.

 b. The
                                            Staff reminds the Registrant that the company and its management are responsible for the
                                            accuracy and adequacy of its disclosures not withstanding any review, comments, action or
                                            absence of action by the Staff.

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June
14, 2024

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2

 c. The
                                            Staff asks the Registrant to please file the responses to comments on Edgar at least 5 days
                                            in advance of the effectiveness.

Response
#1

The
Registrant acknowledges the Staff’s comments above and will respond as requested.

Prospectus

Cover

Comment
#2

Supplementally,
please explain what “Enhanced” is referring to in the name of the fund.

Response
#2

The
Registrant notes that the Fund is considered “enhanced” compared to traditional cash management funds because it has slightly
higher maturity/duration and credit risk to generate higher yield.

Summary
Section – Fund Fees and Expenses

Comment
#3

In
the “Fund Fees and Expenses” section, please remove the second sentence of the first paragraph, as this language is not a
part of Item 3.

Response
#3

The
Registrant has deleted the sentence as requested.

Comment
#4

Please
provide a completed fee table at least 5 days prior to effectiveness.

Response
#4

The
Registrant has provided a completed fee table below:

Annual
Fund Operating Expenses

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

    Management
    Fee
    0.45%

    Distribution
    and/or Service (12b-1) Fees
    NONE

    Other
    Expenses(1)
    0.10%

    Total
    Annual Fund Operating Expenses
    0.55%

    Fee
    Waiver(2)
    (0.20%)

    Total
    Annual Fund Operating Expenses After Fee Waiver and Reimbursement
    0.35%

 (1) Other
                                            Expenses are estimated for the Fund’s initial fiscal year.

June
14, 2024

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3

 (2) The
                                            Fund’s adviser has contractually agreed to waive its fees and reimburse expenses of
                                            the Fund until June 30, 2025, so that the
                                            Total Annual Operating Expenses After Fee Waiver and Reimbursement (excluding: (i) any front-end
                                            or contingent deferred loads; (ii) brokerage fees and commissions, (iii) acquired fund fees
                                            and expenses; (iv) borrowing costs (such as interest and dividend expense on securities sold
                                            short); (v) taxes; and (vi) extraordinary expenses, such as litigation expenses (which may
                                            include indemnification of Fund officers and Trustees, contractual indemnification of Fund
                                            service providers (other than the adviser)) will not exceed 0.35%,
                                            of average daily net assets (“Operating Expense
                                            Limitation Agreement”). These fee waivers and expense reimbursements
                                            are subject to possible recoupment from the Fund within the three years after the fees have
                                            been waived or reimbursed, if such recoupment can be achieved within the lesser of the foregoing
                                            expense limits or the expense limits in place at the time of recoupment. This Operating
                                            Expense Limitation Agreement may be terminated only by the Board of Trustees
                                            on 60 days’ written notice to the Fund’s adviser,
                                            Kurv Investment Management LLC.

Example

This
Example is intended to help you compare the cost of investing in the Fund with the cost of investing in mutual funds and other exchange
traded funds.

The
Example assumes that you invest $10,000 in the Fund for the time periods indicated and then sell 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 (including the effect of the Operating Expenses Limitation Agreement through June 30, 2025).
The figures shown would be the same whether or not you sold your Shares at the end of each period.

Although
your actual costs may be higher or lower, based on these assumptions your costs would be:

    1
    Year
    3
    Years

    $          36%
    $          156%

Comment
#5

In
footnote 2 of the fee table, please confirm that the period for fee waiver will be at least one year after the prospectus goes effective.

Response
#5

The
Registrant confirms that the fee waiver will be at least one year from the date the prospectus is effective. Please see the revised footnote
in the response to Comment #4 above.

Summary
Section – Principal Investment Strategies

Comment
#6

We
note that the Registrant’s name includes “Short Maturity,” however, in the investment strategy section, it states that
the Fund will invest in fixed income instruments of varying maturities. Should the name and strategy agree?

June
14, 2024

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4

Response
#6

The
Registrant notes that the name is not inconsistent with the Fund’s investment strategies. The Registrant notes that in the same
paragraph to which the Staff refers, it states “The dollar-weighted average portfolio maturity of the Fund is normally not expected
to exceed three years.” The Fund can therefore purchase securities of varying maturity so long as normally the average portfolio
maturity is not more than three years. For example, the Fund can purchase 50% of the portfolio of a 2-year maturing bond, and purchase
50% of a 4-year maturity bond, and the average is three years.

Comment
#7

In
paragraph (2) beginning with “Option income strategy” of In the “Principal Investment Strategies” section, you
reference “futures”, “swaptions” and “fed funds.” Please briefly define these terms in this section.

Response
#7

The
Registrant has revised the disclosure in response to the comment. Please see the revised disclosure below:

(2)
        Option income strategy: To generate additional income, the Fund employs an exchange-traded and over-the-counter (“OTC”)
option writing strategy on fixed income.
The Adviser focuses on instruments.
These fixed income based
on domestically traded futures or swaptions, for example, such as those linked to the fed funds or on US treasuries instruments
may include instruments such as futures contracts or interest rate swaps , linked to the federal funds rate (the target interest rate
range at which commercial banks borrow and lend their excess reserves to each other overnight as set by the Federal Open Market Committee)
or on U.S. Treasury securities. A call
option gives the owner the right, but not the obligation, to buy a future at a specified price (strike price) within a specific time
period. A put option gives the owner the right, but not the obligation, to sell a future at a specified price (strike price) within a
specific time period. By selling put and call options in return for the receipt of premiums (the purchase price of an option), the adviser
attempts to increase Fund income as the passage of time decreases the value of the written options. Gains from written option premiums
are capital gains, but commonly referred to as income. The option writing strategy is a form of leveraged investing. The adviser focuses
on writing short-term options with less than six-month to maturity because their value erodes faster than long-term options. Options
may also be purchased or sold for hedging purposes or tail risk management to limit extreme volatility.

In
addition to updating the reference from “futures” to “futures contracts” the Registrant has added a definition
to the Futures Contract Risk factor. Please see the revised disclosure below:

Futures
Contract Risk:  the
risk that, whileA
futures contract is a legal agreement to buy or sell a particular commodity, asset, or security at a predetermined price at a specified
time in the future. While the
value of a futures contract tends to correlate with the value of the underlying asset that it represents, differences between the futures
market and the market for the underlying asset may result in an imperfect correlation. Futures contracts may involve risks different
from, and possibly greater than, the risks associated with investing directly in the underlying assets. The purchase or sale of a futures
contract may result in losses in excess of the amount invested in the futures contract.

June
14, 2024

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5

Summary
Section – Principal Risks of Investing in the Fund

Comment
#8

Please
add an “Exchange-Traded Fund (ETF) Risk” factor. Please address the following ETF related risks, as applicable:

 a. Market
                                            Risk

 b. Absence
                                            of Active Trading Market

 c. Liquidity
                                            Risk

 d. International
                                            Securities Risk

Response
#8

The
Registrant has added the ETF risk factor as requested. Please see below:

Exchange
Traded Fund (ETF) Structure Risk

The
Fund is structured as an exchange traded fund and as a result is subject to special risks, including:

 ● Market
                                            Price Variance Risk. The market prices of shares will fluctuate in response to changes in
                                            NAV and supply and demand for shares and will include a “bid-ask spread” charged
                                            by the exchange specialists, market makers or other participants that trade the particular
                                            security. There may be times when the market price and the NAV vary significantly. This means
                                            that Shares may trade at a discount to NAV.

 ● Authorized
                                            Participant Risk. In times of market stress, market makers may step away from their role
                                            market making in shares of exchange traded funds and in executing trades, which can lead
                                            to differences between the market value of Fund shares and the Fund’s NAV.

 ● Trading
                                            Issues. In stressed market conditions, the market for the Fund’s shares may become
                                            less liquid in response to the deteriorating liquidity of the Fund’s portfolio. This
                                            adverse effect on the liquidity of the Fund’s shares may, in turn, lead to differences
                                            between the market value of the Fund’s shares and the Fund’s NAV.

 ● Absence
                                            of Active Trading Market Risk. An active trading market for the Fund’s shares may not
                                            be developed or maintained. Trading in Shares on the Exchange may be halted due to market
                                            conditions or for reasons that, in the view of the Exchange, make trading in Shares inadvisable,
                                            such as extraordinary market volatility. There can be no assurance that Shares will continue
                                            to meet the listing requirements of the Exchange. If the Fund’s shares are traded outside
                                            a collateralized settlement system, the number of financial institutions that can act as
                                            authorized participants that can post collateral on an agency basis is limited, which may
                                            limit the market for the Fund’s shares.

June
14, 2024

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6

Comment
#9

Please
consider adding a private security risk factor.

Response
#9

The
Registrant respectfully declines to add an additional risk factor regarding private security risk. The Registrant believes that it already
addresses the risks associated with private securities noting that the Fund already includes liquidity risk which addresses certain private
securities such as Rule 144A securities as well as a specific risk factor regarding CLOs which are also privately offered.

Comment
#10

If
there will be emerging market investments, please add an applicable risk factor and disclose this in the strategy as well.

Response
#10

The
Registrant confirms that the emerging market investments will not be a principal investment of the Fund

Comment
#11

“Short
Exposure Risk” is included as a risk factor. If the Fund engages in short sales, please include the principal investment strategy
section. If not, please remove the risk factor.

Response
#11

The
Registrant confirms that is will not engage in short sales. The Registrant has removed the risk factor.

Summary
Section – Portfolio Managers

Comment
#12

Under
“Portfolio Managers,” please fill in, when available, the dates when the listed individuals began acting as portfolio managers
for the Fund and add “since inception.”

Response
#12

The
Registrant has updated the disclosure in response to the comment.

Statutory
Section - Additional Information About The Fund’s Investment Objectives, Strategies And Risks

Comment
#13

Please
complete the Item 9b disclosure. Item 9 should be more comprehensive than Item 4 as the Registrant currently has it in the prospectus.

June
14, 2024

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7

Response
#13

The
Registrant has revised the disclosure in response to the comment. Please see the revised disclosure below:

Additional
Information Regarding Investment Techniques and Policies:

The
Fund’s inve