SecProbe.io

CORRESP
1
filename1.htm

The Atlantic Building

950 F Street, NW

Washington, DC 20004-1404

202-239-3300 | Fax: 202-239-3333

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

June 20, 2024

VIA EDGAR

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Attn: Christopher Bellacicco

    Re:

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

    Post-Effective Amendment No. 12 to the Trust’s Registration
    Statement on Form N-1A, filed on April 9, 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 April 30, 2024, relating to Post-Effective Amendment No. 12 (“PEA No. 12”) to the Trust’s Registration Statement
on Form N-1A filed on April 9, 2024, regarding the Kurv Yield Premium Technology Select ETF (now known as the Kurv Technology Titans Select
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.

Alston & Bird LLP www.alston.com

Atlanta | Beijing | Brussels | Charlotte | Dallas | Los Angeles | New York | Research Triangle | San Francisco | Silicon Valley | Washington, D.C.

    June 20, 2024

Page 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

Summary Section – Fees and Expenses

Comment #2

In the “Fund Fees and Expenses”
section, please provide a completed fee table and expense example table with your response.

Response #2

Please see the completed fee table
and expense example below:

Annual Fund Operating Expenses

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

    Management Fee
    0.99%

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

    Other Expenses(1)
    0.10%

    Acquired Fund Fees and Expenses(2)
    0.20%

    Total Annual Fund Operating Expenses
    1.29%

    Fee Waiver(3)
    (0.30%)

    Total Annual Fund Operating Expenses After Fee Waiver and Reimbursement
    0.99%

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

 (2) Acquired Fund Fees and Expenses are estimated for the Fund’s initial fiscal year.

 (3) 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 0.79%, of average daily
net assets (“Operating Expenses 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 Expenses 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.

    June 20, 2024

Page 3

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 only 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

    $ 101
    $ 379

Comment #3

In the lead-in language to the
Example in the “Fund Fees and Expenses” section, please add disclosure stating that the example assumes that the fee waiver
is in effect only for the time period indicated in the fee table as required by Instruction 4(a) to Item 3 of Form N-1A.

Response #3

The Registrant has added the requested
disclosure. Please see the response to Comment #2 above.

Summary Section – Principal
Investment Strategies

Comment #4

In the “Principal Investment
Strategies” section, please clarify whether the technology companies in which the Fund will invest will be limited to those incorporated
in the U.S. or whether such companies may be incorporated in foreign jurisdictions.

Response #4

The Registrant confirms that the
Fund may invest in both U.S. and non-U.S. technology companies. Please see the revised disclosure below:

Principal Investment Strategies

The Fund is an actively managed exchange-traded fund
(“ETF”) that primarily invests its assets in the shares of other ETFs as well as the equity
securities of, or derivative instruments (e.g. options) relating to, individual companies in theU.S.
and non-U.S. technology sectorcompanies
(“Technology Companies”). generally
with market capitalizations in excess of $10 billion as well as the shares of other ETFs that invest in Technology Companies. The Fund
defines “Technology Companies” to include those companies that provide technology products or services, that benefit from
utilizing technology to gain competitive advantages, improve their business processes, products or applications, or that have introduced
technologically enabled new products or services that potentially change the way the world works.

    June 20, 2024

Page 4

The Fund will invest in the equity
securities of, or derivative instruments (e.g. options) relating to, Technology Companies. The Fund will also invest in the Kurv
Yield Premium ETFs (“Underlying Kurv Yield Premium ETFs”) and other Kurv ETFs (“Underlying Other Kurv ETFs” and,
together with Underlying Kurv Yield Premium ETFs, the “Underlying Kurv ETFs”), which are ETFs advised by Kurv Investment Management
LLC (the “Adviser”), the adviser to the Fund, and, in the case of the Underlying Kurv Yield Premium ETFs, are sub-advised
by NEOS Investment Management (“NEOS” or the “Sub-Adviser”). A number of the Underlying Kurv ETFs have a primary
investment objective to seek current income, and a secondary investment objective to seek exposure to the share price of the common stock
(the “Underlying Security”) of a particular Technology Company (the “Underlying Issuer”), subject to a limit on
potential investment gains. The Fund will also invest in the equity securities of, or derivative instruments
(e.g. options) relating to,In selecting individual
Technology Companies to invest in or have exposure to, the Adviser seeks
Technology Companies with favorable outlooks, examining characteristics of a particular issuer, such as growth or momentum.

Cash and/or Synthetic Long Exposure

The Fund may gain long exposure via purchasing shares
of individual companies or creating a synthetic long position. To achieve a synthetic long exposure, the Fund buys call options of a technology
company and, simultaneously, sells put options of the same company to try to replicate the price movements of underlying company. The
combination of the long call options and sold put options seek to provide the Fund with investment exposure to the underlying company
for the duration of the application option exposure. The notional exposure
to an underlying company will not exceed 150% of net asset value. The call options the Fund buys and the put options it sells will
be at the same strike price and have the same expiration, however, the amount
may differ.

When writing options, the Fund is required to post collateral
to assure its performance to the option buyer. The Fund will hold cash and cash-like instruments or high-quality short-term fixed income
securities (collectively, “Collateral”). The Collateral may consist of (1) U.S. Government securities, such as bills, notes
and bonds issued by the U.S. Treasury; (2) government securities issued by G-10 countries, on a hedged
or unhedged basis (Belgium, Canada, France, Germany, Italy,
Japan, the Netherlands, Sweden, Switzerland, the United Kingdom, and the United States); (3) money market funds; (4) fixed income
ETFs; and/or (5) corporate debt securities, such as commercial paper and other short-term unsecured promissory notes issued by companies
that are rated investment grade or of comparable quality. The Adviser considers an unrated security to be of comparable quality to a security-rated
investment grade if it believes it has a similar low risk of default. The
Fund expects to invest in fixed income securities with low duration to minimize interest rate risk and the Fund’s exposure to foreign
exchange to be less than 5% of its net assets. Kurv actively manages the Collateral held by the Fund with a view toward enhancing
the Fund’s total return.

Covered Call Writing

Based on the Advisor’s
market forecastAs part of its strategy, the Fund may
write (sell) call option contracts on individual companycompanies
to generate income. If the fundFund
gains long exposure synthetically, since the Fund does not directly own shares of the company, these written call options will be sold
short (i.e., selling a position it does not currently own).

    June 20, 2024

Page 5

It is important to note that the sale of a company’s
call option contracts will limit the Fund’s participation in the appreciation in the company’s stock price. If the stock price
of the company increases, the above-referenced synthetic and/or holding the underlying stock directly would allow the Fund to experience
similar percentage gains. However, if the company’s stock price appreciates beyond the strike price of one or more of the sold (short)
call option contracts, the Fund will lose money on those short call positions, and the losses will, in turn, limit the upside return of
the Fund’s synthetic and long stock exposure. As a result, the Fund’s overall strategy (i.e., the combination of the synthetic
and/or long stock exposure to the company and the sold (short) the company’s call positions) will limit the Fund’s participation
in gains in the company’s stock price beyond a certain point.

When the Fund engages in covered call writing with
respect to the companyan
underlying stock, it receives cash from the buyer of the call option who in exchange for that cash obtains the right to purchase
the company on or before the expiration date at a predetermined price called the strike price. Writing covered call options is also considered
long short. Generally, the notional principal amount of written covered call
options will not exceed the principal amount of the synthetic or long stock position in the company, however, the Fund may write call
options for an amount in excess of the value of a company’s position in the Fund’s portfolio.

Uncovered
Call and/or Put Writing

The
Fund may also write (i.e., sell) uncovered call options on securities or instruments in which it may invest but that are
not currently held by the Fund. The principal reason for writing uncovered call options is to realize income without committing
capital to the ownership of the underlying securities or instruments. When writing uncovered call options, the Fund must
deposit and maintain sufficient margin with the broker-dealer through which it made the uncovered call option as collateral
to ensure that the securities can be purchased for delivery if and when the option is exercised. During periods of declining securities
prices or when prices are stable, writing uncovered calls can be a profitable strategy to increase the Fund’s income with minimal
capital risk. Uncovered calls are riskier than covered calls because there is no underlying security held by the Fund that can act
as a partial hedge. Uncovered calls have speculative characteristics and the potential for loss is unlimited. When an uncovered
call is exercised, the Fund must purchase the underlying security to meet its call obligation. There is also a risk, especially
with preferred and debt securities that lack sufficient liquidity, that the securities may not be available for purchase. If the
purchase price exceeds the exercise price, the Fund will lose the difference.

The
Fund also may write (i.e., sell) uncovered put options on securities or instruments in which it may invest but with respect to which
the Fund does not currently have a corresponding short position or has not deposited as collateral cash equal to the exercise value
of the put option with the broker-dealer through which it made the uncovered put option. The principal reason for writing uncovered
put options is to receive premium income and to acquire such securities or instruments at a net cost below the current market value.
The Fund has the obligation to buy the securities or instruments at an agreed upon price if the price of the securities or instruments
decreases below the exercise price. If the price of the securities or instruments increases during the option period, the option
will expire worthless and the Fund will retain the premium and will not have to purchase the securities or instruments at the
exercise price.

If
the Adviser determines to employ a covered call strategy for a Technology Company for which there is a Kurv Yield Premium Strategy ETF
that tracks the same Technology Company, the Adviser may invest in the Kurv Yield Premium Strategy ETF to increase portfolio management
efficiency in gaining the same exposure.

    June 20, 2024

Page 6

Current Underlying Kurv ETFs include:

    Underlying Kurv ETF (Ticker)
    Underlying Issuer

    Kurv Yield Premium Strategy Apple (AAPL) Strategy ETF (Ticker: AAPY)
    Apple Inc.

    Kurv Yield Premium Strategy Amazon (AMZN) Strategy ETF (Ticker: AMZP)
    Amazon.com, Inc.

    Kurv Yield Premium Strategy Google (GOOGL) Strategy ETF (Ticker: GOOP)
    Alphabet Inc.

    Kurv Yield Premium Strategy Microsoft (MSFT) Option Income Strategy ETF (Ticker: MSFY)
    Microsoft Corporation

    Kurv Yield Premium Strategy Netflix (NFLX) Strategy ETF  (Ticker: NFLP)
    Netflix, Inc.

    Kurv Yield Premium Strategy Tesla (TSLA) Strategy ETF  (Ticker: TSLP)
    Tesla, Inc.

    Kurv Enhanced Short Maturity ETF (Ticker: LQID)
     Multiple issuers

The Fund may also invest in any Kurv ETF
formed in the future that supports the Adviser in meeting the investment objective.

Under normal market conditions, the Fund
will invest at least 80% of its net assets (plus borrowings for investment purposes) in the securities of, or ETFs and derivative instruments