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 4, 2025

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. 27 to the Trust’s
    Registration Statement on Form N-1A filed on March 7, 2025

    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 22, 2025, relating to Post-Effective Amendment No. 27 (“PEA No. 27”) to the Trust’s Registration Statement
on Form N-1A filed on March 7, 2025, regarding the Kurv Gold Enhanced Income ETF, Kurv Silver Enhanced Income ETF, and Kurv Platinum Enhanced
Income ETF (each a “Fund” and, collectively, the “Funds”), each 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 4, 2025

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

	With regard to the fee table on page three
of the Prospectus, please provide a completed fee table and expense example with your response.

Response #2

The Registrant has provided
a 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)
    0.00%

    Acquired Fund Fees and Expenses(2)
    0.01%

    Total Annual Fund Operating Expenses
    1.00%

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

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

 Example

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

The Example assumes that you invest $10,000
in the Gold 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 Gold Fund’s operating expenses remain the same. 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

    $ 102
    $318

    June 4, 2025

Page 3

Summary Section: Principal Investment
Strategies

Comment #3

In the first paragraph
of the “Principal Investment Strategies” section on page four of the Prospectus, please clarify whether the Fund will invest
directly in gold.

Response #3

The Registrant notes that
the Fund may invest in physical gold and has clarified the disclosure in response to the comment. Please see the revised disclosure below:

Principal Investment
Strategies

The
Gold Fund seeks to exceed the price return of Goldgold
bullion by primarily investing under normal circumstances in Gold
and Goldderivative instruments on gold bullion-related
exchangedexchange
traded products (“ETPs”), including Goldgold
bullion-related exchange traded funds, as well as derivatives on Gold and Gold (“ETFs”)
and gold bullion-related ETPsexchange
traded notes (“ETNs”), backed by a portfolio of Fixed Income Instruments of varying maturities, which may be represented
by options and forwards, as well as Preferred Securities Instruments.
The Fund may also invest in gold-bullion related ETFs directly as well as
in physical gold and derivative instruments on gold.

Gold bullion-related
ETPsETFs are
those that invest primarily in physical Goldgold
bullion and/or over-the-counter or exchange-traded derivatives on Goldgold
bullion such as forward contracts, futures contracts, and options contracts or swap contracts. Gold
bullion related ETNs are those with interest and/or principal payments linked to the price of gold bullion. Derivatives are primarily
used as substitutes for gold bullion because they are expected to produce returns that are substantially similar to those of gold bullion.
Derivatives used by the Fund are expected to produce a significant portion of the Fund’s returns. The Fund does not invest more
than 25% of Fund assets in over-the-counter derivative contracts with any one counterparty. ETFs and ETNs may employ leverage, which magnifies
the changes in the underlying gold index or gold price upon which they are based. Gold bullion-related ETPs generally are not registered
under the Investment Company Act of 1940, as amended, and, generally, are not actively managed.

“Fixed
Income Instruments” include bonds, debt securities, and other similar instruments issued by various U.S. and non-U.S. public- or
private-sector entities as well as ETPs on such instruments and options on such ETPs. “Preferred Securities Instruments” consist
of preferred securities of U.S. companies and ETPs primarily investing in preferred securities. The Gold Fund may invest in U.S. and non-U.S.
Fixed Income Instruments of any maturity or duration.

    June 4, 2025

Page 4

The
Gold Fund normally uses option contracts on Goldgold
bullion-related ETPs and Gold bullion-related ETPs,
including FLEX options, to gain exposure to Goldgold
bullion. The value of option contracts on Goldgold
bullion-related ETPs as well as Goldgold
bullion-related ETPs should closely track changes in Goldgold
bullion prices.

The
Gold Fund may gain long exposure via purchasing shares of Gold and/or Goldgold
and/or shares of gold bullion-related ETPs or creating a synthetic long position. To achieve a synthetic long exposure, the Gold
Fund buys call options of a Gold or Goldgold
bullion-related ETP and, simultaneously, sells put options of the ETP with
the same expiries to try to replicate the price movements of the underlying ETP. The strike and
number of the call and put options contracts may differ. The combination of the long call options and sold put options
seek to provide the Gold Fund with investment exposure to the Gold or Goldgold
bullion-related ETP for the duration of the application option exposure. The notional exposure to an underlying Gold
or Gold gold bullion-related ETP when the Gold Fund
buys put and call options directly will not exceed 200% of net asset value.

Under
normal circumstances, the Gold Fund invests at least 80% of its net assets plus any borrowings for investment purposes in physical
gold or the securities of Gold or Goldgold
bullion-related ETPs or derivatives on Gold or Goldgold
or gold bullion-related ETPs, the value of which are linked to Gold bullion.  The
Gold Fund will consider the investments of the underlying ETPs in which it invests when determining compliance with its 80% policy. Additionally,
for the purposes of complying with its 80% investment policy, the Gold Fund will use the notional value of the derivatives it holds.

The
Gold Fund may invest, without limitation, in derivative instruments, such as options,
including FLEX options, forward and futures contracts, options on futures, or swap agreements, subject to applicable law and any
other restrictions described in the Gold Fund’s prospectus or Statement of Additional Information.

As
part of its strategy, the Gold Fund may employ various option strategies to generate income and/or to preserve capital. Example of strategies
are:

Covered
Call Writing

As
part of its strategy, the Gold Fund may write (sell) call option contracts on Gold and Goldgold
and gold bullion-related ETPs to generate income. If the Gold Fund gains long exposure synthetically, since the Gold Fund does
not directly own shares of the ETP, these written call options will be sold short (i.e., selling a position it does not currently own).
Any amount of covered call writing above the physical and synthetic long
positions will be considered uncovered. The Adviser may engage in uncovered calls rather than covered calls when it believes there might
be a mispricing of volatility in the market.

    June 4, 2025

Page 5

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

When
the Gold Fund engages in covered call writing with respect to an underlying ETP, it receives cash from the buyer of the call option who
in exchange for that cash obtains the right to purchase the ETP 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 position in the Gold or Goldgold
or gold bullion-related ETP, however, the Gold Fund may write call options for an amount in excess of the value of an ETP position
in the Gold Fund’s portfolio.

Uncovered
Call and/or Put Writing

The
Gold 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 Gold 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 Gold 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 Gold Fund’s income with minimal capital risk. Uncovered calls are riskier than
covered calls because there is no underlying security held by the Gold 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 Gold 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 Gold Fund will lose the difference.

    June 4, 2025

Page 6

The
Gold 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 Gold 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 Gold
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 Gold Fund will retain the premium and will not have to purchase the securities or instruments at the exercise price.

Call
or Put Spreads

The
Gold Fund may write (sell) call or put spreads instead of than stand-alone call option contracts to seek increased participation in the
potential appreciation of an underlying security or instrument’s ’s share
price, while still generating net premium income. In a call option spread, the Gold Fund may sell (write) an out-of-the-money call option
(above the current market price) while also purchasing a another call option that is
further out of the money. Similarly, in a put option spread, the Gold Fund may sell (write) an out-of-the-money put option (below the
current market price) while purchasing a further out-of-the-money put option.

Risk
Reversals or Protective Collars

The
Gold Fund may write (sell) risk reversals rather than stand-alone call option contracts to seek to limit loss from of an underlying security
or instrument’s share price. The cost of this protection would be offset by the premiums earned from a written call option. In a
risk reversal, the Gold Fund may sell (write) an out-of-the-money call option (above the current market price) call option while simultaneously
purchasing an out-of-the-money put option.

Protective
Puts

The
Gold Fund may purchase out-of-the-money protective put options to seek to limit loss from its underlying ETP share price. The cost of
protection may reduce the income generated in the portfolio.

Call
Purchases

    June 4, 2025

Page 7

The
Gold Fund may purchase call options to seek to gain price appreciation from its underlying ETP share price. The cost of the purchase may
reduce the income generated in the portfolio.

The
Fund intends to utilize traditional exchange-traded options contracts and/or FLexible EXchange® Options (“FLEX Options”).
Traditional exchange-traded options have standardized terms, such as the type (call or put), the reference asset, the strike price and
expiration date. Exchange-listed options contracts are guaranteed for settlement by the Options Clearing Corporation (“OCC”). FLEX
Options are a type of exchange-listed options contract with uniquely customizable terms that allow investors to customize key terms
like type, strike price and expiration date that are standardized in a typical options contract. FLEX Options are also guaranteed
for settlement by the OCC. Option contracts can either be “American” style or “European” style. The Fund generally
utilizes European style option contracts, which may only be exercised by the holder of the option contract on the expiration date of such
option contract and settled in