SecProbe.io

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            Stradley Ronon Stevens & Young, LLP

            2005 Market Street

            Suite 2600

            Philadelphia, PA 19103

            Telephone  215.564.8000

            Fax  215.564.8120

            www.stradley.com

    J. Stephen Feinour, Jr.

    (215) 564-8521

    jfeinourjr@stradley.com

    February 24, 2020

    Filed via EDGAR

    Ms. Karen Rossotto

    U.S. Securities and Exchange Commission

    100 F Street, NE

    Washington, DC 20549

            Subject:

            AIM ETF Products Trust (the “Trust”)

            (File Nos. 811-23504; 333-235734)

    Dear Ms. Rossotto:

    On behalf of the Trust, below are the Trust’s responses to the comments you provided us with regard to the Trust’s initial registration statement on Form N-1A (the “Registration Statement”) relating to the registration
      of the AllianzIM U.S. Large Cap Buffer10 Apr ETF, AllianzIM U.S. Large Cap Buffer15 Apr ETF (to be renamed the AllianzIM U.S. Large Cap Buffer20 Apr ETF), AllianzIM U.S. Large Cap Buffer25 Apr ETF, AllianzIM International Buffer15 Apr ETF and
      AllianzIM Emerging Markets Buffer20 Apr ETF series of the Trust.  The Registration Statement was filed with the U.S. Securities and Exchange Commission (“SEC”) on December 27, 2019 under Section 8 of the Investment Company Act of 1940, as amended
      (the “1940 Act”), and Section 6 of the Securities Act of 1933, as amended (the “Securities Act”). The Trust is no longer seeking to register the AllianzIM U.S. Large Cap Buffer25 Apr ETF, AllianzIM International Buffer15 Apr ETF and AllianzIM
      Emerging Markets Buffer20 Apr ETF as part of the Trust’s initial Registration Statement and, therefore, those Funds will be removed from the Registration Statement.  Below we have provided your comments and the Trust’s response to each comment.
      Capitalized terms not otherwise defined in this letter have the meanings assigned to the terms in the Registration Statement.

    General

    1.            Comment: We note that portions of the registration statement are incomplete. We may have additional comments on such portions when you complete them in a
      pre-effective amendment, on disclosures made in response to this letter, on information supplied supplementally, or on exhibits added in any amendments.

    Response: The Trust acknowledges this comment.

    2.            Comment: Please supplementally explain if the Fund has submitted or intends to submit an

      Philadelphia, PA • Harrisburg, PA • Malvern, PA • Cherry Hill, NJ • Wilmington, DE • Washington,
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      A Pennsylvania Limited Liability Partnership

    exemptive application or no-action request in connection with the registration statement, or if the Fund anticipates requesting such relief in the future.

    Response: The Trust confirms it has not submitted an exemptive application or no-action request in connection with the registration statement and currently
      does not intend to do so.  The Funds will rely on Rule 6c-11 under the 1940 Act and the corresponding Securities Exchange Act of 1934 (the “1934 Act”) SEC exemptive order (SEC Release No. 34-87110 (Sept. 25, 2019)).

    3. Throughout the registration statement, please avoid technical terminology and complex language. See, Form N-1A, General Instruction C.(c).

    Response: The Trust acknowledges this comment and has made appropriate revisions to the Registration Statement.

    Prospectus

    AllianzIM U.S. Large Cap Buffer10 Apr ETF

    Cover Page

    4.            Comment: The disclosure in the first bullet on the Cover Page states “[t]he Fund’s investment objective intends to provide return attribute characteristics that
      are distinct from traditional strategies.” First, revise the disclosure to clarify that this is not the Fund’s investment objective. Second, the meaning and purpose of this disclosure is unclear. Please delete or revise and clarify the meaning of
      this bullet in plain English.

    Response: The Trust has revised the above-cited disclosure as requested.

    5.            Comment: The disclosure in the second bullet states “[t]he Fund uses FLEX Options to pursue a defined outcome strategy that seeks to achieve investment
      outcomes based upon the performance of an underlying security or index at the end of the Outcome Period [emphasis added].” The term “Outcome Period” has not yet been defined. Please define Outcome Period
      here, or provide a cross reference to the definition.

    Response: The Trust has revised the disclosure as follows:

    The Fund uses FLEX Options to seek to deliver returns that match, at the end of a specified one-year period described below (the “Outcome Period”), the returns of the S&P 500 Price Index up to the Cap (defined
      below), while limiting downside losses by the amount of the Buffer (defined below). The outcomes sought by the Fund may only be realized where a shareholder holds shares of the Fund for the entire Outcome Period.

    As of the date of this prospectus, the outcomes sought by the Fund are based upon the performance of the S&P 500 Price Index over the Outcome Period of April 1, 2020 through
        March 31, 2021. Following this Outcome Period, each subsequent Outcome Period will be a one-year period from April 1 to March 31.

    6.            Comment: In the second sentence of the third bullet, please replace the phrase “at the beginning” with “on the first day.”

    Response: The above-cited disclosure has been deleted and the Trust notes that additional

    clarifying disclosure has been added to the prospectus in response to this comment.

    7.            Comment: In the fourth bullet, the disclosure states that “the Fund’s returns are based upon the performance of the [TBD LARGE CAP] Price Index… .” Since the
      Fund’s returns are based upon a price-return index, which does not reflect the reinvestment of dividends, disclose, if accurate, that the Fund’s returns do not reflect the reinvestment of dividends.

    Also in the same bullet, cap is defined as “cap,” whereas in the second bullet it is defined as “Cap.” As the cap and buffer are principal components of the Fund’s investment strategy, please
      consider defining these terms clearly and in plain English here. Please refer to the defined terms consistently throughout the registration statement.

    Response: The Trust notes that the Fund’s principal investments in FLEX Options do not provide for dividends to the Fund, as disclosed in the prospectus (see,
      e.g., “Investor Considerations”).  The Trust confirms that the Fund’s returns will reflect the reinvestment of dividends, if any, consistent with the requirements of Form N-1A.  The Trust confirms that the Registration Statement, as revised, clearly
      defines the terms “Cap” and “Buffer,” and those defined terms are used consistently throughout the Registration Statement.

    8.            Comment: In the fifth bullet, first sentence, the disclosure states “[t]he Fund only seeks to provide shareholders that hold shares for the entire Outcome Period with a buffer against the
      first 10% of [TBD LARGE CAP] Price Index losses (based upon the value of the [TBD LARGE CAP] Price Index at the time the Fund entered into the FLEX Options at or near the beginning of the Outcome Period)
      during the Outcome Period [emphasis added].” Please replace “at or near the beginning” with “the first day,” or a similarly precise time (e.g., the first business day).

    Response: The Trust has revised the above-cited disclosure as follows:  “… at the time the Fund enters into the FLEX Options on the business day immediately
      prior to the first day of the Outcome Period”, and has made other clarifying changes in response to this comment.

    9.            Comment: In the same bullet, second sentence, the disclosure states “[y]ou will bear all [TBD LARGE CAP] Price Index losses exceeding 10% on an expected one-to-one basis [emphasis added].” Please explain supplementally why the phrase “an expected” is included here (is there any circumstance in which the losses would not be born on a one-to-one basis?)

    Response: The Trust confirms that Fund shareholders are expected to bear all S&P 500 Price Index losses exceeding 10% on a one-to-one basis, and that the phrase “an expected”
      is included in this context in the event unforeseen circumstances arise that prevent the Fund from achieving its objective, similar to disclosure elsewhere in the prospectus stating that there is no guarantee that the Fund will successfully achieve
      its investment objective or that the outcomes sought for an Outcome Period will be realized.

    10.          Comment: Please disclose on the Cover Page a simple and clear description of the goal of the Fund. For example, consider disclosing here the language from page 10, Buffered Loss Risk, “[t]he Fund’s strategy seeks to deliver returns that match those of the [TBD LARGE CAP] Price Index (up to the cap), while limiting downside losses if Shares are bought on the day on which the Fund enters into
      the FLEX Options and held until those FLEX Options expire at the end of each Outcome Period.” Please also delete this disclosure from Buffered Loss Risk as it does not describe a risk to investors of the
      Fund.

    Response: The Trust has revised the Cover Page as requested. The Trust has also removed the

    above-cited disclosure from the Buffered Loss Risk as requested.

    Prospectus Summary

    11.          Comment: On page 2, in Principal Investment Strategies, General Strategy Description, the disclosure states “[u]nder
      normal market conditions, the Fund invests at least 80% of its net assets in instruments that create exposure to U.S. large cap equity securities.” Immediately following “net assets,” please insert the phrase “plus any borrowings for investment
      purposes.” In addition, please supplementally confirm that 80% of the Fund’s net investments, plus any borrowings for investment purposes, have similar economic characteristics to U.S. large cap equity securities.

    Response: The following language is currently set forth in the statement of additional information (“SAI”) for the Fund under “Names Rule Policies”:  “Net
      assets for purposes of an 80% policy include the amount of any borrowings for investment purposes” (emphasis added).  Because the Fund does not intend to engage in borrowings for investment purposes as
      part of its principal investment strategies, the Trust does not believe that disclosure in the prospectus of the impact of borrowings on the 80% policy for the Fund is needed or appropriate at this time.  The Trust confirms that, under normal market
      conditions, 80% of the Fund’s net investments, plus any borrowings for investment purposes, will create investment exposures having similar economic characteristics to U.S. large cap equity securities.

    12.          Comment: Also in this paragraph, please disclose how many securities are included in the index and how the index defines large cap securities. In addition,
      please describe in plain English what an option contract is.

    Response: The Trust has revised the disclosure as requested.

    13.          Comment: In the second paragraph in General Strategy Description, the disclosure in the first sentence states “[t]he Fund uses FLEX Options to employ
      an outcome-based strategy which seeks to match the performance of the [TBD LARGE CAP] Price Index, subject to a buffer and cap.” Please revise this sentence in plain English. In particular, please describe what an “outcome-based strategy” is and what
      a “buffer and cap” is.

    Response: The Trust has made clarifying revisions throughout this section of the prospectus to streamline and rephrase the disclosure in plain English as
      appropriate. Specifically, the above-cited disclosure has been revised as follows:

    The Fund pursues a buffered outcome strategy that seeks to match the returns of the S&P 500® Price Return Index (“S&P 500 Price Index”), at the end of a specified one-year period from April 1 to March
      31, as described below (the “Outcome Period”), subject to an upside maximum percentage return (the “Cap”) and a downside buffer against the first 10% of losses (the “Buffer”).

    14.          In regard to the disclosure in the bullets in this section, please address the following comments:

    a. In the first bullet, the disclosure states that
      “the combination of FLEX Options held by the Fund is designed to provide upside participation that is intended to match that of the [TBD LARGE CAP] Price Index… .” Please revise this disclosure in plain English. In particular, please clarify the term
      “upside participation.”

    Response: The Trust has revised the disclosure as follows:

    If the S&P 500 Price Index has appreciated in value as of the end of the Outcome Period, the combination of FLEX Options held by the Fund is designed to provide positive returns that match the return of the S&P
      500 Price Index, up to the Cap.

    b. In the second bullet, the disclosure states
      that “the combination of FLEX Options held by the Fund is designed to provide a payoff at expiration that is intended to compensate for losses experienced by the [TBD LARGE CAP] Price Index (if any), in an amount not expected to exceed 10% before
      fees and expenses.” Again, please revise this disclosure in plain English. In particular, please clarify what a “payoff at expiration” refers to.

    Response: The Trust has revised the disclosure as follows:

    If the S&P 500 Price Index has decreased in value as of the end of the Outcome Period, the combination of FLEX Options held by the Fund is designed to compensate for losses experienced by the S&P 500 Price Index
      in an amount up to 10% of such losses.

    c. In the third bullet, please clarify what a “one-to-one basis” is.

    Response: The Trust has revised the above-cited disclosure as follows:

    If the S&P 500 Price Index has decreased in value by more than 10% as of the end of the Outcome Period, the Fund is expected to experience all subsequent losses experienced by the S&P 500 Price Index on a
      one-to-one basis, meaning that the Fund will decrease 1% for every 1% decrease in the S&P 500 Price Index (i.e., if the S&P 500 Price Index loses 20%, the Fund loses approximately 10%).

    15.          Comment: In Buffer and Cap, in the carry-over paragraph at the top of page 4, a majority of the paragraph is bolded. If
      there are particular concepts you believe should be emphasized for investors, consider disclosing in bold only those concepts. Please also present the disclosure in this paragraph clearly and in plain English. Please make similar changes to the
      bolded language throughout this section.

    Response:  The Trust has reviewed the disclosure in the above-cited paragraph and has made clarifying revisions where appropriate.  The Trust notes that
      certain disclosure has also been moved to the Item 9 section of the prospectus and further revised in response to other comments provided.

    16.          Comment: Also in Buffer and Cap, in the carry-over paragraph at the top of page 4, please consider disclosing more
      prominently (e.g., set-off and in bold) the last two sentences of this paragraph.

    Response: The Trust has revised the disclosure as requested.

    17.          Comment: On page 5, in Buffer and Cap, the penultimate sentence in the first paragraph, beginning “[t]he portfolio
      manager will calculate…” is long and technical. Please break up the sentence and revise for plain English.

    Response: The above-cited disclosure has been deleted.

    18.          Comment: On page 5, in Use of Flex Options, the disclosure in the last sentence of the first