SecProbe.io

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    ROPES & GRAY LLP

    THREE EMBARCADERO CENTER

    SAN FRANCISCO, CA 94111-4006

    WWW.ROPESGRAY.COM

    July 12, 2023

    Edward B. Baer

T +1 415 315 6328

edward.baer@ropesgray.com

VIA EDGAR

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attn: Kimberly A. Browning

Anu Dubey

 Re: BondBloxx ETF Trust (the “Registrant”)

File Nos. 333-258986 and 811-23731

Dear Mses. Browning and Dubey:

This letter is being filed to respond to the telephonic
comments received from you on May 23, 2023 and July 6, 2023 regarding the staff of the Securities and Exchange Commission’s (the
“SEC”) review of Post-Effective Amendment No. 14 to the Registrant’s registration statement on Form N-1A (the “Registration
Statement”) filed with the SEC on April 6, 2023. The staff’s comments are summarized in bold to the best of our understanding,
followed by the Registrant’s responses. The Registrant’s responses will be reflected, to the extent applicable, in Post-Effective
Amendment No. 18 to the Registration Statement, which the Registrant expects to be filed on or about July 14, 2023. Capitalized terms
not defined in this letter have the meanings assigned to them in the Registration Statement.

Table of Contents/General

 1. The staff notes the category entitled “A Further Discussion of Other Risks.” Please confirm supplementally that all
principal risks included in Item 9 are also summarized in Item 4. Please relocate non-principal risks to the SAI.

The Registrant intends to remove references to “Focused
Investment Risk” and “Geographic Risks.” Aside from these revisions and the revisions discussed herein, the Registrant
believes the current disclosure adequately discloses the Fund’s principal strategies and risks. The Registrant notes that certain
risks included in Item 9 but not in Item 4 are intended to supplement and enhance Item 4 risk disclosure.

 2. Please confirm supplementally that the investment strategies discussed in the prospectus are all principal strategies. If not,
please relocate non-principal strategies and risks to the SAI. See Form N-1A, Items 4, 9 and 16.

See response to Comment #1.

Fund Overview

Investment Objective

 3. In the staff’s view, the statement articulated under the heading “Investment Objective” describes the Fund’s
investment strategy. Please revise the investment objective to describe the Fund’s investment objective and goals.

The Registrant intends to revise the Fund’s investment
objective as follows (additions in bold/underline and deletions in strike-throughs):

The BondBloxx USD High Yield Bond Sector Rotation ETF
(the “Fund”) seeks to provide total return by primarily investing primarily invest its assets
in U.S. dollar-denominated, high yield corporate bonds in the various sectors of the fixed income securities market through other exchange-traded
funds (“ETFs”).

Fees and Expenses

 4. Please place the second paragraph under “Fees and Expenses” in bold. See Form N-1A, Item 3.

The Registrant intends to make the requested change.

 5. Please disclose in a footnote to the table that Acquired Fund fees and expenses are based on estimated amounts for the current
fiscal year. See Form N-1A, Item 3, Instruction 3(f)(iv).

The Registrant intends to make the requested change.

Principal Investment Strategies

 6. The second sentence of the first paragraph under this section states: “The Fund is newly organized and expects to operate
as a “fund of funds,” meaning that it expects to invest its assets in securities of other ETFs.” Please update this
sentence to remove the anticipatory language “expects to.”

The Registrant intends to revise the above-mentioned disclosure
as follows (additions in bold/underline and deletions in strike-throughs):

The Fund is newly organized and expects to operate
operates as a “fund of funds,” meaning that it expects to invest primarily invests
its assets in securities of other ETFs.

 7. Please supplementally inform the staff what percentage the Fund expects to invest in Underlying Funds. The staff notes the Fund’s
80% policy is not just in Underlying Funds.

The Registrants expects that the Fund will be close to fully
invested at all times in the Underlying Funds.

    -2-

 8. The third sentence of the first paragraph under this section states: “In particular, the Fund allocates its assets among
ETFs that each focus on U.S. dollar-denominated, high yield corporate bonds in the various sectors of the fixed income securities market
. . .” Please indicate that such securities are commonly referred to as “junk bonds.”

The Registrant intends to add the requested disclosure.

 9. Please ensure that the Item 4 disclosure correlates to Item 9 disclosure.

The Registrant acknowledges the staff’s comment. See
also response to Comments #1 and #2.

 10. Please specify the credit quality ratings for the Fund’s principal investments, including such investments the Fund will
use in its respective 80% and 20% baskets, and include attendant risks.

The Registrant notes, as disclosed in “Principal Investment
Strategies,” the Fund intends to invest directly or indirectly (through high yield bond ETFs) in high yield bonds. The Registrant
believes that the current strategies and risk disclosures in the Registration Statement are sufficient for an investor’s consideration
of the risks associated with such strategy.

 11. Please indicate the credit quality ratings that the Fund will be exposed to by investing in the Underlying Funds for its principal
strategies.

The Registrant respectfully notes that the first paragraph
under “Principal Investment Strategies” states: “In particular, the Fund allocates its assets among ETFs that each focus
on U.S. dollar-denominated, high yield corporate bonds in the various sectors of the fixed income securities market . .
. Exposure to the Sectors is obtained by investing in ETFs that invest in the specific sectors included in the ICE BofA US Cash Pay High
Yield Constrained Index (the “Underlying Benchmark”), which is a rules-based index consisting of U.S. dollar-denominated below
investment grade bonds (as determined by ICE Data Indices, LLC (“IDI” or “Index Provider”)).” (emphasis
added) See also the response to Comment #25. For clarity, under “High Yield Securities Risk” in the Summary of Principal Risks
section, the Registrant notes that securities that are rated below investment-grade are sometimes referred to as “junk bonds.”
The Registrant believes that its Item 4 disclosure adequately describes the credit quality ratings that the Fund will be exposed to through
its investments in the Underlying Funds.

 12. As the Fund may make direct investments as part of its principal strategies, please indicate the credit quality ratings that the
Fund will be exposed with respect to its direct investments.

See the response to Comment #10.

 13. The staff notes the disclosure under this section stating that the Fund “may invest in shares of other investment companies
and ETFs.” Please disclose whether the Fund will be investing in affiliated funds other than the funds identified as “Underlying
Funds.” Please additionally clarify that the Underlying Funds are affiliated funds.

The Registrant intends to add the requested clarification
that the Underlying Funds are affiliated funds. As the Fund will not invest principally in affiliated funds other than the Underlying
Funds, the Registrant respectfully declines to add the requested disclosure.

    -3-

 14. The staff notes that the Fund’s 80% policy states: “Under normal circumstances, the Fund invests at least 80% of its
net assets (plus the amount of borrowings for investment purposes) directly or indirectly through the Underlying Funds, in high yield
bonds issued by U.S. companies.” Please clarify whether the Fund may invest directly in high yield bond issues by U.S. companies.

See the response to Comment #10.

 15. The staff notes that the Fund’s 20% basket states: “The Fund may also invest up to 20% of its net assets in certain
futures, options and swap contracts, U.S. Treasury obligations, U.S. Government obligations, U.S. agency securities, securities of other
registered investment companies, cash and cash equivalents.” Please confirm whether the Fund will be investing in these instruments
for purposes of its principal strategies. If not, please relocate to the SAI. See Items 4, 9 and 16. Relatedly, please avoid using terms
or phrases suggesting or indicating that the Fund is not fully describing its investment thesis, including strategies and risks (e.g.,
use of the term “certain” in the statement “. . . in certain futures, options and swap contracts . . .”).

The Registrant reserves the right to invest up to 20% of
its net assets in the instruments identified in the above-mentioned disclosure as part of its principal investment strategies. The Registrant
does not expect the Fund to invest in these instruments to the degree that they would each constitute a principal investment strategy.
The Registrant believes that the current strategies and risk disclosures in the Registration Statement are sufficient for an investor’s
consideration of the risks associated with the Fund’s principal investment strategy.

 16. The staff notes duration disclosure in “Interest Rate Risk.” If the Fund uses duration as a measurement in its investment
strategy, please explain the nature of the duration in the Fund’s investment strategy and include an example.

The Registrant respectfully notes that while duration management
is not a principal investment strategy of the Fund, it is one of the many factors that the Fund takes into consideration when evaluating
investment decisions. The Registrant believes that the current disclosure under “Interest Rate Risk” is sufficient for an
investor’s consideration of the interest rate-related risks associated with fixed-income investments.

 17. Please include a plain English definition of “sector rotation” and explain how sector rotation differs from allocation.
Please disclose any specific allocation strategy and attendant risks.

The Registrant intends to make the following changes to the
second paragraph under “Principal Investment Strategies”:

The Adviser has retained Delaware Investments Fund
Advisers, a series of Macquarie Investment Management Business Trust, a Delaware statutory trust (the “Sub-Adviser”), to provide
the Adviser with periodic asset allocation advisory services with respect to the Underlying Funds. “Sector rotation”
refers to the allocation and reallocation of Fund assets from one or more Sectors into one or more other Sectors. The Sub-Adviser
makes asset allocation recommendations among the Underlying Funds based on its fundamental investment approach that takes into consideration
the analysis of macroeconomic, financial and market data to formulate decisions regarding the recommended sector allocation(s) within
the portfolio, which may result in the allocation and reallocation of Fund assets from one or more Sectors into one or more other
Sectors.

    -4-

The Registrant believes that “Asset Allocation
Risk” adequately discloses the risks associated with implementing the Sub-Adviser’s asset allocation recommendations.

 18. The staff notes the risk factor entitled “Focused Investment Risk.” Please clarify in plain English what is meant by
“focused investment.” In general, for plain English purposes, please use the same term when referring to the same concept.

The Registrant intends to delete the above-mentioned disclosure.
See also response to Comment #27.

 19. Please note that when the Fund invests in other investment companies, the Fund and its adviser may not ignore the investments of
affiliated or unaffiliated underlying investment companies when determining whether the Fund is in compliance with its 80% policy. Please
disclose in prospectus (Item 4 or Item 9) or the SAI that the Fund will consider the investments of its underlying investment companies
when determining the Fund’s compliance with its 80% policy.

The Registrant intends to add the following disclosure to
the section entitled “Investment Policies—Non-Fundamental Investment Policies” in the SAI:

The Fund has adopted a non-fundamental investment policy
to consider the underlying investments of any underlying investment companies when determining the Fund’s compliance with its concentration
policies to the extent that such information is available to the Fund.

 20. If the Fund for purposes of its principal strategies includes derivatives in its 80% investment policy, please include such disclosure
in the Item 4 and indicate the specific types of derivatives that will comprise the 80% policy. Please indicate the purpose(s) for which
the Fund will use derivatives for its principal strategies. Please note the 80% policy pursuant to Rule 35d-1 under the 1940 Act is an
asset based test (and not an exposure test). If the Fund intends to include derivatives as part of its 80% policy, please confirm supplementally
the Fund will value these derivatives on a mark-to-market basis.

The Registrant respectfully declines to make the requested
changes. Consistent with industry practice and staff guidance, a fund may obtain the requisite exposure to comply with its 80% investment
policy either through investments directly in securities or indirectly using derivatives. While the Fund does not intend to use derivatives
to meet its 80% investment policy, it reserves the right to do so. If the Fund determines to seek to meet is 80% investment policy indirectly,
including through derivatives, the Fund will provide Item 4 risk disclosure relating to any such method of seeking to meet its 80% policy.
The Fund believes that its Item 4 risk disclosures adequately reflect its anticipated principal investment strategies and corresponding
risks.

    -5-

 21. Please disclose the applicable capitalization sizes for the Fund’s principal investments and attendant risks.

For the staff’s reference, the relevant index capitalization
for the Underlying Funds, as of May 26, 2023, is as follows:

    Underlying Fund

    Index

    Market Cap

    ($000)

    BondBloxx USD High Yield Bond Consumer Cyclicals Sector ETF
    205,070.83

    BondBloxx USD High Yield Bond Consumer Non-Cyclicals Sector ETF
    110,141.90

    BondBloxx USD High Yield Bond Industrial Sector ETF
    282,748.53

    BondBloxx USD High Yield Bond Energy Sector ETF
    146,914.07

    BondBloxx USD High Yield Bond Financial & REIT Sector ETF
    127,395.59

    BondBloxx USD High Yield Healthcare Sector ETF
    94,757.10

    BondBloxx USD High Yield Bond Telecom, Media & Technology Sector ETF
    243,210.11

The Registrant believes that the current principal strategies
and risk disclosures in the Registration Statement are sufficient for an investor’s consideration of the Fund’s principal
investment strategy of investing in high yield bonds.

 22. Please disclose that the Fund is non-diversified. The disclosure should also explain what “non-diversified” means.

The Registrant intends to add the requested disclosure.

 23. The staff notes that the prospectus mentions derivatives but there is no corresponding Item 4 and Item 9 disclosures in all instances.
Please confirm whether such investments are part of the Fund’s principal strategies and add corresponding strategy and risk disclosure
as necessary.

See responses to Comments #15 and 20.

Summary of Principal Risks

 24. “Investment in the Underlying Funds Risk”

 a. The first two sentences state: “The Fund expects to invest a substantial portion of its assets in the Underlying Funds. Accordingly,
the Fund’s investment performance is likely to be directly related to the performance of the Underlying Funds . . .” Please
update this sentence to remove the anticipatory language “expects to” and “is likely to be.”

The Registrant intends to make the requested changes.

 b. To the extent the Fund, through its investm