SecProbe.io

CORRESP
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  ROPES
                         & GRAY LLP

THREE EMBARCADERO
CENTER

SAN FRANCISCO,
CA 94111-4006

WWW.ROPESGRAY.COM

March
1, 2024

  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

Re: BondBloxx
                                            ETF Trust (the “Registrant”)

File
Nos. 333-258986 and 811-23731

Dear
Ms. Browning:

This
letter is being filed to respond to additional comments received from you on February 29, 2024 regarding the staff of the Securities
and Exchange Commission’s (the “SEC”) review of Post-Effective Amendment No. 25 to the Registrant’s registration
statement on Form N-1A (the “Registration Statement”) filed with the SEC on November 16, 2023, and the Fund’s comment
response letter dated February 27, 2024, responding to initial staff comments received on December 15, 2023 (the “Initial Letter”).
The staff’s additional 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. 37 to the Registration
Statement, which the Registrant expects to be filed on or about March 4, 2024. Capitalized terms not defined in this letter have the
meanings assigned to them in the Registration Statement, and any comment references noted herein are to the Initial Letter.

Comments

 1. Regarding
the response to Comment #2, please clarify what “comparable universe of securities” means.

The
Registrant will revise the relevant disclosure as follows:

If
the Fund should hold a municipal security that loses its tax exempt status retroactively, the Sub-Adviser will evaluate the after-tax
yield of the security relative to the broader universe of U.S. dollar-denominated, investment-grade fixed income debt instruments
securities that the Sub-Adviser follows to determine whether to continue to hold or dispose of the security.

 2. Regarding
the response to Comment #5.a.:

 a. The
                                            staff notes the new disclosure regarding negative average portfolio duration. Please explain
                                            the Fund’s strategy with respect to maintaining a negative average portfolio duration.
                                            For what purpose would the Fund employ such a strategy and what instruments would the Fund
                                            use in connection therewith?

The
Registrant will remove the above referenced disclosure.

 b. For
fair balance disclosure, please disclose the impact on duration during a period of declining or neutral interest rates and the resulting
impact to the Fund.

See
above response.

 3. Regarding
                                            the responses to Comment #5.c. and Comment #5.e., please clarify the Fund’s consideration
                                            of maturity. The response to Comment #5.e., for example, indicates that the Fund intends
                                            to remove “certain” references to maturity, but not all.

The
Registrant respectfully notes that it believes that the Fund’s disclosure serves to put shareholders on notice that the Fund
may invest in securities of any maturity. The Registrant understands that the Sub-Adviser uses any particular criteria with respect
to maturity other than maintaining the duration target of the Fund in selecting securities for the Fund.

 4. The
                                            staff notes the Registrant’s response to Comment #9.a. Please acknowledge that the
                                            staff may not be in a position to grant the Registrant acceleration should the Registrant
                                            request acceleration in the future.

The
Registrant acknowledges the staff’s comment.

 5. Regarding
                                            the response to Comment #9.b., the staff notes the parenthetical, which states “i.e.,
                                            securities backed by an underlying portfolio of loan obligations, which may include, among
                                            others, senior unsecured loans and subordinate corporate loan.” Please delete the phrase
                                            “among others.”

The
Registrant will make the requested change.

 6. Please
                                            delete terms or phrases that suggest that the Fund has not described with specificity the
                                            Fund’s principal strategies and risks.

The
Registrant respectfully notes that it believes that the Fund’s disclosure provides sufficient specificity for investors to understand
the Fund’s principal strategies and risks.

    2

 7. Regarding
                                            the responses to Comment #9.b. and #9.c., the staff notes the disclosure regarding credit
                                            quality requirements applying at the time of investment. To the extent that an investment
                                            is downgraded, would the Fund then be invested principally in junk bonds? Please indicate
                                            the lowest grade that would be applicable here and include applicable attendant risk.

The
Registrant will revise the third paragraph under “Principal Investment Strategies” as follows:

“Investment-grade”
securities are securities that at the time of purchase are rated above Baa3 by at least one nationally recognized statistical rating
organizations (“NRSRO”). In the case of a split rated security (that is, two or more NRSROs give a security different ratings),
the highest rating shall apply. The Fund may only invest in fixed income investments that have a minimum of B3 by Moody’s Investors
Services, Inc. (“Moody’s”) or B- by S&P Global Ratings(“S&P”), or the equivalent by another NRSRO
or that are unrated but considered to be of equivalent quality by the Sub-Adviser. Those bonds ratedBaa3/BBB-/BBB-, while considered
to be “investment grade,” may have speculative characteristics. Any credit quality requirements as to investments apply only
at the time of an investment to which the requirement is applicable and shall not be considered violated unless an excess or deficiency
occurs or exists immediately after and as a result of such investment. Accordingly, any later credit quality downgrade or change in circumstances
will not be considered in determining whether any investment complies with the Fund’s credit quality limitation or requirement.
Nevertheless, while the percentage of investments in investment grade securities is below 80%, the Fund will only purchase qualifying
securities and not purchase additional non-investment grade securities.

 8. Regarding
the response to Comment #10, please confirm whether the Fund will be investing in subprime mortgages for purposes of its principal investment
strategies. If the Fund will not be investing subprime mortgages for purposes of its principal investment strategies, please move this
disclosure to the SAI.

The
Fund will not invest in subprime mortgages for purposes of its principal investment strategies and will remove such references from the
Prospectus.

 9. Regarding
                                            the response to Comment #10.c.:

 a. The
staff notes the proposed Item 4 disclosure. Please revise this disclosure to summarize the risks related to the specific CLO instruments
that the Fund will invest as part of its principal strategies.

 b. The
staff notes the proposed Item 9 disclosure. Please ensure that Item 9 is not repetitive with Item 4 and similarly revise the disclosure
to summarize the risks related to the specific CLO instruments that the Fund will invest as part of its principal strategies.

 c. The
staff notes the reference to “spread compression.” Please include a plain English explanation of this term.

 d. The
staff notes the reference to “phantom taxable income.” Please include a plain English explanation of this term.

 e. The
staff notes the fourth paragraph under the proposed Item 9 disclosure. Please explain in plain English what is meant by “financial
covenants.” Please clarify whether the Fund will only invest in CLOs with financial covenants or will also invest in CLOs without
financial covenants. Please ensure that applicable attendant risks are disclosed.

    3

In
light of the staff’s additional comments noted above, the Registrant will replace the proposed Item 4 and Item 9 disclosures with
the following:

Item
4:

CLO
Risk. The risks of investing in CLOs include both the economic risks of the underlying loans combined with the risks associated with
the CLO structure governing the priority of payments. The degree of such risk will generally correspond to the specific tranche in which
the Fund is invested. The Fund intends to invest primarily in the rated debt tranches of CLOs; however, any such ratings do not constitute
a guarantee, may be downgraded, and in stressed market environments it is possible that even senior CLO tranches could experience losses
due to actual defaults, increased sensitivity to defaults due to collateral default and the disappearance of the subordinated/equity
tranches, market anticipation of defaults, as well as negative market sentiment with respect to CLO securities as an asset class. The
Sub-Adviser may not be able to accurately predict how specific CLOs or the portfolio of underlying loans for such CLOs will react to
changes or stresses in the market, including changes in interest rates. The most common risks associated with investing in CLOs are liquidity
risk, interest rate risk, credit risk, prepayment risk, and the risk of default of the underlying asset, among others.

Item
9:

A
CLO is a type of asset-backed security that is typically structured as a trust collateralized by a pool of loans. The cash flows from
the trust are split into two or more portions, called tranches, varying in risk and yield. The risks of an investment in a CLO depend
largely on the type of the collateral securities and the class of the instrument in which the Fund invests. The Fund intends to invest
primarily in the rated debt tranches of CLOs. In addition to the general risks associated with debt securities discussed herein, CLOs
carry additional risks, including, but not limited to (i) the possibility that distributions from collateral securities will not be adequate
to make interest or other payments; (ii) the quality of the collateral may decline in value or default; (iii) the possibility that the
investments in CLOs are subordinate to other classes or tranches thereof; (iv) the potential of spread compression in the underlying
loans of the CLOs, which could reduce credit enhancement in the CLOs; and (v) the complex structure of the security may not be fully
understood at the time of investment and may produce disputes with the issuer or unexpected investment results.

Between
the closing date and the effective date of a CLO, the CLO collateral manager will generally expect to purchase additional collateral
obligations for the CLO. During this period, the price and availability of these collateral obligations may be adversely affected by
a number of market factors, including price volatility and availability of investments suitable for the CLO, which could hamper the ability
of the collateral manager to acquire a portfolio of collateral obligations that will satisfy specified concentration limitations and
allow the CLO to reach the initial par amount of collateral prior to the effective date. An inability or delay in reaching the target
initial par amount of collateral may adversely affect the timing and amount of interest or principal payments received by the holders
of the CLO debt securities and distributions of the CLO on equity securities and could result in early redemptions which may cause CLO
debt and equity investors to receive less than the face value of their investment.

The
Fund’s CLO investments are exposed to leveraged credit risk. If certain minimum collateral value ratios and/or interest coverage
ratios are not met by a CLO, primarily due to senior secured loan defaults, then cash flow that otherwise would have been available to
pay distributions to the Fund on its CLO investments may instead be used to redeem any senior notes or to purchase additional senior
secured loans, until the ratios again exceed the minimum required levels or any senior notes are repaid in full.

    4

 10. Please
reconcile the responses to Comments #19 and #21. The staff reissues Comment #21. If non-principal risks are included in the prospectus,
please identify them as such or move them to the SAI.

The
Registrant will remove the “Swaps Risk” disclosure in response to the staff’s comment.

 11. Regarding
                                            the response to Comment #22, please ensure that the disclosure includes a clear recitation
                                            of what diversification means under the 1940 Act.

The
Registrant confirms that the disclosure will provide a description of what diversification means under the 1940 Act.

 12. The
                                            staff reissues Comment #23. See Dear Registrant Letter dated Jan. 3, 1991 (the “1991
                                            Letter”).

The
Registrant respectfully declines to make the requested clarification, as it believes the Fund’s current SAI disclosure is consistent
with the requirements of Section 8(b)(1)(E) of the 1940 Act and Item 16 of Form N-1A, which refer to describing policies regarding “concentrating
investments in a particular industry or group of industries.” (emphasis added) The Registrant notes that the 1991
Letter was rescinded on June 1, 1998, in connection with the effective date of the 1998 amendments to Form N-1A. See Registration Form
Used by Open-End Management Investment Companies, SEC Release No. IC-23064 (Mar. 13, 1998) (the “1998 Amendments”). In the
1998 Amendments, the SEC specifically stated that:

Form
N-1A, as amended, incorporates certain disclosure requirements from the [Guidelines to current Form N-1A (the “Guides”)]
and [Generic Comment Letters prepared by the Division of Investment Management (“GCLs”)]. Other disclosure requirements in
the Guides and the GCLs have not been incorporated in Form N-1A because, among other things, they are outdated or result in disclosure
about technical, legal, and operational matters generally common to all funds…. Form N-1A, as amended, includes all of the requirements
necessary for funds to prepare new or amend existing registration statements.

The
1998 Amendments did not incorporate into Form N-1A the interpretation from the 1991 Letter on foreign governments being subject to a
fund’s concentration policy, and therefore that disclosure comment has been rescinded. Nonetheless, the Registrant confirms that
the Fund does not currently intend to invest 25% or more of its net assets in sovereign debt of any single foreign country.

    5

 13. The
                                            staff reissues Comment #24. Please add clarification consistent with Section 18(f)(1) of
                                            the 1940 Act.

The
Registrant will revise the disclosure on page 34 of the SAI as follows:

With
respect to the fundamental policy relating to borrowing money set forth in (2) above, the 1940 Act permits the Fund to borrow money in
amounts of up to one-third of the Fund’s total assets from banks for any purpose, and to borrow up to 5% of the Fund’s total
assets from banks or other lenders for temporary purposes. (The Fund’s total assets include the amounts being borrowed.) To limit
the risks attendant to borrowing, the 1940 Act r