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CORRESP
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Tidal
Trust II

234
West Florida Street, Suite 203

Milwaukee,
Wisconsin 53204

June
20, 2023

VIA
EDGAR TRANSMISSION

Ms.
Karen Rossotto

Division
of Investment Management, Disclosure Review Office

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

  Re:
  Tidal Trust II (the “Trust”)

  Post-Effective Amendment No. 75 to the Trust’s Registration Statement on Form N-1A (the “Amendment”)

  File Nos. 811-23793; 333-264478

Dear
Ms. Rossotto:

This
correspondence responds to comments the Trust received from the staff of the U.S. Securities and Exchange Commission (the “Staff”
or the “Commission”) on June 8, 2023, with respect to the Amendment and the Trust’s proposed new series, the Blueprint
Chesapeake Multi-Asset Trend ETF (the “Fund”).

For
your convenience, the comments have been reproduced with responses following each comment. Capitalized terms not otherwise defined have
the same meaning as in the Amendment.

FEES
AND EXPENSES

1. Please
                                            supplementally provide the Staff with a Fee Table pre-effectively. In addition, please tell
                                            us in correspondence how the Trust estimated Other Expenses and determined it was a reasonable
                                            estimate of the expenses for the current fiscal year. Please also confirm that Other Expenses
                                            include short sale expenses.

Response:
The Fund’s completed Fees and Expenses table and Expense Example are as shown in the attached Appendix A. The Trust further responds
by confirming that Other Expenses include short sale expenses. They were estimated based on a review of sample portfolio holdings for
the Fund. The Trust believes that the estimated Other Expenses for the Fund’s initial fiscal year are reasonable given the Fund’s
expected portfolio holdings.

PRINCIPAL
INVESTMENT STRATEGIES

2. The
                                            Fund’s investment strategy is unclear to the Staff. Please rewrite the Fund’s
                                            principal investment strategies with a focus on using plain English principles (see Form
                                            N-1A, General Instruction 4(c) and Item 4).

Responses:
The Fund’s investment strategies have been rewritten using plain English principles.

3. The
                                            Fund is shown as a non-diversified fund. Please remove references to the term “diversified”
                                            in the investment strategy. Also, please state expressly in the Item 4 summary that the Fund
                                            is non-diversified.

Response:
The Prospectus has been revised accordingly.

4. Please
                                            add an explanation to the Item 9 disclosure explaining how the Fund’s strategies work
                                            together to meet the Fund’s stated objective.

Response:
The Prospectus has been revised accordingly.

5. Explain
                                            the Fund’s derivatives strategy using plain English principles.

Response:
The Prospectus has been revised accordingly.

6. If
                                            the Sub-Adviser’s investment process involves quantitative analysis, disclose that,
                                            as well as the types of data it uses in its analysis.

Response:
The Prospectus has been revised to include the foregoing disclosures.

7. Please
                                            revise the Item 4 disclosure to explain how the Fund makes investment decisions.

Response:
The Prospectus has been revised to include the foregoing disclosures.

8. Please
                                            revise the Fund’s intention with respect to cryptocurrencies. Please clarify how the
                                            Fund’s limit in cryptocurrencies is measured (e.g., on a notional basis?).

Response:
The Prospectus has been revised to reflect the foregoing.

9. Please
                                            add an explanation about what long and short positions are.

Response:
The Prospectus has been revised to include the foregoing disclosures.

10. With
                                            respect to cryptocurrency risk disclosure,

 a. Please
                                            consider shortening the disclosure to more appropriately reflect the Fund’s limited
                                            investment.

 b. The
                                            disclosure notes that “the Fund may have market exposure to cryptocurrencies. . .”
                                            Please state specifically how the Fund will have market exposure to cryptocurrencies.

 c. Please
                                            clarify the statement that “An investment in companies with exposure to cryptocurrency
                                            and active engagement in its associated technology. . .”

 d. Please
                                            clarify the reference to “cryptocurrency products.”

 e. Please
                                            clarify the phrase “even when held indirectly.”

 f. Please
                                            clarify the statement “Holding a privately offered investment vehicle in its portfolio
                                            may cause the Fund to trade at a premium or discount to NAV.”

Responses:

a. The
                                            risk disclosure has been shortened to more appropriately reflect the Fund’s limited
                                            investment in cryptocurrency-related investments.

b. The
                                            Prospectus has been revised accordingly.

c. As
                                            part of the shortening of the risk disclosure, the referenced phrase was removed.

d. As
                                            part of the shortening of the risk disclosure, the referenced phrase was removed.

e. As
                                            part of the shortening of the risk disclosure, the referenced phrase was removed.

f. As
                                            part of the shortening of the risk disclosure, the referenced phrase was removed.

11. For
                                            ETF Risks, please add disclosure noting that an active trading market for shares of the
                                            Fund may not develop or be maintained.

Response:
The Prospectus has been revised to include the foregoing disclosure.

12. Please
                                            tell us correspondence, whether you have engaged in market makers and APs to understand the
                                            feasibility of the arbitrage mechanism for an ETF investing substantially in derivatives.
                                            Please describe the extent of that engagement and its outcome.

Response:
The Fund’s adviser, Toroso, has had multiple discussions with Jane Street (and their associated APs), and they have agreed to act
in the capacity of AP for the Fund. In addition, both Toroso’s trading team and Jane Street have analyzed the Fund’s portfolio
for liquidity and tradability, and don’t have any concerns. In addition, the derivatives that are being contemplated for the Fund’s
portfolio are all listed, which means there is price transparency for the capital markets participants and, in turn, a feasible arbitrage
mechanism.

13. Briefly
                                            tell us in correspondence how the Fund intends to comply with Rule 18f-4 and tell us more
                                            about the derivatives, particularly the futures, the Fund will invest in -- including their
                                            liquidity profile and trading histories.

In
your response, describe the Fund’s plans for coming into compliance with Rule 18f-4 under the 1940 Act, including a preliminary
overview of the key elements of the expected derivatives risk management program and anticipated use of a relative (including an anticipated
designated index) or absolute Value-at-Risk (“VaR”) test. If the Fund will be using a relative VaR test please describe the
reference index. The Staff notes Release No. IC-34084, “Use of Derivatives by Registered Investment Companies and Business Development
Companies.”

Please
also provide us with a capacity analysis for the Fund, which may include qualitative data as appropriate and information regarding the
trading experience of other vehicles providing exposure to the futures the Fund invests in. Further, please make sure your response to
our liquidity questions analyze the liquidity of the specific instruments in which the fund seeks to invest.

Response:
The Fund’s portfolio transactions will be conducted pursuant to the Trust’s written derivatives risk management program (the
“Program”), as approved by the Trust’s Board of Trustees (the “Board”), which includes policies and procedures
that are reasonably designed to manage the risks of each Fund’s usage of derivatives, as required by Rule 18f-4. The Program is
administered and overseen by a derivatives risk manager that has been designated by the Board. Pursuant to the requirements of the Program,
the derivatives risk manager has identified and provided an assessment of the Fund’s derivatives usage and risks as they pertain
to the Fund’s usage of swaps, and any other derivatives, as applicable. The Program provides risk guidelines that, among other
things, consider and provide for (1) limits on the Fund's derivatives exposure; (2) monitoring and assessment of the Fund's exposure
to illiquid investments (if any); (3) monitoring and assessment of the credit quality of the Fund's counterparties; and (4) monitoring
of margin requirements, position limits and position accountability levels. Additionally, the Program provides for stress testing, back-testing,
internal reporting and escalation, and periodic review in compliance with Rule 18f-4. Data relating to such functions will be made available
by a third-party service provider engaged by the Fund, for analysis and monitoring by the Fund’s derivatives risk manager.

The
Fund’s portfolio is constructed using a 50% allocation to each of a trend-following basket of fixed income, currency and commodity
futures (similar to a CTA), and a basket of long/short equities in both security and futures format. Because of the unique construction
of this portfolio, which targets absolute returns not analogous to similar tradable indices, Toroso will be using the absolute VaR test.
Toroso believes an absolute benchmark (i.e., 20%) will provide an appropriate measure against which to gauge the VaR of the Fund’s
aggregate portfolio.

For
a capacity analysis, Toroso notes that the Fund will hold a well-diversified futures portfolio with currency, commodity, and index futures.
The average number of contracts needed if the Fund grew to one billion dollars in assets would be only ninety-four contracts. In Toroso’s
opinion, that number of futures contracts would be considered easy to obtain. Toroso notes that the total volume of futures contracts
traded in 2022 was approximately fifty-three thousand contracts.

As
noted above, both Toroso’s trading team and Jane Street have analyzed the Fund’s portfolio for liquidity and tradability,
and don’t have any concerns. The futures portion of the Fund’s strategy is much like other commodities trading strategies
already available in the ETF market, some of which have recently scaled close to a billion dollars. In addition, the Fund’s sub-adviser
has managed over $200 million in assets using strategy has without issue. Further, the nature of the Fund’s trend following strategy
means that the methodology can be applied to almost any futures contract successfully. The Fund’s strategy will initially consider
roughly 175 different securities (95 futures), which obviously also helps capacity and liquidity.

14. With
                                            respect to the Subsidiary, please:

i. Disclose
                                            that the Fund complies with the provisions of the Investment Company Act governing investment
                                            policies (Section 8) on an aggregate basis with the Subsidiary.

ii. Disclose
                                            that the Fund complies with the provisions of the Investment Company Act governing capital
                                            structure and leverage (Section 18) on an aggregate basis with the Subsidiary so that the
                                            fund treats the Subsidiary’s debt as its own for purposes of Section 18.

iii. Disclose
                                            that the Adviser complies Section 15 with respect to the Subsidiary.  Please note, any
                                            investment advisory agreement between the Subsidiary and its investment adviser is a material
                                            contract that should be included as an exhibit to the registration statement.  As the
                                            Adviser is the investment adviser to both the fund and the Subsidiary, for purposes of complying
                                            with Section 15(c), the reviews of the Fund’s and the Subsidiary’s investment
                                            advisory agreements may be combined.

iv. Disclose
                                            the Subsidiary complies with provisions relating to affiliated transactions and custody (Section
                                            17). Identify the custodian of the Subsidiary, if any.

v. Disclose
                                            any of the Subsidiary’s principal investment strategies or principal risks that constitute
                                            principal investment strategies or risks of the Fund. The principal investment strategies
                                            and principal risk disclosures of the Fund should reflect the aggregate operations of the
                                            Fund and the Subsidiary.

vi. Confirm
                                            in correspondence that the Subsidiary and its board of directors will agree to inspection
                                            by the staff of the Subsidiary’s books and records, which will be maintained in accordance
                                            with Section 31 of the Investment Company Act and the rules thereunder.

vii. Confirm
                                            the Subsidiary and its board of directors will agree to designate an agent for service of
                                            process in the United States.

viii. Confirm
                                            the Subsidiary’s management fee (including any performance fee), if any, will be included
                                            in “Management Fees,” and the Subsidiary’s expenses will be included in
                                            “Other Expenses” in the fund’s fee table.

ix. Disclose
                                            the Fund does not intend to create or acquire primary control of any entity which primarily
                                            engages in investment activities in securities or other assets, other than entities wholly-owned
                                            or majority-owned by the Fund.

Response:

i. The
                                            Trust confirms that Prospectus has been revised to include the disclosure.

ii. The