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Tidal Trust II

234 West Florida Street, Suite 203

Milwaukee, Wisconsin 53204

December 18, 2024

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. 268 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 December 3, 2024, with respect to changes to the registration statement of, inter alia, Defiance Daily Target 2X Long RIOT ETF (formerly
known as the Defiance Daily Target 2X Long Carbon ETF) and Defiance Daily Target 2X Long China Dragons ETF (formerly known as Defiance
Daily Target 2X Long Lithium ETF) (each, a “Fund,” and together, the ‘Funds”). 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 Registration
Statement.

In addition, the Trust notes that it has
determined to make modest revisions to each Fund’s (as well as the Other Funds as defined below) principal investment strategies
to reflect that rather than the original primary reliance on swaps with a secondary reliance on options, the portfolio management team
may rely on the type of derivative instrument most appropriate at the time of the investment. Such revisions have been provided to
the Staff under separate cover.

 1. The Staff notes that you are replacing KRBN with RIOT and LIT with DRAG
as each Fund’s respective underlying security post effectively, and in recent months launched multiple single ETF Funds with similar
strategies. In correspondence, please tell us about the business and legal reasons for replacing KRBN with RIOT and LIT with DRAG, respectively,
and how you generally determine which products to launch or shutter.

    Response: The Trust responds by confirming supplementally that decisions
                              to launch or shutter products are based on several factors, including alignment with the overall product
                              line, and expected financial performance and market demand. Currently, the Adviser has determined that
                              each of RIOT and DRAG demonstrates stronger performance potential and investor interest as compared to
                              KRBN and LIT, respectively.

 2. With respect to the Funds’ initial registration, the Trust filed
a response letter dated May 15, 2024 (“Letter”) which also applies to three other Trust series in the Amendment (“Other
Funds”). The Staff acknowledges the responses, representations and additional information provided by the Trust in the Letter with
respect to the Other Funds. With respect to the Funds, please provide the Staff with the responses, representations or additional information
requested by items 2, 3, 6, 7, 11, and 12 of the Letter. To the extent a response in the Letter is identical to your response to this
series, please confirm in this response or otherwise highlight key areas where your responses differ with respect to this series.

    Response: The Trust responds by confirming supplementally that,
                              except for the exception noted below, each referenced response in the Letter is identical to the response
                              for the Funds. In addition, each Fund will provide under separate cover for the Staff’s review prior
                              to the effective date of the Registration Statement a hypothetical example of VaR testing based on the
                              Fund’s anticipated current portfolio construction and will include the index the Fund intends to
                              use and how such index meets the definition of designated reference portfolio.

    The Trust notes that the response to
comment 7 of the Letter is adjusted slightly with respect to the Funds to state that the Trust is currently in negotiations with four
swap counterparties rather than seven. Otherwise, the response is identical for the Funds.

 3. In correspondence, please advise whether prior to this Amendment the
Funds accepted investments, issued shares or commenced operations. If so, describe any steps taken to mitigate impacts to existing shareholders
by the change in exposure to a different underlying security.

    Response: The Trust responds by confirming supplementally that as
                              of the date hereof, neither Fund has accepted investments, issued shares or commenced operations.

 4. Please note that Staff believes that changing a Fund’s underlying security should be effected
via a 75-day filing, and not a 60-day filing.

    Response: The Trust acknowledges the Staff’s view, and has agreed to delay the effective
                              date of the Amendment through at least December 30, 2024 (the same date that the Amendment would have been
                              effective had it been filed as a 75 day filing).

If you have any questions or require further
information, please contact Michael Pellegrino at (262) 318-8442 or mpellegrino@tidalfg.com.

  /s/ Michael Pellegrino

  Michael Pellegrino

General Counsel

  Tidal Investments LLC