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CORRESP
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Tidal
Trust II

234
West Florida Street, Suite 203

Milwaukee,
Wisconsin 53204

March
14, 2025

VIA
EDGAR TRANSMISSION

Mr.
Raymond Be

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. 297 to the Trust’s Registration Statement on Form N-1A (the “Amendment”)

File
Nos. 811-23793; 333-264478

Dear
Mr. Be:

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 February 11, 2025, with respect to Defiance Leveraged Long MSTR ETF and Defiance Leveraged Long +
Income MSTR 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.

Prospectus

 1. Please
                                            supplementally provide the Staff with a completed Fee Table for each Fund pre-effectively
                                            and describe how Other Expenses were reasonably estimated for the current fiscal year.

Response:
Each Fund’s completed Fees and Expenses table and Expense Example, which are identical for each Fund, are as shown in the attached
Appendix A. In addition, the Trust responds supplementally by confirming that “Other Expenses” were estimated based on reasonably
anticipated expenses to be incurred by each Fund during its initial fiscal period.

 2. With
                                            respect to each Fund’s Principal Investment Strategies section, the Staff notes the
                                            disclosure, “Although the Fund’s leverage will vary, its base, target leverage
                                            level will be approximately 200%.” Please briefly explain how the leverage level will
                                            be calculated and how it differs from “2X daily.” For example, should investors
                                            expect a 200% return in one day, or a different period of time?

Response:
 The Trust respectfully notes that the Prospectus states that: “At the end of each trading day, the Fund’s swaps and
options are marked to market (valued based on current market prices), and the Fund’s investment adviser rebalances the portfolio
to maintain leveraged exposure of approximately 150% to 200% of the Underlying Security’s share price.” Nonetheless, the
Trust has added additional clarifying disclosures indicating that the Fund’s leverage level ranges are daily.

 3. With
                                            respect to each Fund’s Principal Investment Strategies, the Staff notes the disclosure,
                                            “Swap agreements may be entered into with financial institutions for periods ranging
                                            from one day to over a year.” Please clarify the implications of that statement. For
                                            example, will the Swap Agreements require the exchange of returns daily for a year, or just
                                            once at the end of the year?

Response:
Revisions have been made to the Fund’s Principal Investment Risks disclosure to address this comment and provided to the Staff
under separate cover.

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 4. The
                                            Staff notes that although the Funds don’t seek 2X returns daily, they appear to rebalance
                                            daily and seek leveraged returns. Please discuss the risks of compounding due to leverage,
                                            or explain supplementally why this is not a principal risk of the Funds.

Response:
The Trust has supplemented the Funds’ principal risk disclosures with compounding and market volatility risk disclosures.

 5. In
                                            the Principal Investment Strategies section, please enhance and contextualize the disclosure
                                            by providing an explanation of blockchain technology and crypto assets, including the following
                                            with respect to public, permissionless, blockchains:

 ● their
                                            general design and purpose;

 ● how
                                            they are developed, maintained and governed;

 ● how
                                            public, permissionless blockchains are accessed and used;

 ● the
                                            relationship of blockchains to their native crypto assets; and

 ● specific
                                            use cases and applications they support or are designed to support.

Response:
Revisions have been made to the Fund’s Principal Investment Strategies disclosure in Item 9 of Form N-1A to address this comment
and provided to the Staff under separate cover.

 6. In
                                            the Principal Investment Risks section, please discuss the unique risks and challenges associated
                                            with blockchain technology, including the following:

 ● risks
                                            related to the integrity and viability of the consensus mechanism of the blockchain;

 ● the
                                            blockchains capacity to execute and settle transactions in a timely and predictable manner;
                                            and

 ● the
                                            development, maintenance and governance of the blockchain, which is generally open-source
                                            and thus vulnerable to being “forked” by users and miners/validators.

Response:
Revisions have been made to the Fund’s Principal Investment Risks disclosure in Item 9 of Form N-1A to address this comment and
provided to the Staff under separate cover.

If
you have any questions or require further information, please contact Daniel Bulger at (262) 382-3522 or dbulger@tidalfg.com.

Sincerely,

/s/
Daniel Bulger

Daniel
Bulger

VP
of Legal Services

Tidal
Investments LLC

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APPENDIX
A

DEFIANCE
LEVERAGED LONG MSTR ETF

DEFIANCE
LEVERAGED LONG + INCOME MSTR ETF

Fees
and Expenses of the Fund

This
table describes the fees and expenses that you may pay if you buy, hold, and sell shares of the Fund (“Shares”). You may
pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the table and Example
below.

    Annual
    Fund Operating Expenses(1) (expenses that you pay each year as a percentage of the value of your investment)

    Management
    Fees

    1.29%

    Distribution
    and Service (12b-1) Fees

    0.00%

    Other
    Expenses(2)

    0.00%

    Total Annual Fund Operating
    Expenses

    1.29%

    (1)
    The Fund’s
    investment adviser, Tidal Investments LLC (the “Adviser”), will pay, or require a sub-adviser to pay, all of the Fund’s
    expenses incurred by the Fund (except for advisory fees and sub-advisory fees, as the case may be) excluding interest charges on
    any borrowings, dividends and other expenses on securities sold short, taxes, brokerage commissions and other expenses incurred in
    placing orders for the purchase and sale of securities and other investment instruments, acquired fund fees and expenses, accrued
    deferred tax liability, distribution fees and expenses paid by the Fund under any distribution plan adopted pursuant to Rule 12b-1
    under the Investment Company Act of 1940, as amended (the”1940 Act”), and litigation expenses, and other non-routine
    or extraordinary expenses.

    (2)
    Based on estimated amounts for the
    current fiscal year.

Expense
Example

This
Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other funds. The Example assumes
that you invest $10,000 in the Fund for the time periods indicated and then hold or redeem all of your Shares at the end of those periods.
The Example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain the same.
The Example does not take into account brokerage commissions that you may pay on your purchases and sales of Shares. Although your actual
costs may be higher or lower, based on these assumptions your costs would be:

    1
    Year
    3
    Years

    $133
    $415

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