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SEC Company Response from Tidal Trust II (CIK 0001924868) — Dec 22, 2025

Tidal Trust II (CIK 0001924868)
Date: Dec. 22, 2025 · CIK: 0001924868 · Accession: 0001999371-25-020959

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File numbers found in text: 333-264478, 811-23793

Date
December 22, 2025
Author
/s/ John Hadermayer
Form
CORRESP
Company
Tidal Trust II (CIK 0001924868)

Letter

VIA EDGAR TRANSMISSION Division of Investment Management, Disclosure Review Office Washington, D.C. 20549 Re: Tidal Trust II (the “Trust”) Post-Effective Amendment No. 453 to the Trust’s Registration Statement on Form N-1A (the “Amendment”); File Nos. 811-23793; 333-264478

Dear Ms. Goody:

This correspondence responds to comments the Trust received from the staff of the U.S. Securities and Exchange Commission (the “Staff” or “Commission”) on December 8, 2025, with respect to Defiance Daily Target 2X Long WLTH 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.

1. Please confirm supplementally that the effective date of the Fund’s registration will be delayed until the IPO of the Fund’s underlying asset (WLTH) is complete.

Response: The Trust responds supplementally by confirming that the Fund’s registration will not become effective until the IPO of the Fund’s underlying asset (WLTH) is complete.

If you have any questions or require further information, please contact John Hadermayer at (262) 318-8236 or jhadermayer@tidalfg.com.

Sincerely,
/s/ John Hadermayer

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CORRESP
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Tidal Trust II

234 West Florida Street, Suite 203

Milwaukee, Wisconsin 53204

December 22, 2025

VIA EDGAR TRANSMISSION

Ms. Elizabeth Goody

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

                                            File Nos. 811-23793; 333-264478

Dear Ms. Goody:

This correspondence responds to comments the Trust
received from the staff of the U.S. Securities and Exchange Commission (the “Staff” or “Commission”) on December
8, 2025, with respect to Defiance Daily Target 2X Long WLTH 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.

 1. Please confirm supplementally that the effective date of the Fund’s registration will be delayed
until the IPO of the Fund’s underlying asset (WLTH) is complete.

Response: The Trust responds
supplementally by confirming that the Fund’s registration will not become effective until the IPO of the Fund’s underlying
asset (WLTH) is complete.

If you have any questions or require further information,
please contact John Hadermayer at (262) 318-8236 or jhadermayer@tidalfg.com.

Sincerely,

  /s/ John Hadermayer

John Hadermayer

SVP of Legal Services

Tidal Investments LLC, on behalf of Tidal Trust II