SecProbe.io

CORRESP
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June 25, 2024

Mr.
Ray Be

Division
of Investment Management, Disclosure Review Office

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

 Re: Elevation
Series Trust; File Nos. 333-265972, 811-23812

Dear
Mr. Be:

On
April 4, 2024, Elevation Series Trust (the “Trust” or “Registrant”) filed an amendment to its Registration Statement
under Form N-1A pursuant to the Securities Act of 1933 and the Investment Company Act of 1940 on behalf of TrueShares Quarterly Bear
Hedge ETF and TrueShares Quarterly Bull Hedge ETF (each a “Fund” and collectively, the “Funds”).

The
Trust has revised the disclosures in the Fund’s prospectus, statement of additional information, and Part C in response to comments
given by you via telephone to Daniel Moler on May 28, 2024. Those comments are summarized below, with corresponding responses following
each comment, which the Registrant has authorized Thompson Hine LLP to make on its behalf. Capitalized terms used but not otherwise defined
herein have the meanings ascribed to them in the document to which the applicable comment relates.

 Comment
                            1. In
an appropriate place in prospectus, please clarify what “substantial protection of principal” means and what aspects of the
strategy are designed to achieve that.

 Response. The
                                            Registrant has added the following disclosure in the Principal Investment Strategy of TrueShares
                                            Quarterly Bull Hedge ETF:

Substantial
Protection of Principal

The
income component of the Fund’s portfolio is expected to represent at least 98% of its assets on a quarter-to-quarter basis, which
the adviser believes will fulfil the “substantial protection of principal” aspect of the Fund’s investment objective.
For example, even if a 2% call options component of the Fund’s portfolio expired worthless, the Fund would still have at least
98% of its value preserved by the high-quality short-term fixed income debt securities portfolio. Actual value preserved is expected
to be somewhat higher than 98% because interest earned is expected to be higher than Fund expenses. The adviser believes that protection
of at least 98% of principal on a quarter-to-quarter basis, even in adverse low- rate environments, would be considered substantial protection
by most investors.

June
25, 2024

Page
2

The
Registrant has added the following disclosure in the Principal Investment Strategy of TrueShares Quarterly Bear Hedge ETF:

Substantial
Protection of Principal

The
income component of the Fund’s portfolio is expected to represent at least 98% of its assets on a quarter-to-quarter basis, which
the adviser believes will fulfil the “substantial protection of principal” aspect of the Fund’s investment objective.
For example, even if a 2% put options component of the Fund’s portfolio expired worthless, the Fund would still have at least 98%
of its value preserved by the high-quality short-term fixed income debt securities portfolio. Actual value preserved is expected to be
somewhat higher than 98% because interest earned is expected to be higher than Fund expenses. The adviser believes that protection of
at least 98% of principal on a quarter-to-quarter basis, even in adverse low-rate environments, would be considered substantial protection
by most investors.

 Comment
                            2. Given
the expected 0% for Other Expenses, explain in more detail in the footnote what is and is not paid for by the adviser under the management
agreement.

 Response. The
                                            Registrant has added the following as a footnote to the fee tables:

The
Fund’s adviser has agreed to pay substantially all expenses of the Fund out of its unitary management fee, including the cost of
transfer agency, custody, fund administration, securities lending and other non-distribution related services necessary for the Fund
to operate, except for: the fee paid to the Fund’s adviser pursuant to the Investment Advisory Agreement, interest charges on any
borrowings, dividends and other expenses on securities sold short, taxes and related services, 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, extraordinary expenses, and distribution (12b-1) fees and expenses.

Principal
Investment Strategies

 Comment
                            3. The
first sentence states that the Fund “aims to provide the benefits of equity exposure while mitigating the risk posed by a decline
in U.S. equity markets.” Does the risk mitigation have a cost associated with it in terms of limiting the Fund's upside exposure
to equity markets? If so, disclose clearly and prominently.

 Response. The
                                            Registrant has revised the sentence to clarify that the Fund “aims to provide the benefits
                                            of partial
                                            equity
                                            exposure…” Additionally, the Registrant has revised the disclosure under “Active
                                            Management Risk” as follows:

Active
Management Risk. The adviser’s judgments about an investment may prove to be incorrect or fail to have the intended results,
which could adversely impact the Fund’s performance. The adviser’s tail risk strategy may not fully protect the Fund from
declines in the market and will may not allow the Fund
to fully participate in market upside. When the adviser selects out-of-the money call options, the Fund will
not participate in equity market gains until they exceed the strike price of the call option. Lower interest rates or higher call option
prices will tend to increase the cost of mitigating the risk posed by a decline in U.S. large capitalization equity markets.

June
25, 2024

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3

 Comment
                            4. Please
revise the last sentence of the first paragraph to clarify how the strategy is designed to lead to capital appreciation as stated in
the Fund's investment objective.

 Response. The
                                            Registrant has replaced “capital appreciation” in each Fund’s objective
                                            with “total return” and made corresponding changes throughout the prospectuses
                                            to align with the revised objectives.

 Comment
                            5. The
sentences in the second paragraph under “Income Component” explaining how the income component will work are particularly
dense. Please clarify in plain English. Consider using diagrams, examples, etc. to explain how the strategy will be implemented.

 Response. Under
                                            the Income Component for each Fund, the Registrant has made clarifying revisions to the disclosure
                                            and added an example and diagram.

 Comment
                            6. The
first paragraph under “Income Component” references a box spread. Please briefly explain what an option box spread strategy
is.

 Response. The
                                            Registrant has added the following explanation of a box spread:

A
box spread is a four-part, same expiration date, option portfolio with a maturity payout that does not vary and is considered a form
of synthetic money market instrument. For example, the four parts of a box spread could be composed of (i) a long $5 in-the-money call
option position paired with (ii) a written $5 out-of-the-money call option position; and (iii) a long $5 in-the-money put option position
paired with (iv) a written $5 out-of-the-money put option position. At expiration of the options, no matter what the price of the underlying
reference asset is, the payout to the Fund will be $10. If the Fund can construct this portfolio for less than $10 it will be profitable
at expiration.

 Comment
                            7. Please
revise the “Call Options Component” subsection to address the sizing of call options positions relative to the Fund's size.
Address how sizing relates to the degree of upside participation in rising markets.

 Response. The
                                            Registrant has revised the following disclosure to address how sizing relates to the degree
                                            of upside participation in rising markets:

TrueShares
Quarterly Bull Hedge ETF

June
25, 2024

Page
4

The
partial amount of equity upside the Fund captures is dictated by the adviser’s strategy of targeting
investments in call options to an amount approximately equal to the amount of income generated by the Fund’s portfolio. Using
this strategy, based on recent market conditions, the adviser anticipates that the Fund will capture 20% to 40% of U.S. large capitalization
equity market gains on a quarter-to-quarter basis.

TrueShares
Quarterly Bear Hedge ETF

In
such an instance, employing the put option strategy may generate a positive return. Because
puts increase in value when the reference asset declines, the Fund benefits from a market decline. Using this strategy, based on recent
market conditions, the adviser anticipates that the Fund could reap a positive benefit equal to 20% to 40% of U.S. large capitalization
equity market declines on a quarter-to-quarter basis.

The
Registrant has given the Staff’s request thoughtful consideration. The Registrant respectfully declines to include disclosure addressing
the sizing of call options positions relative to the Fund's size. There is a virtually unlimited number of possibilities in terms of
notional sizing, and the Registrant believes that any attempt to provide notional sizing guidance would be potentially misleading to
investors.

 Comment
                            8. In
the “Call Options Component” subsection, please disclose in more detail the types of data and analysis the Fund will use
to determine which call options it will purchase.

 Response. The
                                            Registrant has revised the subsection to clarify that the adviser evaluates the relative
                                            prices of at-the-money and out-of-the money options and selects those with the highest expected
                                            return in light of then-recent U.S. large capitalization equity market volatility.

 Comment
                            9. In
the “Call Options Component” subsection, please explain more clearly how a call option spread operates and how the Fund will
use the strategy to position its investments.

 Response. After
                                            further consideration and review, the Registrant has determined that call spreads will not
                                            be part of the Fund’s principal investment strategy and has revised the prospectus
                                            accordingly.

 Comment
                            10. The
last sentence of the “Call Options Component”
subsection states that “[t]he amount of equity upside the Fund captures is dictated by the adviser’s
strategy of targeting investments in call options to an amount approximately equal to the amount of income generated by the Fund’s
portfolio.” Please clarify what this sentence means.

 Response. The
                                            Registrant has revised the disclosure as follows:

June
25, 2024

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5

The
partial amount of equity upside the Fund captures is dictated by the adviser’s strategy of targeting
investments in call options to an amount approximately equal to the amount of income generated by the Fund’s portfolio. Using
this strategy, based on recent market conditions, the adviser anticipates that the Fund will capture 20% to 40% of U.S. large capitalization
equity market gains on a quarter-to-quarter basis.

Principal
Risks of Investing in the Fund

 Comment
                            11. Please
order the risks to prioritize risks most likely to adversely affect the Fund's NAV, yield, and total return. Please note that after listing
most significant risks to the Fund, the remaining risks may be alphabetized. See ADI 2019-08-improving principal risks disclosure.

 Response. The
                                            Registrant has reordered the risks as follows: Options Risk, FLEX Options Risk, Derivatives
                                            Risk, Active Management Risk, and Equity Market Risk, with the remaining risks alphabetized.

 Comment
                            12. In
the “Options Risk,” consider discussing any principal risks of particular options strategies that the Fund will be employing
including the call option spread and box spread strategies.

 Response. The
                                            Registrant notes that call spreads are no longer part of the principal investment strategy
                                            and does not believe that box spreads pose any risks that are not already covered under the
                                            “Options Risk” disclosure. The Registrant has revised Options Risk in the summary
                                            prospectus for TrueShares Quarterly Bull Hedge ETF as follows:

Options
Risk. Buying and selling (writing) options are speculative activities and entail greater than ordinary
investment risks. As the buyer of a call option, the Fund risks losing the entire premium invested in the option if the Fund does
not exercise the option.

The
Registrant has revised the Options Risk in the summary prospectus for TrueShares Quarterly Bear Hedge ETF as follows:

Options
Risk. Buying and selling (writing)
options are speculative activities and entail greater than ordinary investment risks. As
the buyer of a put option, the Fund risks losing the entire premium invested in the option if the Fund does not exercise the option.

More
detailed risk disclosures are included in the combined statutory prospectus.

 Management

 Comment
                            13. With
respect to the Portfolio Manager, please state title and length of service. See Item 5(b) of Form N-1A.

June
25, 2024

Page
6

 Response. The
                                            Registrant has added the following disclosure:

Jeffrey
Feldman, Portfolio Manager of TrueMark Investments, LLC and Quantitative Risk Manager of RiverNorth Capital
Management, LLC, has served the Fund as portfolio manager since it commenced operations in June, 2024.

Additional
Information About the Funds’ Principal Risks

 Comment
                            14. Please
update “Equity Market Risk” to reflect today's interest climate.

 Response. In
                                            response to the Staff’s comment, the Registrant has reviewed the relevant risk factor
                                            and has revised to remove the second paragraph discussing recent market events as these risks
                                            are duplicative to those discussed within “Market and Geopolitical Risk.” The
                                            Registrant believes that the remaining paragraph within Equity Market Risks adequately discuss
                                            how interest rates as a factor considered by investors under Equity Market Risk. Further
                                            discussion of the impact of interest rates are also discussed under other risk factors such
                                            as Fixed Income Securities Risk.

 MANAGEMENT

 Comment
                            15. With
respect to the investment adviser and with a view to potential risk disclosures, please supplementall