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    Morrison
                                            C. Warren

                           Partner

    Chapman and Cutler LLP

    320 South Canal Street,
    27th Floor

    Chicago, Illinois 60606

    T (312) 845-3484

    warren@chapman.com

January 2, 2024

Via EDGAR Correspondence

Michael Rosenberg

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Roundhill ETF Trust

    File Nos. 333-273052; 811-23887

Dear Mr. Rosenberg:

This letter responds to your comments,
provided by telephone, regarding the registration statement filed on Form N-1A for Roundhill ETF Trust (the “Trust”)
with the Securities and Exchange Commission (the “Commission”) on October 27, 2023 (the “Registration Statement”).
The Registration Statement relates to the Roundhill Bitcoin Covered Call Strategy ETF (the “Fund”), a series of the
Trust. Capitalized terms used herein, but not otherwise defined, have the meanings ascribed to them in the Registration Statement.

Comment
1 – Investment Objective

In the section entitled “Investment
Objective” and throughout the Registration Statement, as applicable, please state that the underlying fund (the “Bitcoin
Futures ETF”) trades on a U.S.-regulated exchange. Additionally, please identify the name of the Bitcoin Futures ETF in the
section entitled “Investment Objective.”

Response
to Comment 1

Pursuant to the Staff’s
comment, the section entitled “Investment Objective” has been revised as set forth below:

The Fund’s primary investment objective
is to provide current income. The Fund’s secondary investment objective is to provide exposure to the price return of an exchange-traded
fund that invests principally in bitcoin futures contracts and whose shares trade on a U.S.-regulated securities exchange.

January 2, 2024

Page 2

The Registrant respectfully declines
to specifically identify the Bitcoin Futures ETF, as the Fund may invest in options that reference different Bitcoin Futures ETFs over
the life of the Fund. Additionally, given that the Fund does not identify the Bitcoin Futures ETF – either by name or by ticker
– in the name of the Fund (as do “single stock ETFs”), the Fund does not believe there is any requirement or convention
that such fund be named in the investment objective.

Comment
2 – Fees and Expenses

Pursuant to Item 3 of Form N-1A,
please add “acquired fund fees and expenses” as a line item to the “Annual Fund Operating Expenses” table. In
the event acquired fund fees and expenses do not exceed 0.01%, the Fund may include these expenses in the line item for “Other Expenses.”
If acquired fund fees and expenses are included in the Fund’s unitary management fee, please disclose in the footnote to the table.

Response
to Comment 2

The Fund does not currently intend
to invest in shares of ETFs, but rather intends to derive its exposure through options that reference the Bitcoin Futures ETF. Accordingly,
the Fund will not have acquired fund fees and expenses.

Comment
3 – Principal Investment Strategies

Please provide an overview of
the operation of the Bitcoin Futures ETF, including how the Bitcoin Futures ETF maintains exposure to bitcoin futures over time (i.e.,
rolling) and a discussion of contango and backwardation. Please also describe the Bitcoin Futures ETF’s use of a wholly-owned subsidiary
to invest in bitcoin futures.

Response
to Comment 3

Pursuant to the Staff’s
comment, the following disclosure has been added to the section entitled “Principal Investment Strategies”:

Additional Information About the Bitcoin
Futures ETF

The Bitcoin Futures ETF seeks to provide investment
results that correspond to the performance of bitcoin. The Bitcoin Futures ETF seeks to achieve this objective through investments in
bitcoin futures contracts. The Bitcoin Futures ETF does not invest directly in bitcoin. The bitcoin futures contracts held by the
Bitcoin Futures ETF are standardized, cash-settled bitcoin futures contracts traded on commodity exchanges registered with the CFTC. While
the Bitcoin Futures ETF seeks to invest in cash-settled, front-month bitcoin futures, it may also invest in back-month, cash-settled bitcoin
futures contracts. Front-month bitcoin futures contracts are those contracts with the shortest time to maturity. Back-month bitcoin futures
contracts are those with longer times to maturity. In order to maintain its exposure to bitcoin futures contracts, the Bitcoin Futures
ETF must sell its futures contracts as they near expiration and replace them with new futures contracts with a later expiration date.
This is often referred to as “rolling” a futures contract. Futures contracts with a longer term to expiration may be priced
higher than futures contracts with a shorter term to expiration, a relationship called “contango.” When rolling futures contracts
that are in contango, the Bitcoin Futures ETF will sell the expiring contract at a relatively lower price and buy a longer-dated contract
at a relatively higher price. Conversely, futures contracts with a longer term to expiration may be priced lower than futures contracts
with a shorter term to expiration, a relationship called “backwardation.” When rolling futures contracts that are in backwardation,
the Bitcoin Futures ETF will sell the expiring contract at a relatively higher price and buy a longer-dated contract at a relatively lower
price.

January 2, 2024

Page 3

The Bitcoin Futures ETF may also invest in
money market instruments and U.S. government to provide liquidity, serve as margin or collateralize the Bitcoin Future ETF’s investments
in bitcoin futures contracts. Due to the high margin requirements that are unique to bitcoin futures contracts and certain tests that
must be met in order to qualify as a regulated investment company (“RIC”) under Subchapter M of the Internal Revenue Code
of 1986 (the “Code”), the Bitcoin Futures ETF may also utilize reverse repurchase agreements during certain times of the year
to help maintain the desired level of exposure to bitcoin futures contracts.

The Bitcoin Futures ETF expects to gain exposure
to bitcoin by investing in bitcoin futures contracts through a wholly-owned subsidiary of the fund organized under the laws of the Cayman
Islands. Because the Bitcoin Futures ETF intends to qualify for treatment as a RIC under Subchapter M of the Code, the Bitcoin Futures
ETF intends to invest no more than 25% of its total assets in the subsidiary at each quarter end of the fund’s tax year.

January 2, 2024

Page 4

Comment
4 – Principal Investment Strategies

Please describe bitcoin and the
bitcoin blockchain, the relationship of bitcoin to the bitcoin blockchain and the applications and use cases that bitcoin and the bitcoin
blockchain have been designed to support.

Response
to Comment 4

Pursuant to the Staff’s
comment, the following disclosure has been added to the section entitled “Principal Investment Strategies”:

Additional Information on Bitcoin

Bitcoin is a digital asset that is created
and transmitted through the operations of the online, peer-to-peer Bitcoin network, a decentralized network of computers that operates
on cryptographic protocols. The ownership of bitcoin is determined by participants in the Bitcoin network. The Bitcoin network connects
computers that run publicly accessible, or “open source,” software that follows the rules and procedures governing the Bitcoin
network. This is commonly referred to as the Bitcoin Protocol. Bitcoin, the asset, plays a key role in the operation of the Bitcoin network,
as the computers (or “miners”) that process transactions on the network and maintain the network’s security are compensated
through the issuance of new bitcoin and through transaction fees paid by users in bitcoin.

No single entity owns or operates the Bitcoin
network. Bitcoin is not issued by any government, by banks or similar organizations. The infrastructure of the Bitcoin network is collectively
maintained by a decentralized user base. The Bitcoin network is accessed through software, and software governs the creation, movement,
and ownership of “bitcoin,” the unit of account on the Bitcoin network ledger. The value of bitcoin is determined, in part,
by the supply of, and demand for, bitcoin in the global markets for trading bitcoin, market expectations for the adoption of bitcoin as
a decentralized store of value, the number of merchants and/or institutions that accept bitcoin as a form of payment and the volume of
private end-user-to-end-user transactions.

January 2, 2024

Page 5

Bitcoin transaction and ownership records
are reflected on the “Bitcoin blockchain,” which is a digital public record or ledger. Copies of this ledger are stored in
a decentralized manner on the computers of each Bitcoin network node (a node is any user who maintains on their computer a full copy of
all the bitcoin transaction records, the blockchain, as well as related software). Transaction data is permanently recorded in files called
“blocks,” which reflect transactions that have been recorded and authenticated by Bitcoin network participants. The Bitcoin
network software source code includes protocols that govern the creation of new bitcoin and the cryptographic system that secures and
verifies bitcoin transactions.

Comment
5 – Principal Investment Strategies

Please provide the name of the
subadvisor.

Response
to Comment 5

The disclosure has been revised
in accordance with the Staff’s comment to remove the reference to the Fund’s investment adviser and investment sub-adviser
in the section entitled “Principal Investment Strategies.” Both the investment adviser and investment sub-adviser are identified
in the section of the prospectus entitled “Management.”

Comment
6 – Principal Investment Strategies

Please provide a summary of the
Bitcoin Futures ETF in which the Fund will invest, including its objective and principal investment strategies. Please also disclose that
to the extent the Fund will invest in underlying funds, it will only do so in underlying funds which trade on a U.S.-regulated exchange.

Response
to Comment 6

Pursuant to the Staff’s
comment, the Registrant has added voluminous disclosure regarding the Bitcoin Futures ETF, which is set forth in Response to Comment 3.
Additionally, the requirement that a Bitcoin Futures ETF’s shares trade on a regulated U.S. exchange has been incorporated into
the definition of “Bitcoin Futures ETF.” Accordingly, the disclosure set forth below, requires that to the extent the Fund
invests in shares of a Bitcoin Futures ETF, such shares would trade on a regulated U.S. exchange.

The Fund seeks to achieve its investment objectives
through the use of a synthetic covered call strategy that provides current income on a monthly basis, while also providing exposure to
the price return of an exchange-traded fund (“ETF”) that invests principally in bitcoin futures contracts and whose
shares trade on a U.S.-regulated securities exchange (the “Bitcoin Futures ETF”). (emphasis added)

…

The Fund may also directly hold shares of
the Bitcoin Futures ETF.

January 2, 2024

Page 6

Comment
7 – Principal Investment Strategies

The Staff notes the following
disclosure set forth in the section entitled “Principal Investment Strategies”:

The Fund does not invest directly in bitcoin.

Please also state that the Bitcoin
Futures ETF will not invest in bitcoin directly.

Response
to Comment 7

Pursuant to the Staff’s
comment, the disclosure has been revised accordingly.

Comment
8 – Principal Investment Strategies

The Staff notes the following
disclosure set forth in the section entitled “Principal Investment Strategies”:

[T]he Fund intends to only utilize exchange-traded
options.

Please indicate that those options
will be traded on a U.S.-regulated exchanges.

Response
to Comment 8

Pursuant to the Staff’s
comment, the disclosure has been revised accordingly.

Comment
9 – Principal Risks

In the “Covered Call Strategy
Risk,” please state that the Fund employs a synthetic covered call strategy and include any risks specific to that strategy.

January 2, 2024

Page 7

Response
to Comment 9

Pursuant to the Staff’s
comment, the referenced disclosure has been revised to include the following disclosure:

The covered call strategy utilized by the
Fund is “synthetic” because the Fund’s exposure to the price return of the Bitcoin Futures ETF is derived through options
exposure, rather than direct holdings of the shares of the Bitcoin Futures ETF. Because such exposure is synthetic, it is possible that
the Fund’s participation in the price return of the Bitcoin Futures ETF may not be as precise as if the Fund were directly holding
shares of the Bitcoin Futures ETF.

Comment
10 – Principal Risks

In “Liquidity Risk,”
please clarify that this risk is also applicable to the futures in which the Bitcoin Futures ETF invests and that the large positions
held by the Bitcoin Futures ETF may also impact the price of bitcoin futures, which could decrease the correlation between the performance
of bitcoin futures and spot bitcoin.

Response
to Comment 10

Pursuant to the Staff’s
comment, the referenced disclosure has been revised to include the following disclosure:

Additionally, the bitcoin futures contracts
held by the Bitcoin Futures ETF are subject to liquidity risk. The market for bitcoin futures contracts may be less developed, and potentially
less liquid and more volatile, than more established futures markets. While the market has grown substantially since bitcoin futures contracts
commenced trading, there can be no assurance that this growth will continue. The large size of the positions which the Bitcoin Futures
ETF may acquire increases the risk of illiquidity, may make its positions more difficult to liquidate, and may increase the losses incurred
while trying to do so. Such large positions also may impact the price of bitcoin futures contracts, which could decrease the correlation
between the performance of bitcoin futures contracts and the “spot” price of bitcoin.

January 2, 2024

Page 8

Comment
11 – Principal Risks

In an appropriate place, please
disclose the following risks associated with the Bitcoin Futures ETF: (1) the Bitcoin Futures ETF does not invest directly in or hold
bitcoin; (2) the performance of the Bitcoin Futures ETF should not be expected to match the performance of spot bitcoin; (3) the risks
associated with bitcoin market volatility; (4) the risks associated with bitcoin futures capacity risk; and (5) general bitcoin futures
risk.

Response
to Comment 11

Pursuant to the Staff’s
comment, the introduction to “Bitcoin Futures ETF Risk” has been revised as set forth below:

The Bitcoin Futures ETF does not invest
directly in bitcoin. Accordingly, the performance of the Bitcoin Futures ETF should not be expected to match the performance of
bitcoin. The Fund will have significant exposure to the Bitcoin Futures ETF through its options positions that utilize the Bitcoin Futures
ETF as the reference asset. Accordingly, the Fund will subject to the risks of the Bitcoin Futures ETF, set forth below.

Additionally, pursuant to the
Staff’s comment, the following risks have been added in the section entitled “Principal Risks – Bitcoin Futures ETF
Risks”: “Bitcoin Futures Risk”; “Bitcoin Futures Capacity Risk”; “Cost of Futures Investment Risk”;
and “Market and Volatility Risk.”

Comment
12 – Principal Risks

In “Bitcoin Risk,”
please disclose that the value of bitcoin has been and may continue to be substantially dependent on speculation such that the trading
and investing in bitcoin generally may not be based on fundamental analysis.

Response
to Comment 12

Pursuant to the Staff’s
comment, the first paragraph of the referenced risk has been revised to include the following disclosure:

The value of bitcoin has been, and may continue
to be, substantially dependent on speculation, such that trading and inves