SecProbe.io

CORRESP
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  Morrison Warren

                         Partner

  Chapman and Cutler LLP

                         320 South Canal Street, 27th Floor

                         Chicago, Illinois 60606

                         T (312) 845-3484

                         warren@chapman.com

January 16, 2024

VIA EDGAR CORRESPONDENCE

Eileen M. Smiley

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Roundhill ETF Trust (the “Trust”)

    File Nos. 333-273052; 811-23887

Dear Ms. Smiley:

This letter responds to your comments
regarding the registration statement filed on Form N-1A for Roundhill ETF Trust (the “Trust”) with the staff of the
Securities and Exchange Commission (the “Staff”) on October 27, 2023 (the “Registration Statement”).
The Registration Statement relates to the Roundhill S&P 500 0DTE Covered Call Strategy ETF and Roundhill N-100 0DTE Covered Call Strategy
ETF (formerly Roundhill SPX 0DTE Covered Call Strategy ETF and Roundhill NDX 0DTE Covered Call Strategy ETF, respectively) (each,
a “Fund” and together, the “Funds”), each 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 – General

The Staff reminds the Registrant
that to the extent that the comments are applicable to both Funds, such comments apply to both Funds.

Response
to Comment 1

The Registrant confirms its understanding
that applicable comments apply to both Funds.

Comment
2 – Fund Names

The Staff notes that the name
of each Fund references to a specific index by the use of the index’s ticker in the Fund name. Accordingly, each Fund is subject
to Rule 35d-1 of the 1940 Act. Please disclose in the principal investment strategy section that each Fund will invest 80% of its net
assets in the components, or economic equivalent thereof, the relevant index.

Response
to Comment 2

Pursuant to the Staff’s
comment, the first paragraph of the section entitled “Principal Investment Strategies” has been revised to include the following
disclosure:

The Fund will invest at least 80% of its net
assets (plus any borrowings for investment purposes) in shares of SPX ETFs and options contracts that utilize SPX as the reference asset.
For purposes of compliance with this investment policy, derivative contracts will be valued at their notional value.

The Fund will invest at least 80% of its net
assets (plus any borrowings for investment purposes) in shares of the N-100 ETFs and options contracts that utilize the N-100 as the reference
asset. For purposes of compliance with this investment policy, derivative contracts will be valued at their notional value.

Comment
3 – Fees and Expenses

To the extent that each Fund incurs
fees in connection with its short positions in excess of one basis point, please confirm to the Staff that such expenses will be broken
out as a separate line item in the Fees and Expenses table. Additionally, please provide the Staff with the completed fee table before
effectiveness.

Response
to Comment 3

While the Funds will have “short”
exposure through their use of written call options, neither Fund will engage in traditional short sales that will incur the types of expenses
referenced in the Staff’s comment. Additionally, completed fee tables for each Fund have been set forth on Exhibit A and Exhibit
B.

Comment
4 – Fees and Expenses

The Staff requests that if the
acquired fund fee expenses of investing in money market funds exceed one basis point, to confirm to the Staff that these expenses be broken
out into a separate line item.

Response
to Comment 4

Each Fund will have acquired fund
fees and expenses in excess of one basis point, and accordingly, such expenses will be broken out as a separate line item.

Comment
5 – Principal Investment Strategies

The Staff requests that the first
paragraph of the section entitled “Principal Investment Strategies” be revised to provide adequate specificity regarding the
instruments that the Funds actually intend to use in order to provide the long and short exposure required to effectuate its investment
strategy.

    2

Response
to Comment 5

Pursuant to the Staff’s
comment, the first paragraph of the section entitled “Principal Investment Strategies” has been significantly revised.

Comment
6 – Principal Investment Strategies

The Staff references the following
disclosure set forth in the first paragraph of the section entitled “Principal Investment Strategies”:

Roundhill Financial Inc.
serves as the Fund’s investment adviser (“Roundhill” or the “Adviser”) and ___________ serves as the Fund’s
investment sub-adviser (“______” or the “Sub-Adviser”).

As such disclosure is not required
to be included pursuant to Form N-1A of the 1940 Act, the Staff believes such disclosure should be deleted.

Response
to Comment 6

Pursuant to the Staff’s
comment, the referenced disclosure has been deleted.

Comment
7 – Principal Investment Strategies

The Staff requests that the second
paragraph of the section entitled “Principal Investment Strategies” be revised to provide adequate specificity regarding the
instruments that the Funds actually intend to use in order to provide the long and short exposure required to effectuate its investment
strategy.

Response
to Comment 7

Pursuant to the Staff’s
comment, the second paragraph of the section entitled “Principal Investment Strategies” has been significantly revised.

Comment
8 – Principal Investment Strategies

The Staff requests that the third
paragraph of the section entitled “Principal Investment Strategies” be revised to provide adequate specificity regarding the
instruments that the Funds actually intend to use in order to provide the long and short exposure required to effectuate its investment
strategy.

Response
to Comment 8

Pursuant to the Staff’s
comment, the third paragraph of the section entitled “Principal Investment Strategies” has been significantly revised.

    3

Comment
9 – Principal Investment Strategies

Please explain supplementally
to the Staff, and consider adding disclosure regarding, how investing directly in the constituent securities of the index would impact
a Fund’s ability to generate income using this strategy of selling out-of-the-money call options on the index.

Response
to Comment 9

The Funds do not intend to invest
directly in the constituent securities of the relevant index. Each Fund intends to derive its long exposure to the applicable index through
investments into ETFs that seek to passively track each index.

Comment
10 – Principal Investment Strategies

The Staff requests that the section
entitled “Principal Investment Strategies” be revised to provide additional detail regarding each index, such as the component
selection criteria for the index, index weighting methodology, name of the index, index provider, rebalancing and reconstitution process,
and number of index components or range. Please explain if the Fund is going to invest directly in the index’s underlying securities,
whether it will use sampling, or use a direct replication of the index.

Response
to Comment 10

Pursuant to the Staff’s
comment, each Fund has included the relevant disclosure in the section of the prospectus entitled “Principal Investment Strategies.”

Comment
11 – Principal Investment Strategies

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

However, it is important to note that the
sale of these call options to generate income will limit the Fund’s ability to participate in increases in value of NDX beyond a
certain point.

This is too vague. Please provide
further specificity regarding at what point the Fund will no longer participate in the gains of the index. Please consider adding a mathematical
example to clarify this concept for shareholders.

Response
to Comment 11

Pursuant to the Staff’s
comment, the third paragraph of the section entitled “Principal Investment Strategies” has been revised to include the following
disclosure:

However, if SPX appreciates in value beyond
the strike price of the call option contracts that the Fund has sold to generate income, the Fund will lose money on those short call
positions, and the losses will, in turn, limit the upside return of the Fund’s long exposure. This strategy effectively converts
a portion of the potential upside return growth of SPX into current income. For instance, if, on a given business day, the Fund
sold SPX call options that were 1% out-of-the-money at the time they were sold, and on that day SPX experienced a gain of 2%, the Fund
would only experience a gain of 1% because while its investments in the SPX ETF gained 2%, they were offset by the 1% loss it experienced
from its sold SPX call options. However, please note, this example is provided for illustration only. The Fund does not seek to sell call
options at a particular strike price. The strike price at which such call options are sold is dependent on prevailing market conditions.

    4

Comment
12 – Principal Investment Strategies

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

The Fund intends to make ______ distribution
payments to shareholders.

Please specify whether this blank
space intended to cover frequency of distribution payments or a specified distribution amount.

Response
to Comment 12

The blank has been filled in to
clarify that this disclosure relates to distribution frequency.

Comment
13 – Principal Investment Strategies

Please revise the section entitled
“Principal Investment Strategies” to include additional disclosure regarding how and for what purpose short-term U.S. treasuries
and money market funds are part of each Fund’s principal investment strategy.

Response
to Comment 13

The referenced disclosure has
been deleted as the Funds’ investments in those securities will not constitute a principal investment strategy of the Funds.

Comment
14 – Principal Investment Strategies

Please supplementally explain
to the Staff whether the Funds will be non-diversified in case the index is non-diversified or if the Fund is also retaining the right
to and is anticipating replicating the index through direct sampling.

    5

Response
to Comment 14

The Funds have been classified
as “non-diversified” at the time of their launch to allow them to preserve flexibility during the invest-up phase. In the
event they are operated in a diversified manner for three consecutive years, their status will automatically convert to “diversified”
under the 1940 Act. The decision to elect “non-diversification” at the outset is unrelated to their investment strategy.

Comment
15 – Principal Investment Strategies

Please supplementally explain
to the Staff if the Funds intend to engage in investment activities and securities or other assets through entities that are primarily
controlled by a Fund.

Response
to Comment 15

The Funds do not currently intend
to engage in investment activities through entities that are primarily controlled by a Fund.

Comment
16 – Principal Risks

Please order the risks to prioritize
the risks that are most likely to adversely affect the Fund’s net asset value, yield and total return in light of changes to each
Fund’s principal investment strategy regarding how it actually intends to derive its contemplated short and long investment exposure.

Response
to Comment 16

Each Fund’s risks have been
ordered accordingly.

Comment
17 – Principal Risks

Please refine the disclosure set
forth in “Covered Call Risk” to reflect how the Funds intend to derive their long exposure. Please consider the applicability
of references to put options in this risk disclosure.

Response
to Comment 17

Pursuant to the Staff’s
comment, “Covered Call Risk” has been revised accordingly.

Comment
18 – Principal Risks

Please add principal risk disclosure
specifically relating to 0DTE options contracts.

Response
to Comment 18

Pursuant to the Staff’s
comment, “Options Risk” has been revised to include the following disclosure:

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The Fund’s use of zero days to
expiration, known as “0DTE” options, presents additional risks. Due to the short time until their expiration, 0DTE
options are more sensitive to sudden price movements and market volatility than options with more time until expiration. Because of
this, the timing of trades utilizing 0DTE options becomes more critical. Although the Fund intends to enter into 0DTE options trades
on market open, or shortly thereafter, even a slight delay in the execution of these trades can significantly impact the outcome of
the trade. Such options may also suffer from low liquidity, making it more difficult for the Fund to enter into its positions each
morning at desired prices. The bid-ask spreads on 0DTE options can be wider than with traditional options, increasing the
Fund’s transaction costs and negatively affecting its returns. Additionally, the proliferation of 0DTE options is relatively
new and may therefore be subject to rule changes and operational frictions.

Comment
19 – Principal Risks

Please supplementally explain
to the Staff why “Counterparty Risk” constitutes a principal risk to the Funds in light of how the Funds intend to actually
achieve their short and long exposure as set forth in the revised “Principal Investment Strategies” section of the prospectus.
Please include disclosure in the first sentence of such risk tying it to one or more of the investments in which the Funds will principally
invest.

Response
to Comment 19

As each Fund’s options positions
are guaranteed by the OCC, the Fund has determined that “Counterparty Risk” does not constitute a principal risk to the Funds.

Comment
20 – Principal Risks

Please supplementally explain
to the Staff why “Credit Risk” constitutes a principal risk to the Funds in light of how the Funds intend to actually achieve
their short and long exposure as set forth in the revised “Principal Investment Strategies” section of the prospectus. Please
include disclosure in the first sentence of such risk tying it to one or more of the investments in which the Funds will principally invest.

Response
to Comment 20

The referenced disclosure has
been deleted.

Comment
21 – Principal Risks

Please supplementally explain
to the Staff why “Derivatives Risk” constitutes a principal risk to the Funds in light of how the Funds intend to actually
achieve their short and long exposure as set forth in the revised “Principal Investment Strategies” section of the prospectus.
Please include disclosure in the first sentence of such risk tying it to one or more of the investments in which the Funds will principally
invest.

Response
to Comment 21

“Derivatives Risk”
constitutes a principal risk to the Funds because the Funds’ use of options contracts, a type of derivative contract, is the primary
means by which the Funds derive income. The Registrant believes the applicability of this risk disclosure is self-evident and respectfully
declines to include any additional disclosure.

Comment
22 – Principal Risks

Please supplementally explain
to the Staff why “Equity Securities Risk” constitutes a principal risk to the Funds in light of how the Funds intend to actually
achieve their short and long exposure as set forth in the revised “Principal Investment Strategies” section of the prospectus.
Please include disclosure in the first sentence of such risk tying it to one or more of the investments in which the Funds will principally
invest.

    7

Response
to Comment 22

“Equity Securities Risk”
has been moved beneath “SPX ETF Risks” and “N-100 ETF Risks,” as applicable, to clarify that the Funds have exposure
to equity securities risk through their holdings of ETFs, which principally hold equity securities.

Comment
23 – Principal Risks

Please supplementally exp