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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

February 21, 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.

On January 16, 2024, the Registrant
filed a response to these comments (the “Prior Correspondence”). However, subsequent to the filing the Prior Correspondence
with the Staff – and prior to the effectiveness of the Registration Statement – the Registrant determined it was operationally
necessary to revise each Fund’s principal investment strategies to reflect that each Fund would derive its long exposure to the
applicable index not through investments in ETFs that track the index, but rather through purchased call options that utilized the index
as the reference asset. Accordingly, the Registrant is revising its responses to the Staff’s comments, as set forth below.

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 financial instruments (such as options
contracts) that utilize the S&P 500Ò Index
as the reference asset. For purposes of compliance with this investment policy, derivative contracts (i.e. options 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 financial instruments (such as options contracts) that utilize the Nasdaq-100
Index as the reference asset. For purposes of compliance with this investment policy, derivative contracts (i.e. options 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.

    2

Response
to Comment 4

The Funds will not have acquired
fund fees and expenses in excess of one basis point, and accordingly, such expenses will not 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.

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.

    3

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.

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 the purchase of call options that utilize the applicable index as the reference asset.

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.

    4

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 the S&P 500Ò Index
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 the S&P 500Ò
Index into current income. For instance, if, on a given business day, the Fund
sold S&P 500Ò Index
call options that were 1% out-of-the-money at the time they were sold, and from the time the options were sold the S&P 500Ò
Index experienced a gain of 2%, the Fund would only experience a gain of 1% because
while its purchased S&P 500Ò Index
call options would produce a gain of 2%, they were offset by the 1% loss it experienced from its sold S&P 500Ò
Index 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.

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.

    5

Response
to Comment 13

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

The Fund will also invest in short-term
U.S. Treasury securities and money market funds. These positions will be used to earn additional yield on any cash not invested in options
contracts.

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.

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.

    6

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, the following has been added a separate risk in the section entitled “Principal Risks”:

ODTE OPTIONS RISK. 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. To the extent that the OCC enacts new rules relating to 0DTE options that make it impracticable
or impossible for the Fund to utilize 0DTE to effectuate its investment strategy, it may instead utilize options with the shortest remaining
maturity available or it may utilize swap agreements to provide the desired exposure.

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.

    7

Response
to Comment 19

As each Fund’s options
positions are guaranteed by the OCC, the Funds have determined that “Counterparty Risk” does not constitute a principal risk.
However, the Funds have added the risk set forth below, which is more directly applicable to each Fund’s holdings.

CLEARING MEMBER DEFAULT RISK. Transactions
in some types of derivatives, including the options held by the Fund, are required to be centrally cleared (“cleared derivatives”).
In a transaction involving cleared derivatives, the Fund’s counterparty is a clearinghouse, such as the OCC, rather than a bank
or broker. Since the Fund is not a member of clearinghouses, and only members of a clearinghouse (“clearing members”) can
participate directly in the clearinghouse, the Fund will hold cleared derivatives through accounts at clearing members. With regard its
cleared derivatives positions, the Fund will make payments (including margin payments) to, and receive payments f