SecProbe.io

CORRESP
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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

March
1, 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

Please
confirm that the name and ticker symbol of the Funds will be updated on EDGAR.

Response
to Comment 1

The
Registrant so confirms.

Comment
2 – Principal Investment Strategies

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

This
means that the Fund will exercise these contracts and will experience a gain equal to the difference between the strike price
of the options contracts and the value of the S&P 500® Index.

Please
consider adding disclosure that clarifies that trading in options is subject to transaction costs.

Response
to Comment 2

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

Lastly,
the trading of options is subject to transaction costs that may impact the Fund’s returns.

Comment
3 – Principal Risks

The
Staff notes the following disclosure set forth in “0DTE Options Risk”:

Additionally,
the Fund is a “synthetic” covered call strategy, meaning that it derives its long exposure to the N-100 Index from
derivatives that utilize the N-100 Index as the reference asset. (emphasis added)

If
accurate, please consider changing “derivatives” to “options.”

Response
to Comment 3

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

Comment
4 – 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 4

The
Registrant revised the order of the Funds’ risks in response to a prior Staff comment and believes that the current order
of risks is responsive to the Staff’s comment and is compliant with the requirements of Form N-1A.

Comment
5 – Principal Risks

The
Staff notes the following disclosure set forth in “Cash Transactions Risk”:

The
Fund will effect a significant portion of its creations and redemptions for cash, rather than in-kind securities.

Please
confirm the accuracy of this disclosure and confirm that all over disclosure throughout the Registration Statement is consistent
therewith.

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Response
to Comment 5

Pursuant
to the Staff’s comment, the Registrant confirms that the referenced disclosure is accurate. Due to the nature of each Fund’s
holdings, creations and redemptions will almost always be effected for cash. However, there may be limited instances where in-kind
securities do constitute a portion of a Fund’s creation and redemption basket. Accordingly, the Registrant believes that
this disclosure, and all other disclosure referencing creation and redemptions in the Registration Statement, is accurate and
compliant with the requirements of Form N-1A.

Comment
6 – Additional Information About the Fund’s Principal Investment Strategies

The
Staff notes that the disclosure set forth in the section entitled “Additional Information About the Fund’s Principal
Investment Strategies” is largely repetitive of what is set forth in the section entitled “Principal Investment Strategies.”
Please consider shortening or expanding upon the disclosure set forth in the Item 9 portion of the prospectus so that it is duplicative
of the disclosure set forth in Item 4.

Response
to Comment 6

Pursuant
to the Staff’s comment, the section entitled “Additional Information About the Fund’s Principal Investment Strategies”
has been significantly shortened, so as not to be duplicative, as set forth below:

Additional
Information About the Fund’s Investment Strategies

As
set forth in the section of the prospectus entitled “Principal Investment Strategies,” the Fund seeks to utilize 0DTE
options to achieve its investment objective. The Fund may, on a non-principal basis, achieve the long and short exposure set forth
above through the use of swap agreements or futures contracts.

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 options 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.

The
Fund is classified as “non-diversified” under the 1940 Act.

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*
* * * * * * *

Please
call me at (312) 845-3484 if you have any questions or issues you would like to discuss regarding these matters.

    Sincerely yours,

    Chapman and Cutler LLP

    By:
    /s/
    Morrison C. Warren

    Morrison
    C. Warren

    cc:
    Richard
    Coyle, Esq., Chapman and Cutler LLP

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