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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

July 31, 2024

VIA EDGAR CORRESPONDENCE

Eileen 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 the Trust with the staff of the Securities
and Exchange Commission (the “Staff”) on May 23, 2024 (the “Registration Statement”). The Registration
Statement relates to Roundhill S&P 500Ò Target
10 Managed Distribution ETF and Roundhill S&P 500Ò Target
20 Managed Distribution ETF (formerly, Roundhill S&P 500Ò Target
10 Distribution ETF and Roundhill S&P 500Ò Target
20 Distribution ETF) (each, a “Fund,” and collectively, 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 – Fund Name

The Staff continues to believe
that each Fund’s name is misleading under Section 35(d) of the 1940 Act because use of “Distribution” in the names could
lead investors to believe that such distribution is comprised of income or capital gains and not just return of capital. Please add a
modifier before “Distribution” to reflect the limitations on the distribution each Fund intends to pay. For example, the Staff
would not object to “Managed Payout” in lieu of “Distribution” or the insertion of “Managed” before
“Distribution.”

Response
to Comment 1

Pursuant to the Staff’s
comment, the Funds’ names have been changed to Roundhill S&P 500 Target 10 Managed Distribution ETF and Roundhill S&P 500
Target 20 Managed Distribution ETF, respectively.

Comment
2 – Principal Investment Strategies

The Fund does not describe with
sufficient specificity the principal strategies of the Funds, particularly with regard to how the Fund will try to achieve return of capital
distributions that will enable investors to fully understand the risks of this fund, particularly if return of capital or deferral of
taxes are instrumental to the investors’ decision. Please disclose with more specificity how the Fund intends to achieve its investment
objective.

Response
to Comment 2

In the Registrant’s prior
response to the Staff, the disclosure set forth below was added to the section entitled “Principal Investment Strategies”:

The Adviser evaluates the Fund’s net gain
or loss position in determining the means by which cash is generated to make the target monthly distribution payments. The Adviser may
utilize uninvested cash or the proceeds from securities sold through the application of tax sensitive investment strategies, including
the use of tax loss harvesting. There may be months when the techniques utilized by the Adviser generate tax liabilities for the Fund
and the corresponding monthly distribution is not entirely characterized as return of capital. In addition, the Adviser may utilize investment
strategies to generate cash that carry some degree of uncertainty as it relates to the tax characterization of the cash produced therefrom.
In the event that it is subsequently determined that such techniques produce cash that is not characterized as return of capital, the
Fund would incur tax liabilities that would negatively affect the Fund’s returns and the Fund’s ability to achieve its investment
objective.

The Registrant believes that this
disclosure sufficiently explains the mechanism of each Fund’s principal investment strategy. Although the outcome of the strategy
– relatively large distributions payouts designed to be characterized entirely as return of capital while maintaining exposure to
the return of the S&P 500 Index – sounds complicated, the mechanism of the strategy itself is straightforward. The Funds will
have exposure to two assets, purchased call options on SPY, and cash. Depending on the Fund’s net gain or loss position each month,
the Fund may either sell its call options (if such a sale would be at a loss or if the Fund already has embedded losses, the Fund may
sell such options at a gain) or fund the distributions through payment of uninvested cash. The Registrant believes the disclosure set
forth above describes this in such a way to be both accurate and understandable to the average investor.

Comment
3 – Principal Investment Strategies

The Staff notes the following
three sentences in the second paragraph of the section entitled “Principal Investment Strategies”:

The Adviser seeks to maximize the amount of the
distribution that is categorized as “return of capital” from a tax perspective, with a target of 100% return of capital…

Return of capital represents a return of a portion
of a Fund shareholder’s invested capital and is not taxable in the year it is received unless the distribution exceeds a shareholder’s
basis in the Fund. However, a return of capital may result in an increase in a later gain on a sale of Fund Shares or a reduction of a
loss.

The Staff believes that these
sentences are critical to an investor’s understanding of the Fund’s investment strategy and should be made more prominent.

Response
to Comment 3

Pursuant to the Staff’s
comment, the referenced sentences have been bolded.

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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