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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

December 5, 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
regarding the registration statement filed on Form N-1A for the Roundhill ETF Trust (the “Registrant” or the“Trust”)
with the staff of the Securities and Exchange Commission (the “Staff”) on August 23, 2024 (the “Registration
Statement”). The Registration Statement relates to the Roundhill Apple AAPL Weekly Covered Call Strategy ETF, Roundhill Advanced
Micro Devices AMD Weekly Covered Call Strategy ETF, Roundhill Amazon AMZN Weekly Covered Call Strategy ETF, Roundhill Coinbase COIN Weekly
Covered Call Strategy ETF, Roundhill Alphabet GOOGL Weekly Covered Call Strategy ETF, Roundhill Meta Platforms META Weekly Covered Call
Strategy ETF, Roundhill Microsoft MSFT Weekly Covered Call Strategy ETF, Roundhill MicroStrategy MSTR Weekly Covered Call Strategy ETF,
Roundhill Nvidia NVDA Weekly Covered Call Strategy ETF and Roundhill Tesla TSLA Weekly Covered Call Strategy 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.

The Registrant notes that in response
to the Staff’s comments and certain operational considerations, the Registrant has revised the investment strategy of the Funds.
Revised prospectuses disclosing these changes have been provided to the Staff under separate cover. However, due to the changes in the
strategy, several of the Staff’s comments, especially those relating to the use of options, are no longer applicable as the Funds
will no longer utilize options contracts, but will instead invest principally in swap agreements.

The names of the Funds have been
changed as set forth in the table below.

    Old Name
    New Name

    Roundhill Apple AAPL Weekly Covered Call Strategy ETF
    Roundhill AAPL WeeklyPay ETF

    Roundhill Advanced Micro Devices AMD Weekly Covered Call Strategy ETF
    Roundhill AMD WeeklyPay ETF

    Roundhill Amazon AMZN Weekly Covered Call Strategy ETF
    Roundhill AMZN WeeklyPay ETF

    Roundhill Coinbase COIN Weekly Covered Call Strategy ETF
    Roundhill COIN WeeklyPay ETF

    Roundhill Alphabet GOOGL Weekly Covered Call Strategy ETF
    Roundhill GOOGL WeeklyPay ETF

    Roundhill Meta Platforms META Weekly Covered Call Strategy ETF
    Roundhill META WeeklyPay ETF

    Roundhill Microsoft MSFT Weekly Covered Call Strategy ETF
    Roundhill MSFT WeeklyPay ETF

    Roundhill Microstrategy MSTR Weekly Covered Call Strategy ETF
    Roundhill PLTR WeeklyPay ETF

    Roundhill Nvidia NVDA Weekly Covered Call Strategy ETF
    Roundhill NVDA WeeklyPay ETF

    Roundhill Tesla TSLA Weekly Covered Call Strategy ETF
    Roundhill TSLA WeeklyPay ETF

Comment
1 – General

The Staff reminds the Registrant
and its management that they are responsible for the accuracy and adequacy of the disclosures, notwithstanding any review, comments, action
or absence of action by the Staff. Where a comment is made in one location, it is applicable to all similar disclosures appearing elsewhere
in the Registration Statement. Please ensure that corresponding changes are made to all similar disclosure.

 Please provide responses
to all of the Staff’s comments on EDGAR at least five business days before the effective date of the Registration Statement.

Response
to Comment 1

The Registrant confirms that corresponding
changes made in response to the Staff’s comments have been made to any similar disclosure throughout the Registration Statement
and that it will provide the Staff with a response letter in the form of correspondence at least five business days before effectiveness.

    2

Comment
2 – Principal Investment Strategies

Please include the following disclosure,
in bold, in the section entitled “Principal Investment Strategies” for each Fund (as modified based on each Fund’s exposure):

 1. Any investment in the Fund is not an investment in AAPL.

 2. The Fund’s strategy will cap its potential gains if AAPL shares increase in value.

 3. The Fund’s strategy is subject to all potential losses if AAPL shares decrease in value, which may
not be offset by income received by the Fund.

 4. Fund shareholders are not entitled to AAPL dividends.

Response
to Comment 2

Pursuant to the Staff’s
comment, the referenced disclosures, modified as applicable, have been added to the sections entitled “Principal Investment Strategies.”

It is critical that investors understand
the following:

 1. An investment in the Fund is not an investment in AAPL.

 2. The Fund’s strategy is subject to all potential losses if AAPL shares decrease in value, and
may lose all of its value if shares of AAPL decrease by 83.33 percent over the course of any calendar week.

Comment
3 – Principal Investment Strategies

Please supplementally confirm
each of the following:

 1. Whether notional principal will always be equal to or larger than the call options the Fund is covering.

 2. Whether the purchased call options will always be equal to or longer than the sold call options the Fund
is covering.

 3. Whether the strike price of the purchased call options would ever be higher than that of the sold call
options the Fund covers and, if so, what the maximum difference in strike prices would be.

Response
to Comment 3

The Registrant has revised the
strategy of each Fund such that the Fund will not invest in options as part of its principal investment strategies. Instead, the Fund
will invest substantially in swap agreements to derive its exposure to the applicable underlying security. Accordingly, the Staff’s
comment is no longer applicable.

    3

Comment
4 – Principal Investment Strategies

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

This strategy effectively
converts a portion of the potential upside price return growth of AAPL into current income.

The strategy seeks to offset,
not convert, a portion of the potential upside into current income. Please revise accordingly.

Response
to Comment 4

The Registrant has revised the
strategy of each Fund such that the Fund will no longer pursue a covered call investment strategy. Accordingly, the Staff’s comment
is no longer applicable.

Comment
5 – Principal Investment Strategies

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

In addition to the options
contracts, the Fund will also invest in short-term U.S. Treasury securities and money market funds.

Please explain that these options
are used as collateral in connection with the Fund’s covered call strategy.

Response
to Comment 5

Pursuant to the Staff’s
comment, the referenced disclosure has been revised as follows:

In addition to the swap
agreements, the Fund will also invest in short-term U.S. Treasury securities, short-term U.S. Treasury ETFs, and money market funds that
will be used to collateralize such agreements. (emphasis added)

Comment
6 – Principal Investment Strategies

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

… AAPL is assigned
to the information technology sector.

Please specify the industry, in
addition to the sector, to which Apple is assigned.

    4

Response
to Comment 6

Pursuant to the Staff’s
comment, the referenced disclosure has been revised to disclosure the “industry group” for each of the Funds.

Comment
7 – Principal Investment Strategies

Please disclose in the
section entitled “Principal Investment Strategies” that the Fund intends to continuously obtain indirect exposure to
AAPL through the use of options contracts and that as the option contracts it holds are exercised or expire it may enter into new
options contracts, a practice referred to as “rolling,” and that the Fund’s practice of rolling may result in high
portfolio turnover.

Response
to Comment 7

The Registrant has revised the
strategy of each Fund such that the Fund will not invest in options as part of its principal investment strategies. Instead, the Fund
will invest substantially in swap agreements to derive its exposure to the applicable underlying security. Accordingly, the Staff’s
comment is no longer applicable as the concept, costs and risks of “rolling” options contracts is not present as it relates
to an automatic resetting of each Fund’s swap agreements.

Comment
8 – Principal Investment Strategies

Please disclose in the section
entitled “Principal Investment Strategies” the range of exposure to cash money market funds and treasuries held by the Fund,
the range of exposure to options, and whether, in terms of notional value, the combination of these investment instruments will provide
exposure to AAPL equal to at least 100% of the Fund’s total assets.

Response
to Comment 8

The Registrant supplementally
confirms that each Fund will hold cash and cash equivalents approximately equal to 100% of the Fund’s net assets. The Funds have
revised their investment strategy disclosure to indicate that a significant portion of s Fund’s investments will be held in cash
and cash equivalents but decline to indicate that approximately 100% of each Fund’s assets will be invested in such instruments
as they believe that would be confusing to an average investor who does not understand the collateral mechanics of a swap agreement.

Comment
9 – Principal Investment Strategies

Please disclose in the section
entitled “Principal Investment Strategies” that neither the Fund, the Trust, the Advisor, the Sub-Adviser nor their respective
affiliates make any representations to the investor as to the performance of AAPL.

    5

Response
to Comment 9

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

Lastly, neither the Fund, the Trust, the
Adviser nor the Sub-Adviser, nor any of their respective affiliates, make any representations investors as to the performance of AAPL.

Comment
10 – Principal Risks

The Staff notes “Information
Technology Companies Risk” set forth the section entitled “Principal Risks.” Please revise to add disclosure regarding
the industry to which AAPL is assigned.

Response
to Comment 10

The Registrant acknowledges the
Staff’s comment but respectfully declines to make the requested addition based upon unique practical considerations in certain circumstances.
While it is generally customary and proper for a fund to include industry-specific disclosure, the Funds are different because each currently
provides company-specific risk disclosure for the company to which they have exposure. This is a level of specificity that goes well-beyond
industry-specific disclosure. Furthermore, each Fund already contains disclosure relating to the broader sector to which that security
is assigned. This disclosure is designed to describe the broader risks to which a company in a certain sector is subject. In many instances,
the company-specific disclosure and the sector-level disclosure are already broadly similar, as one would expect. In certain instances,
providing disclosure that is slightly broader than company-specific and slightly narrower than sector-specific does not generally provide
anything different to disclose. Nevertheless, in instances where a Fund has an industry-level exposure that lends itself to unique disclosure,
such as the semiconductor industry, such disclosure has been included.

Comment
11 – Tax Information

The Staff notes the section entitled
“Tax Information.” It is the Staff’s understanding that the federal income tax treatment of certain aspects of the proposed
operations of the Funds are not entirely clear and, given the resulting implication of each Fund’s ability to qualify and maintain
RIC status, the ultimate tax treatment appears to be material to an informed investor. Therefore, please explain the technical merits
of the Fund’s tax position regarding its RIC status, any known views of the taxing authorities with respect to such positions, a
history of the taxing authority with respect to resolving fund tax issues with similar levels of technical support and any other relevant
information.

Response
to Comment 11

Pursuant to the Staff’s
comment, the section entitled “Principal Risks” has been revised to include the following risk factor:

SPECIAL
TAX RISK. The Fund intends to qualify annually and to elect to be treated as a regulated investment company under the Internal
Revenue Code of 1986, as amended (the “Code”). To qualify for the favorable U.S. federal income tax treatment generally accorded
to regulated investment companies, the Fund must, among other things, (i) derive in each taxable year at least 90% of its gross income
from dividends, interest, payments with respect to securities loans and gains from the sale or other disposition of stock, securities
or foreign currencies or other income derived with respect to its business of investing in such stock, securities or currencies, or net
income derived from interests in certain publicly traded partnerships; (ii) diversify its holdings so that, at the end of each quarter
of the taxable year, (a) at least 50% of the market value of the Fund’s assets is represented by cash and cash items (including
receivables), U.S. government securities, the securities of other regulated investment companies and other securities, with such other
securities of any one issuer generally limited for the purposes of this calculation to an amount not greater than 5% of the value of the
Fund’s total assets and not greater than 10% of the outstanding voting securities of such issuer, and (b) not more than 25% of the
value of its total assets is invested in the securities (other than U.S. government securities or the securities of other regulated investment
companies) of any one issuer, or two or more issuers which the Fund controls which are engaged in the same, similar or related trades
or businesses, or the securities of one or more of certain publicly traded partnerships; and (iii) distribute at least 90% of its investment
company taxable income (which includes, among other items, dividends, interest and net short-term capital gains in excess of net long-term
capital losses) and at least 90% of its net tax-exempt interest income each taxable year. There are certain exceptions for failure to
qualify if the failure is for reasonable cause or is de minimis, and certain corrective action is taken and certain tax payments are made
by the Fund.

    6

The authority with regard to swaps entered
into by regulated investment companies is unclear both as to the qualification under the income test and the identification of the issuer
under the diversification test. The Fund intends to take the position that because the swaps held by the Fund reference securities that
the income on the swaps are “other income” from the Fund’s business of investing in stocks and securities. In addition,
the Fund intends to manage its investments in the swaps so that neither the exposure to issuer of the referenced security nor the exposure
to any one counterparty of the swaps will exceed 25% of the gross value of the Fund’s portfolio at the end of any quarter.

If the Fund were to fail to meet the qualifying
income test or asset diversification test and fail to qualify as a RIC, it would be taxed in the same manner as an ordinary corporation,
and distributions to its shareholders would not be deductible by the Fund in computing its taxable income, which would adversely affect
the Fund’s performance.

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