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CORRESP
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  Morrison Warren

  Chapman and Cutler LLP

  Partner

  320 South Canal Street, 27th Floor

  Chicago, Illinois 60606

  (312) 845-3484

  warren@chapman.com

May 1, 2025

VIA EDGAR CORRESPONDENCE

Ashley Vroman-Lee

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 Ms. Vroman-Lee:

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 April 11, 2025 (the “Registration
Statement”). The Registration Statement relates to the Roundhill ABNB WeeklyPayTM ETF, Roundhill ARM WeeklyPayTM
ETF, Roundhill ASML WeeklyPayTM ETF, Roundhill AVGO WeeklyPayTM ETF, Roundhill BABA WeeklyPayTM ETF,
Roundhill BRKB WeeklyPayTM ETF, Roundhill COST WeeklyPayTM ETF, Roundhill CRWD WeeklyPayTM ETF, Roundhill
DKNG WeeklyPayTM ETF, Roundhill HOOD WeeklyPayTM ETF, Roundhill JPM WeeklyPayTM ETF, Roundhill LMT WeeklyPayTM
ETF, Roundhill MSTR WeeklyPayTM ETF, Roundhill NFLX WeeklyPayTM ETF, Roundhill RDDT WeeklyPayTM ETF,
Roundhill SHOP WeeklyPayTM ETF, Roundhill SPOT WeeklyPayTM ETF, Roundhill TSM WeeklyPayTM ETF, Roundhill
UBER WeeklyPayTM ETF and Roundhill XOM WeeklyPayTM 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 – General

For each applicable Fund, please
disclose whether there is a likelihood or a risk that weekly payments may not be made, if accurate.

Response
to Comment 1

Each Fund’s strategy has
been designed so that the Fund will make weekly distributions under all circumstances. The only thing that will change based upon prevailing
market conditions is the amount of the distributions. Absent an extraordinary event (such as the closure of a Fund), it is not currently
expected that the Funds will not make weekly distribution payments.

Comment
2 – Fee Table

Please supplementally provide
a completed fee table for each Fund sufficiently in advance of effectiveness for the Staff’s review. If the fee table is the same
for each Fund, please note when providing the completed fee table.

Response
to Comment 2

Pursuant to the Staff’s
comment, a completed fee table has been set forth on Exhibit A. This fee table will be the same for each Fund.

Comment
3 – Current Market Conditions Risk

Within the “Current Market
Conditions Risk,” please include trade restrictions (i.e. tariffs) on any country that could have a significant effect on
the reference asset for each Fund.

Response
to Comment 3

Pursuant to the Staff’s
comment, “Current Market Conditions Risk” and “Market Risk” have been revised to include disclosure relating the
potentially negative impact on the Funds of tariffs.

Comment
4 – Derivatives Risk

Please include a separate “Swap
Risk” unless a Fund will be using additional derivatives. If a Fund will be using additional derivatives, please include updated
disclosure for each Fund in the “Principal Investment Strategies” section.

Response
to Comment 4

The Registrant respectfully directs
the Staff’s attention to “Swap Agreements Risk,” set forth in each Fund’s prospectus. The risk appears outside
of alphabetical order in the front of the section entitled “Principal Risks” as the Adviser has deemed this risk to be especially
relevant to potential investors. The only derivative the Funds currently intend to utilize are swaps.

Comment
5 – Performance

Please supplementally disclose
each Fund’s appropriate broad-based securities market index.

Response
to Comment 5

Each Fund will use the Solactive
GBS Global Markets All Cap USD Index TR as its broad-based securities market index.

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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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Exhibit A

Annual Fund Operating Expenses (expenses that you pay each year
as a percentage of the value of your investment)

    Management Fees(1)
    0.99%

    Distribution and Service (12b-1) Fees
    0.00%

    Other Expenses(2)
    0.00%

    Total Annual Fund Operating Expenses
    0.99%

 (1) The investment advisory agreement between the Trust and Roundhill
Financial Inc. (“Roundhill”) utilizes a unitary fee arrangement pursuant to which Roundhill will pay all operating expenses
of the Fund, except Roundhill’s management fees, interest charges on any borrowings (including net interest expenses incurred in
connection with an investment in reverse repurchase agreements or futures contracts), dividends and other expenses on securities sold
short, taxes, brokerage commissions and other expenses incurred in placing orders for the purchase and sale of securities and other investment
instruments (including any net account or similar fees charged by futures commission merchants), accrued deferred tax liability and extraordinary
expenses.

 (2) “Other Expenses” are estimates based on the expenses
the Fund expects to incur for the current fiscal year.

Example

This example is intended to help
you compare the cost of investing in the Fund with the cost of investing in other funds. The example assumes that you invest $10,000 in
the Fund for the time periods indicated, and then sell all of your Fund Shares at the end of those periods. The example also assumes that
your investment has a 5% return each year and that the Fund’s operating expenses remain the same. Although your actual costs may
be higher or lower, based on these assumptions your costs would be:

    Year 1
    Year 3

    $101
    $315

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