SecProbe.io

CORRESP
 1
 filename1.htm

 Morrison Warren

 Partner
 Chapman and Cutler LLP

 320 South Canal Street, 27th Floor

 Chicago, Illinois 60606

 (312) 845-3484

 warren@chapman.com

 August 26, 2025

 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 June 20, 2025 (the "Registration
Statement" ). The Registration Statement relates to the Roundhill WeeklyPay TM Universe ETF (the "Fund" ),
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 – Cover Page

 Please include cover page disclosure
presented by the underlying funds.

 Response
to Comment 1

 Pursuant to the Staff's
comment, the cover page has been revised accordingly.

 Comment
2 – Principal Investment Strategies

 Please disclose that each underlying
WeeklyPay TM Fund provides exposure to a single company and list the current company in which each underlying WeeklyPay TM
Fund invests.

 Response
to Comment 2

 P ursuant
to the Staff's comment, the following disclosure has been added to the section entitled "Additional Information Regarding
the Fund's Investment Strategies":

 Each WeeklyPay TM
Fund provides exposure to a single company. As of ________, 2025, the Index was composed of the constituents set forth below. Please note
that these are subject to change. For a more up-to-date version of the Fund's holdings, please visit the Fund's website.

 Comment
3 – Principal Investment Strategies

 Please disclose whether there
is any risk that the Fund may not make a weekly distribution payment. Please disclose whether distributions will be paid even if the Fund,
the reference asset or the underlying swap is losing money. If the Fund may forgo a weekly distribution payment based upon prevailing
market conditions, please change the name of the Fund, as the Staff believes such name would be misleading.

 Response
to Comment 3

 The Registrant intends to make
a weekly distribution payment regardless of market conditions, including in the unlikely scenario in which each of the Fund's WeeklyPay TM
Fund holdings makes no distribution. While prevailing market conditions will affect the amount of such distribution from week to week,
the entire premise of the Fund's principal investment strategy, and thus the Fund's name, is that the Fund will make a weekly
distribution payment.

 Comment
4 – Principal Investment Strategies

 Please supplementally inform the
Staff whether the Fund plans to disclose an estimate or historical payout in its marketing materials.

 Please disclose whether the Fund
expects the payment of the weekly distribution to be ordinary income or return of capital. If it intends for a significant portion to
be a return of capital, please disclose that return of capital represents a return of a portion of a shareholder's invested capital
and is not taxable in the year that it is received unless the distribution exceeds such shareholder's basis in the Fund; however,
return of capital may result in an increase in the later gain in the sale of the Fund's shares.

 Response
to Comment 4

 The Registrant confirms that the
Fund plans to disclose a historical payout in its marketing materials.

 The Registrant expects that a
substantial portion of the Fund's weekly distribution to consist of return of capital. However, the Fund will not know that for
certain until the end of the year. Disclosure regarding return of capital is set forth in "Distribution Tax Risk," which is
reproduced below.

 DISTRIBUTION TAX RISK .
The Fund currently expects to make distributions on a weekly basis. Such frequent distributions may expose investors to increased tax
liabilities. However, these distributions may exceed the Fund's income and gains for the Fund's taxable year. Distributions
in excess of the Fund's current and accumulated earnings and profits will be treated as a return of capital. A return of capital
distribution generally will not be taxable but will reduce the shareholder's cost basis and will result in a higher capital gain
or lower capital loss when those Fund Shares on which the distribution was received are sold. Once a Fund shareholder's cost basis
is reduced to zero, further distributions will be treated as capital gain if a Fund shareholder holds Fund Shares as capital assets. Additionally,
any capital returned through distributions will be distributed after payment of Fund fees and expenses. Because a portion of the Fund's
distributions may consist of return of capital, the Fund may not be an appropriate investment for investors who do not want their principal
investment in the Fund to decrease over time or who do not wish to receive return of capital in a given period. In the event that a shareholder
purchases Fund Shares shortly before a distribution by the Fund, the entire distribution may be taxable to the shareholder even though
a portion of the distribution effectively represents a return of the purchase price.

 2

 Comment
5 – Principal Investment Strategies

 Please confirm that the Fund will
use a relative VaR test under Rule 18f-4.

 Response
to Comment 5

 The Registrant confirms that the
Fund will only have exposure to shares of the underlying WeeklyPay TM Funds. Therefore, Rule 18f-4 is not applicable to the
Fund.

 Comment
6 – Principal Investment Strategies

 Please supplementally provide
the Index's methodology and current holdings.

 Please also disclose whether the
Fund will be concentrated and, if so, in what industries.

 Response
to Comment 6

 The Registrant confirms that it
will provide the Staff with the Index's methodology and current holdings.

 With respect to the second portion
of the Staff's comment, the Registrant respectfully points the Staff the following disclosure set forth in the section entitled
"Principal Investment Strategies":

 The Fund will be concentrated
(i.e. hold 25% or more of its total assets) in an industry or a group of industries to the extent that the Index is so concentrated.

 3

 Comment
7 – Principal Risks

 Please consider whether "Indirect
Investment Risk" should be added as a principal risk of the Fund.

 Response
to Comment 7

 Pursuant to the Staff's
comment, "Indirect Investment Risk" has been added as a principal risk of the Fund.

 Comment
8 – Principal Risks

 In response to Item 9 of Form
N-1A, please consider elaborating on the risks of investing in each of the securities in the underlying WeeklyPay TM Funds.

 Response
to Comment 8

 The Registrant has thoughtfully
considered the Staff's comment and respectfully declines to revise the existing risk disclosure to include company-specific disclosure
for each company that an underlying WeeklyPay TM Fund provides exposure. Due to the number of Index components, the risk of
an exposure to any particular company does not constitute a principal risk of the Fund.

 Comment
9 – Statement of Additional Information

 The Staff notes the concentration
policy set forth in the section entitled "Investment Objective and Policies" in the Statement of Additional Information. Please
disclose the industries in which the Fund is concentrated, if any, as of June 30 (or a more recent date) and disclose that the Fund considers
the underlying investments of other investment companies when determining compliance with its concentration policy.

 Response
to Comment 9

 Pursuant to the Staff's
comment, the Fund will add the following disclosure to the Statement of Additional Information:

 Additionally, as it relates to the fundamental
policy set forth in (7) above, the Fund will consider the underlying investments of other investment companies when determining compliance
with its concentration policy.

 The Fund respectfully declines
to include the Fund's current concentration, if any, in the Statement of Additional Information as such information is included
in the summary section of the Prospectus.

 4

 *
* * * * * * *

 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

 5