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CORRESP
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 Morrison Warren

 Partner
 Chapman and Cutler LLP

 320 South Canal Street, 27th Floor

 Chicago, Illinois 60606

 (312) 845-3484

 warren@chapman.com

 November 24, 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 September 30, 2025 (the "Registration
Statement" ). The Registration Statement relates to Roundhill APP WeeklyPay™ ETF, Roundhill ORCL WeeklyPay™ ETF,
Roundhill UNH WeeklyPay™ ETF, and Roundhill WMT WeeklyPay™ 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

 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.

 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.

 Comment 2
– Cover Page

 On the cover page, please disclose
that over time a Fund's returns could vary in amount and direction from the stated multiple. The cover page should also state that
the Adviser intends for all or a significant portion of a Fund's weekly distributions to be characterized as "return of capital"
but cannot make assurances that this will be the case.

 Response
to Comment 2

 Pursuant to the Staff's
comment, the following disclosures have been added to the cover page:

 Over time, a Fund's
returns could vary an amount and direction from the stated multiple.

 The Adviser intends for
all or a significant portion of a Fund's weekly distributions to be characterized as return of capital but cannot make assurances
that this will be the case.

 Comment
3 – Principal Investment Strategies

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

 In addition to providing
1.2 times (120%) exposure to the total return of APP shares over a given calendar week, the Fund will make weekly distribution payments
to shareholders.

 As this is the primary objective
of the Fund, please move this sentence earlier in the disclosure. Additionally, please include the secondary objective following the disclosure
above.

 Response
to Comment 3

 The referenced disclosure has
been revised in accordance with the Staff's comment.

 Comment
4 – Principal Investment Strategies

 In the "Principal Investment
Strategies" section, please explain that a "return of capital" is neither income nor profit but rather represents a
return of the shareholder's investment.

 Response
to Comment 4

 Pursuant to the Staff's
comment, the following disclosure set forth in the section entitled "Principal Investment Strategies" has been revised as
follows:

 The Adviser intends for
 all or a significant portion of the Fund's weekly distributions to be characterized as return of capital, though
it can make no assurances this will be the case . Return of capital is neither income nor profit. 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.

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 Comment
5 – Principal Investment Strategies

 In the "Principal Investment
Strategies," section, please make clear in the disclosure that not only a significant portion of the distributions could be characterized
as a return of capital but that all of the distributions could be characterized as such.

 Response
to Comment 5

 The Staff's comment has
been addressed in Response to Comment 4.

 Comment
6 – Principal Investment Strategies

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

 It is critical
that investors understand the following :

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

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

 Please also state that it is critical
that investors understand that all or a substantial portion of the weekly distributions may be a return of capital.

 Response
to Comment 6

 The referenced disclosure has
been revised in accordance with the Staff's comment.

 ********

 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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