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        Chapman and Cutler LLP

320 South Canal Street, 27th Floor

Chicago, Illinois 60606

T 312.845.3000

F 312.701.2361

www.chapman.com

November 8, 2023

Mark Cowan

U.S. Securities and Exchange Commission

Division of Investment Management

Disclosure Review Office

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    FT 11097

    Cboe Vest Regional Banking Buffered 20 Portfolio

    (the “Trust”)

    CIK No. 1989593 File No. 333- 274717

Dear Mr. Cowan:

We received your comments
regarding the Registration Statement for the above captioned Trust. This letter serves to respond to your comments.

Comments

Cover Page

1.Please
revise the “before” and “after” parentheticals relating to the cap and buffer amounts throughout the prospectus
to remove the reference to the Trust’s annual operating expenses.

Response:In accordance with
the Staff’s comment, the disclosure has been revised accordingly.

Portfolio

2.Please
include a statement the Trust’s portfolio is concentrated in investments that provide exposure to the banking sector.

Response:In accordance with
the Staff’s comment, the Trust has added the following disclosure to the “Objective” section of the prospectus:

The Trust is concentrated (i.e., invests 25% or
more of Trust assets) in investments that provide exposure to the banking sector.

Additionally, the Trust has added
the following risk factor immediately preceding the “Banking Companies Risk”:

Concentration Risk. When 25% or more of
a trust’s portfolio is invested in securities that provide exposure to companies within a single sector, the trust is considered
to be concentrated in that particular sector. A portfolio concentrated in one or more sectors may present more risks than a portfolio
broadly diversified over several sectors.

The Trust is concentrated in investments that
provide exposure to the banking sector.

3.The
Staff notes the disclosure states, “Under normal market conditions, the Trust will invest at least 80% of its net assets in investments
that provide exposure to banking companies.” Please revise “banking companies” to “regional banking companies”
to better align with the Trust’s name and provide a definition of “regional banking companies.”

Response:In accordance with
the Staff’s comment, the disclosure has been revised as follows:

Under normal market conditions, the Trust will
invest at least 80% of its net assets in investments that provide exposure to regional banking companies, which are those companies included
in the Underlying Index (as defined below).

4.The
Staff notes the SPDR S&P Regional Banking ETF (the “Underlying ETF”) filed a supplement dated June 21, 2023 to add additional
detail regarding regional bank risk. Please add corresponding disclosure to the Trust’s prospectus to better align with the disclosure
of the Underlying ETF.

Response:In accordance with
the Staff’s comment, the “Banking Companies Risk” has been replaced in its entirety with the following disclosure:

Banking Companies Risk. The performance
of bank stocks may be affected by extensive governmental regulation, which may limit the amounts and types of loans and other financial
commitments they can make, the interest rates and fees they can charge, and the amount of capital they must maintain. The impact of changes
in regulations and capital requirements on a banking company cannot be predicted and may negatively impact such banking company. Profitability
is largely dependent on the availability and cost of capital funds, and can fluctuate significantly when interest rates change. Credit
losses resulting from financial difficulties of borrowers can negatively impact banking companies. Banks may also be subject to severe
price competition. Competition is high among banking companies and failure to maintain or increase market share may result in lost market
value.

Regional Bank Risk. Investments in regional
banks, which may be small or medium in size, may involve greater risk than investing in larger, more established banks. Securities of
regional banks are often less liquid and subject to greater volatility and less trading volume than is customarily associated with securities
of larger banks. A regional bank’s financial performance may be dependent upon the business environment in certain geographic regions
of the United States and, as a result, adverse economic or employment developments in such regions may negatively impact such regional
bank and, in turn, the Underlying ETF.

Additionally, the Trust has updated
its disclosure in “The Underlying ETF and the Underlying Index” section to align with the Underlying ETF’s most recent
amendment to its registration statement.

5.The
Staff notes the addition of the “Futures Contract Risk” for the Trust. Please confirm whether this risk is unique to the Trust
or if the Sponsor’s other defined outcome UITs should include this risk.

Response: The
Trust confirms that “Futures Contract Risk” is unique to the Underlying ETF for this Trust, and is therefore only applicable
to the Trust.

6.Please
explain why the “Futures Contract Risk” is more prominent in the “Risks Factors” section of the prospectus.

Response:The
Trust notes the ordering of risk factors generally corresponds to the order of risks of the Underlying ETF and the risks of the Underlying
ETF are grouped together. As such, the Trust believes the current ordering of risk factors is appropriate.

We appreciate your prompt attention
to this Registration Statement. If you have any questions or comments or would like to discuss our responses to your questions, please
feel free to contact Brian D. Free at (312) 845-3017 or the undersigned at (312) 845-3721.

    Very truly yours,

    Chapman and Cutler llp

    By:
    /s/ Daniel J. Fallon

    Daniel J. Fallon