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    Morrison Warren
    Chapman and Cutler LLP

    Partner
    320 South Canal Street, 27th Floor

    Chicago, Illinois  60606

    T 312.845.3484

    warren@chapman.com

February 19, 2025

VIA EDGAR CORRESPONDENCE

Jaea Hahn

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Re: REX ETF Trust (the “Registrant”),
on behalf of its series,

REX COIN Covered Call ETF, REX MSTR Covered Call ETF, REX NVDA

Covered Call ETF and REX TSLA Covered Call ETF

     File Nos. 333-283221; 811-24023

Dear Ms. Hahn:

This letter responds to your
comments provided via correspondence regarding the registration statement filed by the Registrant on Form N-1A (the “Registration
Statement”) with the staff of the Securities and Exchange Commission (the “Staff”) on November 14, 2024,
on behalf of REX COIN Covered Call ETF, REX MSTR Covered Call ETF, REX NVDA Covered Call ETF and REX TSLA Covered Call ETF (each, a “Fund”
and collectively, the “Funds”), each a series of the Registrant. Capitalized terms used but not defined herein
have the meanings ascribed to such terms in the Registration Statement. We are submitting via EDGAR this letter on behalf of the Funds,
which is intended to respond to your comments.

Comment
1 – General

The Staff notes that the Registration
Statement is missing information (e.g., information regarding service providers, trustees and management) and exhibits (e.g.,
seed financial statements of the Fund, bylaws and advisory contracts) and contains bracketed disclosures. The Staff may have additional
comments on such completed portions in any pre-effective amendment, on disclosures made in response to this letter, on information supplied
supplementally, or on exhibits filed in any pre-effective amendment. Please plan accordingly.

Response
to Comment 1

The Registrant acknowledges the Staff’s comment.

Comment
2 – General

Please confirm whether the
Registrant expects to submit any exemptive application(s) or no-action request(s) in connection with the Registration Statement.

Response
to Comment 2

The Registrant does not anticipate
submitting any exemptive relief applications at this time.

Comment
3 – General

Supplementally, please explain
if a party (other than a Fund’s sponsor or one of its affiliates) is providing the Fund’s initial (seed) capital. If yes,
please supplementally identify the party providing the seed capital and describe their relationship with the Fund.

Response
to Comment 3

The Registrant confirms that
the Adviser, or one of its affiliates, will provide the Fund’s initial (seed) capital.

Comment
4 – General

Please explain whether the
Registrant’s and Adviser’s Code of Ethics (“Codes”) address investments in ETFs that provide exposure to
a single corporate issuer (“Single Name ETFs”). If these investments are excluded from either of these Codes, please
advise whether the Codes will be amended to account for Single Name ETFs, including Single Name ETFs that are not advised by the Adviser
and/or the sub-adviser. If not, please advise how excluding Single Name ETFs from reporting requirements is consistent with the Registrant’s
obligations to implement procedures reasonably designed to prevent violations of the federal securities laws.

Response
to Comment 4

The Registrant confirms that
Single Name ETFs will not be excluded from the Registrant’s and Adviser’s Codes.

Comment
5 – REX COIN Covered Call ETF – Summary Prospectus – Fees and Expenses of the Fund

Please provide a completed
fee table and expense example for the Staff’s review and comment. Supplementally, confirm there will be no fee waiver or expense
limitation agreement in place.

Response
to Comment 5

A completed fee table and
expense examples applicable to each Fund has been attached hereto as Exhibit A. The Registrant confirms there will be no fee waiver or
expense limitation agreement in place for the Funds.

Comment
6 – REX COIN Covered Call ETF – Summary Prospectus – Principal Investment Strategies

The Staff notes that the disclosure
in this section states that the Fund intends to achieve exposure to the share price of COIN “through direct holdings of COIN shares
or by utilizing options contracts that provide exposure to the price return of COIN.” The Staff also notes that the Fund intends
to invest at least 80% of its net assets in shares of COIN or derivative instruments that provide exposure to COIN. What percent of its
assets does the Fund intend to invest directly in COIN shares? Please supplementally explain. In the response, please also explain how
the Fund’s intended strategy and disclosures are and will be consistent with Rule 140 under the Securities Act of 1933 (the “1933
Act”).

Response
to Comment 6

The Registrant believes COIN
(or any other underlying issuers) should not be considered co-registrants under Rule 140 of the 1933 Act. Rule 140 provides:

“A person, the chief part of whose business
consists of the purchase of the securities of one issuer, or of two or more affiliated issuers, and the sale of its own securities . .
. to furnish the proceeds with which to acquire the securities of such issuer or affiliated issuers, is to be regarded as engaged in the
distribution of the securities of such issuer or affiliated issuers within the meaning of section 2(11) of the [1933 Act].”

Rule 140 only applies to
the extent that the “chief part” of a company’s business consists of selling its securities and utilizing the proceeds
to purchase the securities of a single issuer or affiliated issuers. Rule 140 does not set forth any standard for identifying the “chief
part” of the issuer’s business. However, the Staff has provided that “chief part” indicates an investment of
greater than 45% of a fund’s assets in the securities of a particular issuer.1 The Registrant confirms that each Fund’s
investments in securities of the respective underlying issuer will be below the 45% threshold previously detailed by the Staff. The remainder
of each Fund’s assets will be invested in options contracts and/or swaps that provide exposure to the price return of the underlying
issuer’s securities and short-term U.S. Treasury securities, which will be used as income to the Fund as well as collateral in
connection with the Fund’s use of options contracts and swaps. Rule 140, which relates to the purchase of securities of an issuer,
would not apply to a Fund’s investments in derivatives that reference the corresponding issuer’s securities. Furthermore,
the Fund cannot be deemed to be engaged in an underwriting of the relevant underlying issuer’s shares because it is not purchasing
the underlying issuer’s securities from the underlying issuer, but rather in the secondary market.

 1 See FBC
                                            Conduit Trust I, SEC No-Action Letter (Oct. 6, 1987).

Comment
7 – REX COIN Covered Call ETF – Summary Prospectus – Principal Investment Strategies

In the second paragraph:

 a. Please clarify the disclosure to explain what combination of options the Fund intends to purchase and
sell to create the desired exposure to COIN and how each type of option will be used to carry out the Fund’s strategy. For example,
please describe the suite of options to be purchased/sold by the Fund, at what strike prices, and explain how the Fund’s covered
call strategy will create the desired exposure to the underlying issuer and generate income or losses for the Fund.

 b. In the second sentence, please clarify what “utilizing options contracts that provide exposure to
the price return of COIN” means. Is this a reference to purchased call options?

 c. Please briefly explain what a “covered call strategy” is in plain English. Please clarify
if the Fund will implement a traditional covered call strategy where the Fund will sell a call option on an underlying security it owns
or if the Fund intends to use a synthetic covered call strategy. If the Fund intends to use a synthetic covered call strategy, please
describe this strategy in greater detail.

 d. Please clarify if the Fund intends to continuously maintain direct and indirect exposure to COIN
(e.g., by holding COIN shares and through options contracts). What are the expected target maturities for the different option
contracts that the Fund invests in? As the options contracts the Fund holds are exercised or expire, will it enter into new option contracts
(e.g., engage in “rolling”)? If so, please disclose that the rolling of options may result in high portfolio turnover.

 e. Because the Fund’s primary investment objective is to produce current income, please disclose how
often the Fund will provide distribution payments to shareholders (e.g., monthly or weekly).

Response
to Comment 7

The disclosure has been revised
in accordance with the Staff’s comment. Please refer to Exhibit B attached hereto for the revised “Principal Investment Strategies”
section.

Comment
8 – REX COIN Covered Call ETF – Summary Prospectus – Principal Investment Strategies

In the third paragraph, please
clarify that options contracts must be exercised or traded to close within a specified time frame, or they expire.

Response
to Comment 8

The disclosure has been revised
in accordance with the Staff’s comment. Please refer to Exhibit B attached hereto for the revised “Principal Investment Strategies”
section.

Comment
9 – REX COIN Covered Call ETF – Summary Prospectus – Principal Investment Strategies

In the fourth paragraph, the
disclosure states that the Fund will hold short-term U.S. Treasury securities as collateral in connection with the Fund’s use of
options.

 a. Please disclose any target percentage or limit on the Fund’s assets that will be invested, under
normal circumstances, in COIN shares, cash and treasuries, and options, respectively.

 b. Please clarify whether the short-term U.S. Treasury securities may also generate income in addition to
serving as collateral.

 c. In the fifth paragraph, please clarify when, if at all, the Fund may take temporary defensive positions
under any circumstances. The current disclosure only addresses periods of adverse market, economic, or other conditions.

Response
to Comment 9

The disclosure has been revised
in accordance with the Staff’s comment. Please refer to Exhibit B attached hereto for the revised “Principal Investment Strategies”
section.

Comment
10 – REX COIN Covered Call ETF – Summary Prospectus – Principal Investment Strategies

In the sixth paragraph:

 a. Please revise the statement that “any investment in the Fund is not an investment in COIN”
to more appropriately reflect a Fund investor’s exposure to COIN, particularly since the second paragraph states that the Fund will
“achieve exposure to the share price of COIN through direct holdings of COIN shares…”

 b. Please confirm that the last sentence is accurate if the Fund directly holds COIN shares. Is it possible
that the Fund’s income may include dividends from shares of COIN that it holds directly?

 c. Please add, if accurate, disclosure that states that the Fund’s performance will differ from that
of COIN’s stock price and that the performance differences will depend on, among other things, the price of COIN, changes in the
value of the COIN options contracts the Fund holds, and changes in the value of the U.S. Treasuries the Fund holds.

Response
to Comment 10

The disclosure has been revised
in accordance with the Staff’s comment. Please refer to Exhibit B attached hereto for the revised “Principal Investment Strategies”
section.

Comment
11 – REX COIN Covered Call ETF – Summary Prospectus – Coinbase Global, Inc.

In the second paragraph under
Coinbase Global, Inc., please confirm the file number associated with Coinbase Global, Inc., currently shown as 001-04321, is correct.

Response
to Comment 11

The Registrant confirms the
Registration Statement has been updated to reflect the correct file number associated with each underlying issuer.

Comment
12 – REX COIN Covered Call ETF – Summary Prospectus – Coinbase Global, Inc.

Please briefly enhance and
contextualize the disclosure related to Coinbase’s business, by providing an explanation of blockchain technology and crypto assets.
Please include the following disclosure with regard to public, permissionless blockchains:

 · Their general design and purpose;

 · How they are developed, maintained, and governed;

 · How they are accessed and used;

 · The relationship between them and their native crypto assets; and

 · The specific use cases and applications that they support or are designed to support.

Response
to Comment 12

The Registrant respectfully
declines to include the additional suggested disclosure in the “Principal Investment Strategies” section as such concepts
are already disclosed in “Coinbase Global, Inc. Investing Risks,” which the Registrant believes is the more appropriate location
for such disclosure.

Comment
13 – REX COIN Covered Call ETF – Summary Prospectus – Principal Risks

For clarity and to increase
investor comprehension, please consider reorganizing (i) the presentation so that related risks are grouped together but separated under
subheadings (e.g., ETF operational risks); and (ii) lengthy risk disclosure, such as Coinbase Global, Inc. Investing Risk, into
one risk with multiple sub-risks. Additionally, the risks should appear in order of importance rather than alphabetically. See
ADI 2019-08 - Improving Principal Risks Disclosure.

Response
to Comment 13

The Registrant has reviewed
each Fund’s risk disclosures to ensure that such disclosures are tailored appropriately to each Fund’s principal risks, not
overly lengthy or technical, and that the risks the Staff would consider most significant are not obscured or constructed in a manner
that could render the disclosure misleading. Additionally, the Registrant believes that listing the risk disclosures alphabetically allows
each Fund to be consistent in its presentation, provides better comparability and eliminates any subjective arguments as to the importance
of certain risk disclosures. As such, the Registrant respectfully declines the Staff’s request.

While the Registrant respectfully
declines to reorder the Funds’ principal risks, the Registrant notes that the following disclosure is included in the first paragraph
under “Principal Risks” in each Fund’s summary section, with similar language included in response to Item 9 of Form
N-1A, to help investors understand the importance of reading each risk disclosure regardless of their sequence:

“Each risk summarized below is considered
a principal risk of investing in the Fund, regardless of the order in which it appears. The significance of each risk factor below may
change over time and you should review each risk factor carefully.”

Comment
14 – REX COIN Covered Call ETF – Summary Prospectus – Principal Risks

Please consider moving the
section entitled “Indirect Investment Risk” to the beginning of the Principal Risk disclosure as this disclosure highlights
the Fund’s relationship with Coinbase Global, Inc. and the Coinbase Global, Inc. Investing Risk appears first in the Principal Risk
section.

Response
to Comment 14

In accordance with the Staff’s
comment, the “Indirect Investment Risk” has been moved to immediately follow the “Coinbase Global, Inc. Investing Risks.”

Comment
15 – REX COIN Covered Call ETF – Summary Prospectus – Principal Risks

Please add a risk related
to price participation. This added risk would clarify that investing in the Fund is not equivalent to investing in COIN. It would also
clarify that the Fund’s investment strategy to sell call option contracts will limit participation in any gains in the share price
of COIN while leaving the Fund fully exposed to any decreases in value experienced by COIN over the call period. Please also explain how
the Fund’s net asset value (“NAV”) will correlate on a day-to-day basis with the returns of COIN.

Respo