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    Morrison Warren

    Partner

    Chapman and Cutler LLP

    320 South Canal Street, 27th Floor

    Chicago, Illinois 60606

    T 312.845.3484

    warren@chapman.com

April 14, 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
additional comments provided on March 25, 2025, 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,
and amended on February 19, 2025, 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.

The Registrant is also informing
the Staff that changes have been made to each Fund’s principal investment strategies, that in addition to each Fund’s covered
call strategy, each Fund will seek to have leveraged notional exposure of between 105% and 125% to the common stock of the Fund’s
applicable underlying security for a single day (the “Strategy Revisions”). In accordance with the Strategy Revisions,
the names of the Funds will be revised as follows:

    Old Name
    New
    Name

    REX COIN Covered Call ETF
    REX COIN Growth & Income ETF

    REX MSTR Covered Call ETF
    REX MSTR Growth & Income ETF

    REX NVDA Covered Call ETF
    REX NVDA Growth & Income ETF

    REX TSLA Covered Call ETF
    REX TSLA Growth & Income ETF

Comment
1 – General

Please provide the Staff with
the seed capital financial statements for the Funds.

Response
to Comment 1

The Registrant notes the seed
capital financial statements for the Funds will be included in an amended Registration Statement filing.

Comment
2 – Principal Investment Strategies

The Staff notes the disclosure
states, “To achieve long exposure to COIN, the Fund will directly purchase shares of COIN. Alternatively, to achieve synthetic long
exposure to COIN, the Fund will purchase COIN call options and, simultaneously, sell COIN put options to seek to replicate the price movements
of COIN.” Please consider rephrasing this disclosure to explain what the Fund will do under normal circumstances.

Response
to Comment 2

The Registrant notes the disclosure
has been revised in light of the Strategy Revisions. The Registrant will provide blackline copies of the revisions to the Staff under
separate cover.

Comment
3 – Principal Investment Strategies

Please disclose if there is
an upper limit to the notional exposure to COIN. Please also disclose what exposures are expected in terms of the Fund’s net assets.

Response
to Comment 3

The Registrant notes the disclosure
has been revised in light of the Strategy Revisions. The Registrant will provide blackline copies of the revisions to the Staff under
separate cover.

Comment
4 – Principal Investment Strategies

Please revise the SEC file
number for Coinbase Global, Inc. to “001-40289.”

Response
to Comment 4

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

Comment
5 – Principal Risks

The Staff notes the SEC dismissed
the enforcement actions brought against Coinbase Global, Inc. Please update the “Coinbase Global, Inc. Regulatory Risk” as
necessary.

Response
to Comment 5

The Registrant confirms the
“Coinbase Global, Inc. Regulatory Risk” has been removed from the Registration Statement.

* * * * * * * * * * * * * * *
* * * * * *

Please call me at (312) 845-3484
if you have additional comments or wish to discuss any of the foregoing responses. Thank you.

    Very truly yours,

    Chapman and Cutler llp

    By:
    /s/ Morrison C. Warren

    Morrison C. Warren, Esq.

cc:      	Gregory King, Chief Executive Officer,
REX Advisers, LLC