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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

May 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 Growth & Income ETF, REX MSTR Growth & Income ETF,

REX NVDA Growth & Income ETF and REX TSLA Growth & Income
ETF

File Nos. 333-283221; 811-24023

Dear Ms. Hahn:

This letter responds to your
additional comments provided on May 12, 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,
amended on February 19, 2025, and amended again on April 14, 2025, on behalf of REX COIN Growth & Income ETF, REX MSTR Growth &
Income ETF, REX NVDA Growth & Income ETF and REX TSLA Growth & Income 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 reminds the Funds
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 – Principal Investment Strategies

Please supplementally confirm
to the Staff that each Fund will employ a covered call strategy, particularly since each Fund will now have leveraged exposure to its
underlying reference security.

Response
to Comment 2

The Registrant confirms each
Fund’s portfolio will consist of leveraged long exposure to the respective underlying reference security and each Fund will also
employ a covered call writing strategy, whereby call options will be sold against the leveraged portion of the strategy which allows each
Fund to generate income. Please refer to the Registrant’s responses to Comment 5 and Comment 6 below for additional information.

Comment
3 – Principal Investment Strategies

Please supplementally confirm
to the Staff if each Fund intends to invest in more than 45% of its net asset value in the underlying reference security directly.

Response
to Comment 3

The Registrant confirms that
each Fund’s direct investments in its underlying reference security will be below the 45% threshold previously detailed by the Staff.

Comment
4 – Principal Investment Strategies

Please supplementally confirm
to the Staff that each Fund’s 80% investment policy remains accurate, specifically with respect to “income-producing investments.”

Response
to Comment 4

The Registrant confirms each
Fund’s 80% investment policy is accurate.

Comment
5 – Principal Investment Strategies

Please supplementally confirm
to the Staff that each Fund’s written options will be fully covered.

Response
to Comment 5

The Registrant confirms each
Fund’s written call options will be fully covered, such that the notional amount of the underlying reference security exposure (from
its direct holdings, options contracts, and/or swap agreements) will be at least equal to the notional amount of the underlying reference
security which underlies the written call options. The Registrant notes REX Advisers, LLC, each Fund’s investment adviser (the “Adviser”),
has designed each Fund to maintain this coverage and ongoing portfolio management ensures that the coverage will be maintained as market
conditions and exposures change. Please refer to the Registrant’s response to Comment 6 below for additional information.

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Comment
6 – Principal Investment Strategies

Please supplementally confirm
to the Staff that each Fund’s call writing strategy will not have the effect of reducing the stated exposure to the respective underlying
reference security.

Response
to Comment 6

The Registrant notes the Adviser
will utilize a covered call writing strategy, which involves selling call options on the respective underlying reference security while
simultaneously holding a corresponding long position in that security. The Adviser will carefully consider the delta of the options contracts
when implementing this strategy, such that the delta of the deep in-the-money call options contract (or combination of the purchased and
sold at-the-money call and put options contracts) produces a targeted leverage amount between 105% and 150% of the Fund’s NAV. The
delta represents the sensitivity of the option’s price to changes in the price of the underlying security and, in this context,
is used to manage the Fund’s overall exposure to the underlying reference security.

The call writing strategy
is not intended to reduce each Fund’s stated exposure to the underlying reference security. Rather, the strategy is designed to
generate additional income through the premiums received from selling call options, while maintaining each Fund’s targeted exposure.
Each Fund will continue to maintain its stated exposure to the underlying reference security within the range of 105% to 150% of the notional
exposure for a single day. The Adviser will actively manage the portfolio to ensure that each Fund’s exposure remains within this
range, taking into account the impact of the call options’ deltas. Therefore, the call writing strategy is implemented in a way
that preserves each Fund’s intended exposure to the underlying reference security, and the Adviser does not anticipate that this
strategy will have the effect of reducing such exposure.

Comment
7 – Principal Investment Strategies

The Staff notes the disclosure
states, “Fund shareholders will not have voting rights or rights to receive dividends or other distributions or any other rights
with respect to COIN.” Please supplementally confirm to the Staff that Fund shareholders will not have the right to receive dividends,
even if the Fund directly holds shares of COIN.

Response
to Comment 7

The Registrant confirms that
the Funds will have their own distribution frequency unrelated to the underlying reference securities distribution and/or dividend payment
schedule. As such, the Registrant believes it is important to convey the risks associated with shareholders not having the right to receive
dividends with respect to the underlying reference securities.

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Comment
8 – Principal Investment Strategies

Please update the date and
aggregate market value of the voting and non-voting stock held by non-affiliates of each underlying reference security.

Response
to Comment 8

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

Comment
9 – Principal Risks

With respect to the “Coinbase
Global, Inc. Regulatory Risk,” please revise the risk factor in light of recent updates.

Response
to Comment 9

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

Comment
10 – Principal Risks

The Staff notes the “Indirect
Investment Risk” states, “Investing in the Fund is not equivalent to investing in COIN. Fund shareholders will not have voting
rights or rights to receive dividends or other distributions or any other rights with respect to COIN.” Please supplementally confirm
to the Staff the accuracy of this statement.

Response
to Comment 10

The Registrant confirms the
above-referenced disclosure is accurate.

Comment
11 – Principal Risks

The Staff notes the first
sentence of the “Compounding Risk” states, “The Fund has a single day investment objective, and the Fund’s performance
for any other period is the result of its return for each day compounded over the period.” Please revise this sentence for accuracy
and clarify the Fund’s primary investment objective.

Response
to Comment 11

The Registrant has revised
the beginning of the “Compounding Risk” as follows:

“While the Fund’s
primary investment objective is to pay weekly distributions, the Fund’s secondary investment objective is to seek daily investment
results, before fees and expenses, between 105% and 150% the daily percentage change of the common stock of COIN. Therefore, the performance
of the Fund for periods longer than a single day will very likely differ in amount, and possibly even direction, from the targeted daily
leveraged return of COIN for the same period.”

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Comment
12 – Principal Risks

With respect to the “Counterparty
Risk,” please clarify that increased volatility in the underlying reference security may lead counterparties to tighten up position
limits or place other restrictions that could prevent each Fund from achieving its investment strategy.

Response
to Comment 12

The Registrant has added the
following disclosure to the “Counterparty Risk”:

“Additionally, increased
volatility in a single security may lead clearing members to lower position limits or place other restrictions that could prevent the
Fund from achieving its investment strategy.”

Comment
13 – Principal Risks

With respect to the “Debt
Securities Risk,” please clarify if debt securities are tied to each Fund’s investment strategy.

Response
to Comment 13

The Registrant confirms the
“Debt Securities Risk” ties to the portion of each Fund’s investment strategy which includes short-term U.S. government
securities or money market funds, which are used for collateral for the options contracts and/or swap agreements and to generate additional
income to such Fund. The following disclosure has been added as the first sentence of the “Debt Securities Risk”:

“The Fund will invest
in various types of debt securities, which may be used for collateral for the Fund’s options contracts and/or swap agreements and
may be used to generate additional income.”

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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: Robert Rokose, President and Chief Financial Officer, REX
Advisers, LLC

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