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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

May 21, 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 19, 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 further amended on February 19, 2025, April 14, 2025, and May 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

With respect to each Fund’s
80% investment policy, please clarify that the “income producing investments” are tied to the applicable underlying security.

Response
to Comment 2

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

Comment
3 – Principal Investment Strategies

The Staff notes the disclosure
states that options contracts may be less efficient than the use of swap agreements. Please clarify in the disclosure why the Funds may
not be able to use swap agreements.

Response
to Comment 3

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

Comment
4 – Principal Investment Strategies

Please clarify if the Funds
will use both a traditional covered call strategy and a synthetic covered call strategy.

Response
to Comment 4

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

Comment
5 – Principal Investment Strategies

Please move the paragraph
beginning with “The Fund’s portfolio will consist of the following elements…” earlier in the “Principal
Investment Strategies” section.

Response
to Comment 5

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

Comment
6 – Principal Risks

Please clarify that the “Blockchain
Risk” and “Crypto Asset Market and Volatility Risk” apply to the Fund’s investments in COIN.

Response
to Comment 6

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

Comment
7 – Principal Risks

The Staff notes that the Fund
will be concentrated in the industry or group of industries to which the applicable underlying security is assigned. For example, COIN
is assigned to the Capital Markets industry. Please consider removing the “Financial Sector Risk” under the “Concentration
Risk.”

Response
to Comment 7

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

Comment
8 – General

Please supplementally confirm
to the Staff that the changes made in connection with this comment response letter will be the only changes made to the definitive registration
statement.

Response
to Comment 8

The Registrant so confirms.

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

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