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    ALLISON
        M. FUMAI

        allison.fumai@dechert.com

        +1 212 698 3526 Direct

        +1 698 698 3599 Fax

March 10, 2025

Securities and Exchange Commission

Judiciary Plaza

100 F Street, NE

Washington, D.C. 20549

Attention: Ms. Soo Im-Tang

Ms. Shandy Pumphrey

Mr. Keith A. O’Connell

Mr. Michael J. Spratt

Re: Lazard
Active ETF Trust (the “Trust” or “Registrant”) (File No. 811-24041)

To Whom It May Concern:

Thank you for the comments provided in correspondence
dated February 13, 2025 regarding the Trust’s initial registration statement on Form N-1A (the “Registration
Statement”) filed with the Securities and Exchange Commission (the “Commission” or “SEC”) on January
15, 2025. The Registration Statement was filed for the purpose of registering shares of the following initial series of the Registrant:
(i) Lazard Emerging Markets Opportunities ETF; (ii) Lazard Equity Megatrends ETF; (iii) Lazard International Dynamic Equity ETF;
(iv) Lazard Japanese Equity ETF; and (v) Lazard Next Gen Technologies ETF (each, a “Portfolio,” and collectively, the
“Portfolios”). The Registrant has considered your comments and has authorized us to make the responses and changes
discussed below to the Registration Statement on its behalf. For your convenience, we have restated the comments below followed
by our responses. Capitalized terms used but not defined in this letter have the meaning given to them in the Registration
Statement.

GENERAL

    Comment 1.
    We note that portions of the registration statement are incomplete. A full
    financial review (e.g., seed financial statements, auditor’s report, consent) must be performed prior to declaring
    the registration statement effective. We may have additional comments on such portions when you complete them in a pre-effective
    amendment, on disclosures made in response to this letter, on information supplied supplementally, or on exhibits added in
    any amendment.

    Response 1.
    The Registrant confirms that the Portfolios will complete or update all information that is
    currently in brackets or missing in the Registration Statement, including exhibits, in subsequent amendments. The Registrant
    will consider any additional comments made in connection with the SEC Staff’s review of the Registration Statement,
    disclosures made in response to this letter, supplemental information, or exhibits added in any pre-effective amendments.

    Comment 2.
    Please inform the Staff if a party other than the Portfolio’s sponsor
    or an affiliate is providing the Portfolio with initial seed capital. If so, supplementally identify the party providing the
    seed capital and describe its relationship with the Portfolio.

    Response 2.
    We hereby confirm that no party other than Lazard Asset Management LLC (“LAM”
    or the “Investment Manager”), the Portfolios’ sponsor, or an affiliate of LAM, will provide the initial
    seed capital for the Portfolios.

    Comment 3.
    Please confirm the Portfolios will file a fidelity bond under Form 40-17G.

    Response 3.
    We hereby confirm that the Trust will file a fidelity bond under Form 40-17G.

    Comment 4.
    Please provide the principal trading market (exchange) for each Portfolio.

    Response 4.
    The disclosure has been revised accordingly.

    Comment 5.
    Please apply any comments on a particular Portfolio globally to each of the Portfolios,
    if applicable.

    Response 5.
    We acknowledge the comment and have addressed it accordingly.

FOR ALL PORTFOLIOS – PROSPECTUS

Fees and Expenses

    Comment 6.
    The Staff notes that there is a caption for a fee waiver on the Fees and Expenses
    table. Please confirm if there will be a fee waiver and if so, please provide the details in a footnote to the table and if
    applicable, include any details regarding any potential recoupments.

    Response 6.
    We hereby confirm that only Lazard Equity Megatrends ETF and Lazard Next Gen Technologies
    ETF will have a management fee waiver at launch and the disclosure has been revised accordingly. We further confirm that such
    waivers are not subject to recoupment by the Investment Manager.

    Comment 7.
    The prospectus indicates that each Portfolio may invest in other investment companies.
    If acquired fund fees and expenses (“AFFEs”) from such investments will exceed 0.01% of the average net assets
    of the Portfolio, please disclose these fees and expenses as a separate line item in the fee table. See Item 3, Instruction
    3(f)(i) of Form N-1A.

    Response 7.
    We hereby confirm that none of the Portfolios is expected to have AFFE exceeding
    0.01% of its average net assets at launch.

    LAZARD EMERGING MARKETS OPPORTUNITIES ETF

    Principal Investment Strategies, pages 2-3; Investment Strategies, page 29

    Comment 8.
    The first paragraph discloses that the Portfolio invests primarily in equity securities
    of “non-US companies whose principal activities are located in emerging market

    countries . . . .” Please explain what criteria the Portfolio uses to
    determine that a company’s “principal activities” are located in emerging market countries.

    Response 8.
    The disclosure has been revised accordingly.

    Comment 9.
    Please disclose the Portfolio’s market capitalization policy used to select equity
    investments. We note there is principal risk disclosure of small, medium and large company risk but no corresponding principal
    investment strategy disclosure.

    Response 9.
    The disclosure has been revised accordingly.

    Comment 10.
    The first sentence in the third paragraph states, “Under normal circumstances, the
    Portfolio invests at least 80% of its assets in equity securities . . . .” Please revise to state, “at least 80%
    of its net assets (plus any borrowings for investment purposes) . . . .”

     Response 10.
    The disclosure has been revised accordingly.

    Comment 11.
    The third sentence states, “In addition implementation of the Portfolio’s investment
    strategy may, during certain periods, result in the investment of a significant portion of the Portfolio’s assets in
    a particular market sector.” Please identify the particular market sectors and disclose associated risks under the principal
    investment risks section.

    Response 11.
    The disclosure has been revised to indicate that while the Portfolio’s investment strategy
    is not designed to focus investments in any particular market sector or sectors, the implementation of the Portfolio’s
    investment strategy may, from time to time, result in significant exposure to particular market sectors. We supplementally
    submit that the Investment Manager does not expect the Portfolio to have significant exposure to any particular market sectors
    at launch.

    Comment 12.
    On page 29, the disclosure lists the types of securities that the Portfolio invests in,
    including convertible securities. If the Portfolio invests, or expects to invest in, contingent convertible securities (“CoCos”),
    the Portfolio should consider what, if any, disclosure is appropriate. The type and location of disclosure will depend on,
    among other things, the extent to which the Portfolio invests in CoCos, and the characteristics of the CoCos (e.g.,
    the credit quality and the conversion triggers). If CoCos are, or will be, a principal type of investment, please provide
    a description of them in the prospectus, as well as the attendant risks.

    Response 12.
    We hereby confirm that the Portfolio does not expect to invest CoCos at launch but reserves
    the discretion to do so in the future.

    Comment 13.
    The last paragraph of page 29 discloses that the Investment Manager incorporates ESG considerations,
    that the Portfolio may invest in businesses that have poor ESG characteristics if the Investment Manager is aware, that ESG
    factors are considered alongside non-ESG factors and are generally no more significant than other factors in the selection
    process. Please briefly describe, or provide examples, of the types of ESG considerations that the Investment Manager incorporates.

    Response 13.
    The disclosure has been revised accordingly.

    Principal Investment Risks, pages 3-5

    Comment 14.
    Please include an “Underlying ETF Risk” and “Value Investing Risk”
    (listed in the “Glossary – Investment Risks” section on pages 36-43) for this Portfolio as well.

    Response 14.
    The disclosure has been revised to include “Underlying ETF Risk” as a principal
    risk of the Portfolios. We respectfully note that “Value Investing Risk” is already included as a principal risk
    for the Portfolio.

LAZARD EQUITY MEGATRENDS ETF

Principal Investment Strategies, pages 7-8;
Investment Strategies, pages 30-31

    Comment 15.
    The first paragraph states, “The Portfolio will seek to achieve its
        investment objective by investing primarily in an actively managed portfolio of established, well managed companies located
        around the world, including emerging markets, which have a market capitalization of greater than $1 billion at the time
        of purchase.”

        a)  Please disclose
        the criteria or provide examples of how the Portfolio determines a company is “established, well managed.”

        b)  Please define
        “emerging markets.”

        c)  Market capitalization of
        greater than $1 billion (referenced above) may include small, medium and large cap companies. Please disclose the Portfolio’s
        market capitalization policy used to select equity investments. We also note there is a principal risk disclosure of large
        cap company risk but no corresponding principal investment strategy disclosure.

    Response 15.
    The disclosure has been revised in response to subparts (b) and (c) of the comment.
    With respect to subpart (a), we respectfully note that the fourth paragraph of the “Summary—Lazard Equity Megatrends
    ETF—Principal Investment Strategies” section already discloses that the Investment Manager takes into account
    factors such as the quality, growth prospects and valuation of companies, which are assessed and identified by the Investment
    Manager through the bottom-up fundamental company research, in selecting the Portfolio’s investments.

    Comment 16.
    The second paragraph states, “Under normal circumstances, the Portfolio invests at
    least 80% of its assets in equity and equity-related securities . . . .” Please revise to state, “at least 80%
    of its net assets (plus any borrowings for investment purposes) . . . .”

    Response 16.
    The disclosure has been revised accordingly.

    Comment 17.
    Please include any policy to concentrate in securities or issuers in a particular industry
    or group of industries, or any geographic concentrations.

    Response 17.
    We hereby confirm that the Portfolio has no policy to concentrate in securities of issuers
    in a particular industry or group of industries or in any geographic region.

    Comment 18.
    In an appropriate part of this section, please define “Megatrends”
    as used in the Portfolio’s name.

    Response 18.
    The disclosure has been revised accordingly.

    Comment 19.
    The disclosure on page 30 states that the Portfolio invests at least 80% of its assets
    in equity and equity-related securities that include those listed and traded on certain Chinese stock exchanges (“China
    A-Shares”) acquired through either the Shanghai-Hong Kong Stock Connect or the Shenzhen-Hong Kong Stock Connect (“Stock
    Connect”). Please explicitly include this disclosure in the principal investment strategies section of the Portfolio,
    and corresponding risks in the principal investment risks section.

    Response 19.
    This Portfolio does not currently expect investing in China A-Shares to be a principal investment
    strategy of the Portfolio. Accordingly, the disclosure referenced above has been removed.

    Principal Investment Risks, pages 8-11

    Comment 20.
    Under “Thematic Investing Risk,” the disclosure states in part, “In addition,
    the Investment Manager is not required to monitor on an ongoing basis whether a current holding continues to be aligned with
    one or more of the themes/trends it identifies. The Portfolio is not required to sell, and may instead add to, positions in
    holdings that no longer continue to be aligned with one or more of the themes/trends identified by the Investment Manager.”
    In light of this disclosure, please explain how the Portfolio can remain materially consistent with its investment strategy
    of identifying significant macroeconomic trends and selecting investments that take advantage of such trends.

    Response 20.
    The disclosure referenced above has been removed.

    LAZARD INTERNATIONAL DYNAMIC EQUITY ETF

    Principal Investment Strategies, pages 12-13; Investment Strategies, page 31

    Comment 21.
    The first sentence of this section states that the Portfolio will invest
        primarily in equities of “US and non-US companies, including those in emerging markets.”

        a)   Please clarify how the portfolio will be allocated among US and non-US companies.

        b)   Please define “emerging markets.”

    Response 21.
    With respect to subpart (a), the disclosure has been revised to remove the reference to investments
    in “US and non-US companies.” With respect to subpart (b), the disclosure has been revised accordingly.

    Comment 22.
    The disclosure states, “The Portfolio will typically invest the majority of its assets
    in securities of non-US developed market companies . . . .” Please disclose what is meant by “non-US developed
    market companies.”

    Response 22.
    The disclosure has been revised accordingly.

    Comment 23.
    Please include any policy to concentrate in securities or issuers in a particular
    industry or group of industries, or any geographic concentrations.

    Response 23.
    We hereby confirm that the Portfolio has no policy to concentrate in securities of issuers
    in a particular industry or group of industries or in any geographic region.

    Comment 24.
    The disclosures states, “In addition to a multidimensional assessment of risk, each
    company is evaluated daily according to four independent measures: growth, value, sentiment and quality.” Please disclose
    what is meant by “sentiment.”

    Response 24.
    The disclosure has been revised accordingly.

    Comment 25.
    The first paragraph on page 13 states, “Under normal circumstances, the Portfolio
    invests at least 80% of its assets in non-US securities . . . .” Please revise to state, “at least 80% of its
    net assets (plus any borrowings for investment purposes) . . . .”

    Response 25.
    The disclosure has been revised accordingly.

    Comment 26.
    The same paragraph also discloses that, “Implementation of the Portfolio’s
    investment strategy may, during certain periods, result in the investment of a significant portion of the Portfolio’s
    assets in a particular country.” Please identify the particular country(ies) and disclose associated risks under the
    principal investment risks section.

    Response 26.
    This sentence has been removed from the “Summary—Lazard International Dynamic
    Equity ETF—Principal Investment Strategies” section.

    Comment 27.
    Please also include disclosure that this Portfolio is classified as a “diversified”
    investment company, consistent with the disclosure on page 1 of the SAI.

    Response 27.
    The disclosure has been revised accordingly.

    Comment