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Baron ETF Trust

 Dechert LLP

 Three Bryant Park

1095 Avenue of the Americas

 New York, NY 10036-6797

+1 212 698 3500 Main

 +1 212 698 3599 Fax

Allison Fumai

 Partner

 Allison.fumai@dechert.com

+1 212 698 3526 Direct

 +1 212 698 3599 Fax

 October 6, 2025

 Securities and
Exchange Commission

 Judiciary Plaza

 100 F Street, NE

Washington, D.C. 20549

Attention:

Ms. Soo Im-Tang

Mr. Jeffrey W. Long

Mr. John Lee

Mr. Michael Kosoff

Re:
 Baron ETF Trust (the “Trust” or Registrant”) (File
No. 333-289683 and 811-24115)

 To Whom It May
Concern:

 Thank you for the comments provided in correspondence dated September 15, 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 August 18, 2025. The Registration Statement
was filed for the purpose of registering shares of the following initial series of the Registrant: (i) Baron First Principles ETF; (ii) Baron Global Durable Advantage ETF; (iii) Baron SMID Cap ETF; (iv) Baron Financials ETF; and
(v) Baron Technology ETF (each, a “Fund,” and collectively, the “Funds”). 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. These changes are expected to be reflected in Pre-Effective Amendment No. 1 to the Registration
Statement, which will be filed via EDGAR on or about October 6, 2025. Capitalized terms used but not defined in this letter have the meaning given to them in the Registration Statement.

 October 6, 2025

  Page
 2

 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.

We hereby confirm all information that is currently in brackets or missing in the Registration Statement, including exhibits, will be completed or updated 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 Fund’s sponsor or an affiliate is providing the Fund with initial seed capital. If so, supplementally identify the party providing the seed capital and describe its
relationship with the Fund.

Response 2.

We hereby confirm that no party other than BAMCO, Inc. (“BAMCO” or the “Adviser”), the Funds’ investment adviser, or an affiliate of BAMCO, will provide the initial seed capital for the Funds.

Comment 3.

Please confirm the Fund will file a fidelity bond under Form 40-17G.

Response 3.

We hereby confirm that the Registrant will file a fidelity bond under Form 40-17G for the Funds.

Comment 4.

Please apply any comments on a particular Fund globally to each of the Funds, if applicable.

Response 4.

We acknowledge the comment and have addressed it accordingly.

 October 6, 2025

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 FOR ALL FUNDS – PROSPECTUS

Expenses Example

Comment 5.

Please provide updated figures in the expense example for each Fund.

Response 5.

The disclosure has been revised accordingly.

BARON FIRST PRINCIPLES ETF

Investments, Risks, and Performance, pages 1-4

Comment 6.

Please consider explaining the term “Principles First” and how it relates to the Fund’s objectives and strategies.

Response 6.

We respectfully note that the Fund’s name includes “First Principles” instead of “Principles First”. “First Principles” is a common term associated with breaking down complex problems to
their most fundamental truths and building solutions from there. This concept relates to the Fund’s strategies as the Adviser seeks to analyze businesses at their most fundamental level to determine if investing in those businesses will meet
the Fund’s objective of long-term capital appreciation. We believe the current disclosure adequately addresses this concept.

Comment 7.

Under principal investment strategies of the Fund, the first paragraph states that the Fund may borrow money from banks (leverage) in an amount up to one-third of its total assets. Please
confirm whether the Fund will employ leverage within the first 12 months of operations. If so, please add a line item for interest expense to the fee table.

Response 7.

We hereby confirm that the Fund intends to employ leverage within the first 12 months of operations. The fee table has been revised accordingly.

Comment 8.

On page 2, the staff notes principal risk factors, “Industry Concentration” and “Risks of Emphasizing a Sector or Industry.” Please identify the specific industry or sectors the Fund may concentrate in and
include related disclosures in the principal investment strategies section.

 October 6, 2025

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Response 8.

We respectfully acknowledge your comment; however, we believe that the current disclosure is appropriate. Although it is not a principal investment strategy of the Fund to concentrate in a specific industry or sector, the Registrant
acknowledges that such concentration may occur due to market fluctuations in the value of the Fund’s investments, as described in the “Industry Concentration” risk tile. The Registrant will consider whether any additional industry
or sector risks are appropriate in connection with its next annual update, once the Fund commences operation.

Comment 9.

The staff notes there is a “Common CEO Risk” for this Fund. Please include this discussion in the principal investment strategies section, as there is no reference to Fund’s investment in companies with certain
persons in common (including chief executive officers or others fundamental to the success of the company).

Response 9.

We hereby confirm that it is not the Fund’s principal investment strategy to invest in companies with certain persons in common. The disclosure has been revised accordingly.

Comment 10.

Under “ETF Structure Risks,” please also disclose that, where all or a portion of the ETF’s underlying securities trade in a market that is closed when the market in which the ETF’s shares are listed and
trading in that market is open, there may be changes between the last quote from its closed foreign market and the value of such security during the ETF’s domestic trading day. In addition, please note that this in turn could lead to
differences between the market price of the ETF’s shares and the underlying value of those shares.

Response 10.

The disclosure has been revised accordingly.

BARON GLOBAL DURABLE ADVANTAGE ETF

Investments, Risks, and Performance, pages 5-9

Comment 11.

Please supplementally explain what is meant by “durable advantage” in the Fund’s name with respect to the Fund’s investment strategy, and how it is measured.

Response 11.

“Durable Advantage” relates directly to the Fund’s strategy of investing in companies that the Adviser believes have competitive advantages that are sustainable, enabling them to grow faster than their competitors
over long periods of time. The Adviser selects securities based on issuers’ current free cash flow yield and a high and/or rising return on invested capital, among other factors.

 October 6, 2025

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Comment 12.

Please disclose that this Fund is classified as a “diversified” investment company, consistent with the disclosure on page 1 of the Statement of Additional Information (“SAI”).

Response 12.

The disclosure has been revised accordingly.

Comment 13.

The first paragraph states, “The Fund seeks to achieve its investment objective by investing primarily in equity securities in the form of common stock of established and emerging markets companies located throughout the
world, with capitalizations within the range of companies included in the MSCI ACWI Index Net USD.”

 (a)   In the disclosure, please define “emerging markets
companies,” and the criteria used to determine how the Fund determines a company is an emerging markets company.

 (b)  Please identify the market capitalization range for the MSCI ACWI Index Net
USD in the disclosure. You can note that the range provided is as of a particular date, and that it may fluctuate over time.

Response 13.

The disclosure has been revised to state that “[t]he Fund seeks to achieve its investment objective by investing primarily in equity securities in the form of common stock of
established and emerging markets developing countries companies located throughout the world, with capitalizations within
the range of companies included in the MSCI ACWI Index Net (USD). Developing countries include countries
in the MSCI Emerging Markets (EM) Index, countries in the MSCI Frontier Markets (FM) Index and other countries determined by the Adviser to be developing countries based on classifications made by the International Monetary Fund or on country
characteristics similar to those of the countries in the EM and FM Indexes. As of August 29, 2025, the market capitalization of the companies in the MSCI ACWI Index (USD) ranged from $197.38 million to $4.25 trillion and may fluctuate over
time.”

Comment 14.

The second paragraph states in part, “The Adviser seeks to invest primarily in what it believes are unique, well-managed, competitively advantaged businesses...” Please provide examples or explain what is meant by
“unique” in the disclosure.

 October 6, 2025

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Response 14.

The disclosure has been revised to remove “unique.”

Comment 15.

On page 6, the staff notes principal risk factors, “Concentration” (that the Fund may hold large positions in a “relatively limited number of issuers, investments or industries”) and “Risks of
Emphasizing a Region, Sector or Industry.” Please identify the specific types of issuers, region, sector or industry that the Fund may concentrate/emphasize and update the principal investment strategy disclosure accordingly.

Response 15.

We respectfully acknowledge your comment; however, we believe that the current disclosure is appropriate. It is not a principal investment strategy of the Fund to concentrate in or emphasize specific types of issuers, regions,
sectors or industries, except as currently disclosed (i.e., that (i) under normal market and economic conditions, which will be assessed on a global basis, at least 40% of the Fund’s net assets will be invested in stocks of companies
outside the U.S. and (ii) under non-favorable market and economic conditions, which will be assessed on a company by company basis, at least 30% of the Fund’s net assets will be invested in
stocks of companies outside the U.S.). However, the Registrant acknowledges that such concentration may occur as a result of, among other things, price shifts of its investments, as described in the “Concentration” risk tile. The
Registrant will consider whether any additional risks related to specific types of issuers, regions, sectors or industries are appropriate in connection with its next annual update, once the Fund commences operation.

Comment 16.

The staff notes “Technology” risk which describes the risk of investing in technology companies. If investments in technology companies are a principal investment strategy of the Fund, please include related
disclosure in the principal investment strategy section.

Response 16.

We hereby confirm that investing in technology companies is not a principal investment strategy of the Fund. Accordingly, the disclosure has been revised to remove “Technology” risk as a principal risk of the
Fund.

 October 6, 2025

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Comment 17.

The staff notes “Emerging Markets and Developing Countries Risk” (page 7). Please clarify in the disclosure whether the term “developing countries” is synonymous with “emerging markets”
(referenced in the principal investment strategies discussion). If they are investments in different regions, to the extent they are principal investment strategies, please include related disclosures for both in the principal investment strategies
and the principal risks sections.

Response 17.

As noted above in Response 13, the Fund’s principal investment strategies have been revised to reference the term “developing countries” instead of “emerging markets.” Accordingly, the “Emerging
Markets and Developing Countries Risk” principal risk has been replaced with the below risk:

Developing Countries. The Fund invests in developing countries, which include countries in the MSCI Emerging Markets (EM) Index, countries in the MSCI Frontier Markets (FM) Index and other countries determined by the Adviser
to be developing countries based on classifications made by the International Monetary Fund or on country characteristics similar to those of the countries in the EM and FM Indexes. Investments in developing countries are subject to all of the risks
of non-U.S. investing generally, and have additional heightened risks due to a lack of established legal, political, business and social frameworks to support securities markets, including: delays in settling
portfolio securities transactions; currency and capital controls; greater sensitivity to interest rate changes; pervasiveness of corruption and crime; currency exchange rate volatility; and inflation, deflation or currency devaluation. These risks
are greater for countries in the FM Index.

Comment 18.

On pages 7-8, the staff notes the following principal risk factors with extensive discussions under each risk: “Risks Associated with China and Hong Kong,” “Risks
Associated with Investing in Chinese Companies through Variable Interest Entities” and “Risks related to Variable Interest Entities.” To the extent investments in China (and through Variable Interest Entities) and Hong Kong are
principal investment strategies of the Fund, please update the principal investment strategy disclosures accordingly.

Response 18.

We hereby confirm that it is not a principal investment strategy of the Fund to invest in China or variable interest entities. Accordingly, the disclosure has been revised to remove the following principal risks: “Risks
Associated with China and Hong Kong,” “Risks Associated with Investing in Chinese Companies through Variable Interest Entities” and “Risks related to Variable Interest
Entities.”

 October 6, 2025

  Page
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Comment 19.

Under “ETF Structure Risks,” please also disclose that, where all or a portion of the ETF’s underlying securities trade in a market that is closed when the market in which the ETF’s shares are listed and
trading in that market is open, there may be changes between the last quote from its closed foreign market and the value of such security during the ETF’s domestic trading day. In addition, please note that this in turn could lead to
differences between the market price of the ETF’s shares and the underlying value of those shares.

Response 19.

The disclosure has been revised accordingly.

 BARON SMID CAP ETF

Investments, Risks, and Performance, pages 11-14

Comment 20.

The first sentence of this section states that the Fund will invest at least 80% of its net assets in securities of small- and mid-sized companies. Please disclose the specific types of
securities in which the Fund intends to invest (e.g., equity securities).

Response 20.

The disclosure has been revised to state that “[t]he Fund is a diversified fund that, under normal circumstances, invests at least 80% of its net assets in equity securities of small- and mid-sized companies.”

Comment 21.

Please incl