STARBOARD INVESTMENT TRUST

116 South Franklin Street
Rocky Mount, North Carolina 27804
252-972-9922

January 15, 2021

VIA EDGAR

U.S. Securities and Exchange Commission

Public Filing Desk

100 F Street, N.E.

Washington, D.C. 20549

Re: Starboard Investment Trust Registration Statement on Form N-14 File Nos. 333-159484 and 811-22298

Ladies and Gentlemen:

On behalf of Starboard Investment Trust (the “Trust”), we hereby electronically file the Trust’s registration statement on Form N-14, pursuant to the Securities Act of 1933, as amended. This Form N-14 is being filed in connection with the reorganization of the Adaptive Growth Opportunities Fund (the “Acquired Fund”) into the Adaptive Growth Opportunities ETF (the “Acquiring Fund”), another series of the Trust, in exchange for shares of the Acquiring Fund and the assumption by the Acquiring Fund of the liabilities of the Acquired Fund.

No fees are required in connection with this filing.

If you have any questions concerning this filing, please contact Tanya Boyle at 214-665-3685.

Sincerely,

/s/ Tracie A. Coop

Tracie A. Coop

Secretary