June 8, 2018

Mail Stop 4631

Via E-Mail
Mr. Michael Panosian
Chief Executive Officer
ToughBuilt Industries, Inc.
655 N. Central Ave., Suite 1700
Glendale, CA 91203

       Re:     ToughBuilt Industries, Inc.
               Amendment No. 1 to Draft Registration Statement on Form S-1
               Submitted May 14, 2018
               CIK No. 1668370

Dear Mr. Panosian:

      We have reviewed your amended draft registration statement and have the
following
comments. In some of our comments, we may ask you to provide us with
information so we
may better understand your disclosure.

       Please respond to this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Dividend Policy, page 23

1.     We note your response to comment 9 and we reissue our comment. Please
revise this
       section to include the amount of common stock that is subject to
outstanding options or
       warrants to purchase, or securities convertible into, your common stock.
See Item
       201(a)(2)(i) of Regulation S-K.

Business, page 33

2.     We note your response to comment 18. Please revise your disclosure to
include data
       regarding home improvement spending in 2017.
 Michael Panosian
ToughBuilt Industries, Inc.
June 8, 2018
Page 2

3.      We note your response to comment 19. Please disclose the names of the
retailers in
        Africa and the Middle East that carry your products.

Mobile Device Market, page 37

4.      We note your response to comment 22 and we reissue our comment. Please
file
        supplementally a copy of the IDG Research Services study you reference
with the
        relevant portion highlighted. In this regard, we note that the document
you filed as
        Appendix A appears to be an article posted on the internet.

Financial Statements, page F-1

General

5.      Please amend your filing to update your financial statements pursuant
to Rule 8-08 of
        Regulation S-X.

Item 16. Exhibits and Financial Statement Schedules

6.      Please file a legible copy of the Service Agreement filed as Exhibit
10.1.

        You may contact Tracey McKoy (Staff Accountant) at 202-551-3772 or
Jeanne Baker
(Staff Accountant) at 202-551-3691 if you have questions regarding comments on
the financial
statements and related matters. Please contact Frank Pigott (Staff Attorney) at
202-551-3570 or
me at 202-551-3397 with any other questions.


                                                             Sincerely,

                                                             /s/ Jay Ingram

                                                             Jay Ingram
                                                             Legal Branch Chief
                                                             Office of
Manufacturing and
                                                             Construction