United States securities and exchange commission logo August 10, 2022 Martin Galstyan Chief Financial Officer Toughbuilt Industries, Inc 8669 Research Drive Irvine, CA 92618 Re: Toughbuilt Industries, Inc Registration Statement on Form S-1 Filed August 3, 2022 File No. 333-266496 Dear Mr. Galstyan: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Evan Ewing at 202-551-5920 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing