MAXIM GROUP LLC

405 Lexington Avenue, 2^nd Floor

New York, NY 10174

November 6, 2018

VIA EDGAR

Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549

Re:

ToughBuilt Industries, Inc.

Registration Statement on Form S-1

(File No. 333-226104) (the “Registration Statement”)

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Act”), Maxim Group LLC, as representative of the underwriters, hereby requests acceleration of the effective date of the above-referenced Registration Statement so that it will become effective at 5:00 p.m., Eastern Time, on November 8, 2018, or as soon thereafter as practicable.

Pursuant to Rule 460 of the General Rules and Regulations under the Act, the undersigned advises that as of the date hereof, 990 copies of the Preliminary Prospectus have been distributed to prospective underwriters, dealers, institutional investors, retail investors and others.

The undersigned confirms that it has complied with and will continue to comply with, and it has been informed or will be informed by participating dealers that they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection with the above-referenced issue.

[Signature Page Follows]

	Very truly yours,

	MAXIM GROUP LLC

	By:	/s/ Clifford A. Teller
	Name:	Clifford A. Teller
	Title:	Head of Investment Banking,
		Executive Managing Director

[Signature Page to Acceleration Request]