May 26, 2020




United States Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington, DC 20549

Attention: Mr. Edward M. Kelly



ToughBuilt Industries, Inc.

Registration Statement on Form S-1, as amended

Originally filed April 8, 2020

File No. 333-237606


Ladies and Gentlemen:


Pursuant to Rule 461 under the Securities Act of 1933, as the underwriter of the proposed offering of Toughbuilt Industries, Inc. (the “Company”), we hereby join the Company’s request for acceleration of the above-referenced Registration Statement, requesting effectiveness for 5:30 p.m., Eastern Time, on May 28, 2020, or as soon thereafter as is practicable.


  Very truly yours,
  Maxim Group LLC
  By: /s/ John H. Shaw III
  Name: John H. Shaw III
  Title: Senior Managing Director, Investment Banking