TOUGHBUILT INDUSTIES, INC.

25371 Commercentre Drive, Suite 200

Lake Forest, CA 92630

(949) 528-3100

 

December 17, 2020

 

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

 

  Re: ToughBuilt Industries, Inc. (the “Company”)
    Pre-Effective Amendment No. 1 to Registration Statement on Form S-3
    File No. 333-251185

 

Ladies and Gentlemen:

 

In accordance with Rule 461 under the Securities Act of 1933, as amended, the undersigned respectfully requests that the effective date of the Company’s above-referenced Registration Statement, as amended, be accelerated so that the same will become effective at 4:00 P.M. (EST) on Thursday, December 17, 2020, or as soon thereafter as is practicable.

 

  Very truly yours,
   
  TOUGHBUILT INDUSTRIES, INC.
   
  By: /s/ Michael Panosian
  Name:  Michael Panosian
  Title: Chief Executive Officer