November 30, 2022

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”)

Registration Statement on Form S-1

File No. 333-268537

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 above-referenced Registration Statement be accelerated so that the same will become effective at 5:00 PM (EST) on Friday, December 2, 2022, or as soon thereafter as is practicable.

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

8669 Research DR

Irvine, Ca 92618

p: 800 288 4659

f: 800 604 3259