November 30, 2022



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,  
  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