October 10, 2018

Mail Stop 4631

Via E-Mail
Mr. Michael Panosian
Chief Executive Officer
ToughBuilt Industries, Inc.
655 N. Central Ave., Suite 1700
Glendale, CA 91203

       Re:    ToughBuilt Industries, Inc.
              Amendment No. 4 to Registration Statement on Form S-1
              Filed October 10, 2018
              File No. 333-226104

Dear Mr. Panosian:

        We have reviewed your amended registration statement and have the
following comment.
Please respond to this letter by amending your registration statement and
providing the requested
information. If you do not believe our comment applies to your facts and
circumstances or do
not believe an amendment is appropriate, please tell us why in your response.

General

   1. We note your registration statement covers the offer and sale of up to
$5,163,856 of
      securities to be issued upon conversion of outstanding debentures.
Although you do not
      identify the holder of the debenture in your prospectus, we presume the
holder is Hillair
      Capital Investments LP and that the debenture you reference is the Senior
Secured
      Convertible Debenture you issued to Hillair on or about October 17, 2016,
as amended
      and restated thereafter. Because the convertible debenture is immediately
exercisable
      into common stock, i.e., within a year of issuance, you appear to have
commenced this
      transaction privately, on or about October 17, 2016 when you issued the
convertible
      debenture to Hillair. Please note that a transaction commenced privately
cannot be
      converted to a registered offering. Please refer to Question 134.02 of
our Securities Act
      Sections Compliance and Disclosure Interpretations and remove this
component of your
      offering.
 Michael Panosian
ToughBuilt Industries, Inc.
October 10, 2018
Page 2

       Please contact Frank Pigott (Staff Attorney) at 202-551-3570 or me at
202-551-3397 with
any questions.


                                                         Sincerely,

                                                         /s/ Jay Ingram

                                                         Jay Ingram
                                                         Legal Branch Chief
                                                         Office of
Manufacturing and
                                                         Construction

cc:     Jolie Kahn, Esq.
        Wexler, Burkhart, Hirschberg & Unger, LLP