September 23, 2019

Michael Panosian
Chief Executive Officer
ToughBuilt Industries, Inc.
25371 Commercentre Drive, Suite 200
Lake Forest, CA 92630

       Re: Toughbuilt Industries, Inc
           Registration Statement on Form S-1
           Filed September 6, 2019
           File No. 333-233655

Dear Mr. Panosian:

       We have limited our review of your registration statement to those
issues we have
addressed in our comments. In some of our comments, we may ask you to provide
us with
information so we may better understand your disclosure.

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

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Form S-1 filed September 6, 2019

Calculation of Registration Fee table, page i

1.     Please advise us of the basis for utilizing Rule 457(o) for the
Calculation of Registration
       Fee. Under the circumstances, we believe paragraph (c) of Rule 457 is
the applicable
       subsection to calculate the fee.
2.     You disclose in footnote (1) of the fee table and on the prospectus
cover page that you are
       registering 11,500,000 common shares underlying the principal amount of
senior secured
       convertible notes and 5,750,000 shares underlying 5,750,000 warrants
issued to the selling
       stockholder. However, in the Selling Stockholder and Plan of
Distribution section you
       disclose that the shares of common stock being offered by the selling
stockholder
       constitute common stock and common stock into which the Series C
convertible preferred
       stock is convertible. Please make your disclosures consistent throughout
the registration
 Michael Panosian
ToughBuilt Industries, Inc.
September 23, 2019
Page 2
         statement.
The Selling Stockholder and Plan of Distribution, page 54

3.       Please revise to provide the information required by Item 507 of
Regulation S-K as of the
         most recent practicable date.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

      Please contact Sherry Haywood (Staff Attorney) at (202) 551-3345 or Jay
Ingram (Legal
Branch Chief) at (202) 551-3397 with any questions.



                                                             Sincerely,
FirstName LastNameMichael Panosian
                                                             Division of
Corporation Finance
Comapany NameToughBuilt Industries, Inc.
                                                             Office of
Manufacturing and
September 23, 2019 Page 2                                    Construction
FirstName LastName