SecProbe.io

CORRESP
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filename1.htm

June 20, 2019

VIA
FEDERAL EXPRESS AND E-MAIL

Mr.
Ronald Alper

Ms.
Brigitte Lippman

Office
of Beverages, Apparel and Mining

Division
of Corporate Finance

United
States Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

Re:
Trxade Group, Inc.: Response to telephonic conversation of June 18, 2019

regarding Amendment #1 to Registration Statement on
Form S-1

Filed June 14, 2019 (SEC File Number 333-231246)

Mr.
Alper and Ms. Lippman:

We
write on behalf of our client, Trxade Group, Inc., a Delaware corporation (the “Company”), in connection with the
above-referenced matter. The Company requested us, as its legal counsel, to respond to your June 18, 2019 telephonic conversation
with the United States Securities and Exchange Commission (the “Commission”). Based on our discussion with the Commission
and the current business status, the Company has concurrently filed herewith Amendment No. 2 to its Registration Statement on
Form S-1 (the “Amendment”).

Mr.
Ronald Alper

Ms.
Brigitte Lippman

Division
of Corporate Finance

United
States Securities and Exchange Commission

June
20, 2019

Page
2

Per telephonic conversation
June 18, 2019

General

1. We note that you plan to incorporate
by reference information pursuant to General Instruction VII of Form S-1. However, it appears that the company is a penny stock
issuer as defined in Rule 3a51-1 of the Exchange Act and, therefore, is not eligible to use incorporation by reference. Please
revise or advise.

The Company modified its disclosure. Please see the registration
statement filed concurrently herewith as the Amendment.

Should the Commission or
the Staff declare the filing effective, the Company respectfully requests acceleration of the effective date of its pending registration.
In connection with this request, the Company hereby acknowledges the following in a separate certification signed by the Company’s
President, Mr. Suren Ajjarapu (attached):

    1.
    The
    Company is responsible for the adequacy and accuracy of the disclosure in the filing;

    2.
    Staff
    comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with
    respect to the filing; and

    3.
    The
    Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal
    securities laws of the United States.

Please
feel free to contact us directly with any questions or comments. Thank you in advance for your assistance.

    Very
    Truly Yours,

    Blair
    Krueger, Esq.

    cc:
    Trxade
    Group, Inc.

    Mr.
    Suren Ajjarapu

    Mr.
    Howard Doss

    Mr.
    Steven Lee, Esq.

Enclosure

Blair
Krueger, Esq.

Krueger
LLP

Securities
and Exchange Commission

Response
Letter

Dated
June 20, 2019

CERTIFICATION
SIGNED

In
connection with this letter, the Company hereby acknowledges the following:

    1.
    The
    Company is responsible for the adequacy and accuracy of the disclosure in the filing;

    2.
    Staff
    comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with
    respect to the filing; and

    3.
    The
    Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal
    securities laws of the United States.

Very
truly yours,

    /s/
    Suren Ajjarapu

    Chairman
    of the Board, Chief Executive Officer and Secretary

    June
    20, 2019

    Suren
    Ajjarapu

    (Principal
    Executive Officer)

    /s/
    Howard A. Doss

    Chief
    Financial Officer (Principal Financial and Accounting Officer)

    June
    20, 2019

    Howard
    A. Doss