SecProbe.io

CORRESP
1
filename1.htm

June
28, 2019

Mr.
Ronald Alper

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.: Effectiveness of its Registration Statement on Form S-1, filed May 6, 2019, as amended by Form S-1
Pre-Effective Amendment No. 2 as filed on June 20, 2019 (SEC File Number 333-231246)

Dear
Mr. Alper:

This
letter serves as Trxade Group, Inc., a Delaware corporation’s (the “Company”) request, per specific guidance
received by the Company’s securities counsel, Blair Krueger, Esq. of Krueger LLP, for acceleration of the effective date
of the above-referenced Registration Statement on Form S-1 (as amended, the “Registration Statement”), so that such
Registration Statement shall become effective at 4:00 pm (EDT) on Monday, July 1, 2019, or as soon thereafter as practicable.

In
that respect and in furtherance of our Acceleration Request, the Company hereby acknowledges that:

    ●
    Should
    the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority,
    declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to
    the Registration Statement;

    ●
    The
    action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective,
    does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration
    Statement; and

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

Please
provide a copy of the Commission’s order declaring the Registration Statement effective to the Company at the following
address and location:

Mr.
Suren Ajjarapu

Trxade
Group, Inc.

3840
Land O’ Lakes Boulevard

Land
O’ Lakes, Florida 34639

(800)
261-0281

Please
call us with your questions or comments, if any. Thank you in advance for your assistance.

    /s/
    Suren Ajjarapu

    Chairman
    of the Board, Chief Executive Officer and Secretary

    Suren
    Ajjarapu

    (Principal
    Executive Officer)

    cc:
    Ms.
    Brigitte Lippman

    Division
    of Corporation Finance

    United
    States Securities and Exchange Commission

    Trxade
    Group, Inc.

    Mr.
    Suren Ajjarapu

    Mr.
    Howard Doss

    Mr.
    Steven Lee, Esq.