SecProbe.io

CORRESP
1
filename1.htm

January
24, 2020

    Ms. Katherine Bagley
    VIA EDGAR

Division
of Corporate Finance

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington
D.C. 20549

Re: Request
                                         for Acceleration of Effectiveness of Registration Statement on Form S-1 (File No. 333-235540)
                                         of Trxade Group, Inc. (the “Registrant”)

Dear
Ms. Bagley:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, we hereby request that the effectiveness of the above-captioned Registration
Statement (the “Registration Statement”) be accelerated so that such Registration Statement will become effective
on Monday, January 27, 2020 at 3:00 p.m., Eastern Time, or as soon thereafter as practicable.

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

    ●
    Should
    the Securities and Exchange Commission (“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 Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration
    Statement; and

    ●
    The
    Registrant 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
direct any comments or questions to our counsel, David M. Loev, of The Loev Law Firm, PC, at (832) 930-6432.

Sincerely,

    /s/
Suren Ajjarapu

    Suren
Ajjarapu

    Chief
Executive Officer