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Workhorse Group Inc.

100 Commerce Drive

Loveland, Ohio  45140

513-360-4704

February 12, 2019

VIA EDGAR

United States Securities

and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: Susan Block, Esq.

Re:  Workhorse Group Inc.

    Registration Statement on Form S-3

    File No. 333-229024

Ladies and Gentlemen:

Pursuant to Rule
461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), Workhorse Group
Inc. (the “Company”) respectfully requests that the effective date of the registration statement referred to above
be accelerated so that it will become effective at 4:00 p.m., Washington, D.C. time, on Tuesday February 12, 2019, or as soon thereafter
as possible. Once the registration statement has been declared effective, please orally confirm that event with our counsel, Fleming
PLLC, by calling Stephen Fleming, Esq., at (516) 833-5034.

The Company hereby
acknowledges the following:

 · that should the Commission or the staff, acting pursuant to delegated authority, declare the filing
effective, it does not foreclose the Commission from taking any action with respect to the filing;

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

Thank
you for your assistance in this matter.

    WORKHORSE GROUP INC.

    By:
    /s/ Paul Gaitan

    Name:

        Title:

    Paul Gaitan
Chief Financial Officer

cc:  Stephen M. Fleming, Esq.

    Fleming PLLC