SecProbe.io

CORRESP
1
filename1.htm

March 23, 2020

VIA
EDGAR

U.S. Securities
and Exchange Commission

Division
of Corporation Finance

100 F.
Street, NE

Washington,
D.C. 20549

Attention:
	Edward Kelly

	Asia Timmons-Pierce

Re:  Ecoark
                                         Holdings, Inc.

    Registration
                                         Statement on Form S-1

    File
                                         No. 333-235456

    Acceleration
                                         Request

    Requested
                                         Date:
                                                        March
                                         25, 2020

    Requested
                                         Time:
                                                               9:00
                                         A.M. Eastern Time

Ladies
and Gentlemen:

Pursuant to Rule 461 under
the Securities Act of 1933, as amended, Ecoark Holdings, Inc. (the “Company”) hereby respectfully requests
that the above-referenced Registration Statement on Form S-1 (File No. 333-235456) (the “Registration Statement”)
be declared effective at the “Requested Date” and “Requested Time” set forth above, or as soon as practicable
thereafter, or at such later time as the Company or its counsel may orally request via telephone call to the staff of the Division
of Corporation Finance of the Securities and Exchange Commission. The Company hereby authorizes Peter DiChiara, counsel to the
Company, to make such request on its behalf.

Please confirm the effectiveness
of the Registration Statement with Peter DiChiara of Carmel, Milazzo & DiChiara LLP by telephone at (212) 658-0458 or email
at pdichiara@cmdllp.com.

Sincerely,

ECOARK HOLDINGS, INC.

/s/ Randy S. May

Randy S. May

Chief Executive Officer