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filename1.htm

November
29, 2018

VIA
EDGAR CORRESPONDENCE

Loan
Lauren Nguyen, Legal Branch Chief

Anuja
Majmudar, Attorney-Advisor

Division
of Corporation Finance

Office
of Natural Resources

United
States Securities Exchange Commission

Washington
D.C. 20549

    Re:
    Barfresh
    Food Group, Inc.

    Form
    10-K for the Fiscal Year Ended December 31, 2017

    Filed
    April 2, 2018

    File
    No. 000-55131

Dear
Mses. Nguyen and Majmudar:

This
letter sets forth the supplemental information requested during a teleconference call on November 8, 2018 between SEC Examiner
Lily Dang and Joseph Tesoriero. The teleconference concerned the response letter of Barfresh Food Group, Inc. (“Barfresh”
or the “company”) dated November 7, 2018, which was filed in response to your letter dated November 2, 2018, relating
to the above captioned Annual Report. The follow up questions from the teleconference are set forth in bold text below, and the
responses of the company are set forth in plain text immediately following each comment.

Management’s
Discussion and Analysis of Financial Condition and Results of Operations, page 20

    1.
    With
    regard to your response to prior comment 1, please disclose in the future filings the relevant factual information contained
    in your response letter dated November 7, 2018.

We
will include appropriate further information in future filings, emphasizing that this individual’s responsibilities are
in the area of product development, rather than manufacturing.

Financial
Statements

Note
2 – Property, Plant and Equipment, page F-101.

1. With
                                         regard to your response to prior comment 2, please explain how manufacturing equipment
                                         is used if all products are manufactured by outside contractors.

Barfresh
utilizes third party contract manufacturers to manufacture all of its products. The current portfolio of products includes smoothies,
shakes and frappes. Products are packaged in two distinct formats. The single serve format features portion controlled and ready
to blend beverage ingredient packs or “beverage packs”. The beverage packs contain all of the solid ingredients necessary
to make the beverage, including the base (either sorbet, frozen yogurt or ice cream), real fruit pieces, juices and ice –
five ounces of water are added before blending. The second format is the Company’s bulk “Easy Pour” format,
which also contains all of the solid ingredients necessary to make the beverage, packaged in gallon containers in a concentrated
formula that is mixed “one to one” with water. For both product formats, the third party contract manufacturers supply
all of the manufacturing equipment needed to make the frozen beverage product mixture. For the single serve format, Barfresh supplies
certain manufacturing equipment, required to place the ingredients into the beverage packs, including bagging machines, ice machines,
scales, and conveyor belts. For the bulk “Easy Pour” format, Barfresh does not supply any manufacturing equipment.

Mses.
Nguyen and Majmudar

November
29, 2018

Page

    2.
    Do
    any Barfresh employees work on any part of the manufacturing line, or operate the bagging machinery for the single serve lines
    at the contract manufacturers?

No,
the entire manufacturing lines for both product formats, including the bagging machines for the single serve lines, are operated
by employees of the third party contract manufacturers.

    3.
    Please
    provide support for your conclusion that the manufacturing equipment depreciation does not have a material impact on your
    gross profit in the Annual Report on Form 10-K for the fiscal year ending December 31, 2017, and confirm treatment of this
    item for your 2018 periodic reports.

Total
Depreciation and Amortization included in our 2017 Form 10-K for the year 2017 was $330,883, of which $268,784 pertains to depreciation
on equipment, and $62,099 pertains to amortization of intangible assets. For the year 2016, total Depreciation and Amortization
was $208,614, of which $147,131 pertains to depreciation on equipment, and $61,483 pertains to amortization of intangible assets.
In both 2017 and 2016, equipment includes manufacturing equipment, blenders and freezers placed at food service locations, company
automobiles, office equipment, and similar equipment. If depreciation on manufacturing equipment had been included as an expense
in arriving at Gross Profit, the impact on the gross profit margin would have been 4.9% in 2017 (40.74% as adjusted, as compared
with 45.64% as reported), and 6% in 2016 (40.93% as adjusted, as compared with 46.98% as reported).

Considering
guidance available in SAB No. 99, in particular considering the total mix of information made available, and considering both
quantitative and qualitative factors, management is of the view that the impact of our treatment of depreciation expense on manufacturing
equipment on our financial statements is immaterial for 2017, and that the 2017 financial statements taken as whole accurately
reflect the Company’s results. Further, there would be no material change in our net losses versus what was reported.

Based
on our discussions with our independent auditor and their review of this letter, our auditors agree with the Company’s management
that the impact of the matters discussed herein do not have a material qualitative effect on the financial statements; however
our auditors have not performed any audit procedures with respect to the changes to the financial statements referred to above.

Beginning
with our Form 10-K for 2018, we will report depreciation on manufacturing equipment as an expense in arriving at Gross Profit,
for both the current year, and for the comparable prior year. We will plan on disclosing this change as a reclassification in
our Notes to our Financial Statements for the year ending December 31, 2018.

    4.
    Please
    provide accounting support for your conclusion that the provision of blending equipment by Barfresh to food service and restaurant
    locations that buy Barfresh’s products from Barfresh’s customers (i.e., from distributors) is not part of your
    product sales performance obligation?

Barfresh
sells its products to independent distributors, such as Sysco. Once Barfresh delivers products to the distributor, title and risk
of loss of that product passes to the distributor. Our contracts contain a single performance obligation, which is the delivery
of frozen beverages. The transaction price is allocated to that single performance obligation. In certain situations, Barfresh
also provides blending equipment to food service and restaurant locations that buy Barfresh’s products from Barfresh’s
customers. The Company views the provision of blending equipment as related to its marketing effort, and not as related to cost
of goods sold. In addition we have also concluded that ASC 606 does not require us to analyze the provision of blending equipment
as a performance obligation associated with our recording of revenue upon sales to our customers.

*      *       *

Mses.
Nguyen and Majmudar

November
29, 2018

Page

We
appreciate the Staff’s guidance and assistance in this matter. If you have any questions, please contact the undersigned
and our legal counsel: Libertas Law Group Inc., Mark Abdou at (310) 359-8742; or Ruba Qashu at (949) 355-5405.

Very
truly yours,

Barfresh
Food Group, Inc.

    /s/
    Joseph Tesoriero

    Joseph
    Tesoriero, Chief Financial Officer

    cc:
    Mr.
    Riccardo Delle Coste, Chief Executive Officer

    Mark
    Abdou, Esq.

    Ruba
    Qashu, Esq.