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    Ameriguard Security Services, Inc.

    5470 W. Spruce Avenue, Suite 102

    Fresno, CA 93722

May 19, 2023

Via Edgar

United State Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, DC 20549

 Attention: Patrick Kuhn

Linda Cvrkel

Jennie Beysolow

Jennifer López Molina

Re: Ameriguard Security Services, Inc.

Registration Statement on Form S-1

Filed April 10, 2023

File No. 333-271200

Dear Sir or Madam:

Ameriguard Security Services, Inc. (the “Company”)
is hereby responding to your recent review letter addressed to Lawrence Garcia, Chief Executive Officer of the Company, dated May 4, 2023
(the “SEC Letter”), and is filing an amendment (the “Amendment”) to the Registration Statement on Form S-1 (the
“Registration Statement”). This response letter addresses the concern you have expressed. The following numbered response
correspond to the comment number in the SEC Letter.

Registration Statement on Form S-1 filed April 10, 2023

Cover page

1. We note that your common stock is quoted
on the OTC Pink market and you state that selling stockholders may sell their shares at prevailing market prices. Please note that the
OTC Pink market is not an established public trading market into which a selling stockholder may offer and sell shares at other than a
fixed price. Accordingly, please revise your disclosure throughout to disclose a fixed price at which the selling stockholders will offer
and sell shares. Refer to Item 501(b)(3) of Regulation S-K.

We have amended the disclosure in the Registration
Statement to reflect a fixed price of market plus $0.25

2. Please revise to disclose that the
selling security holders are acting as underwriters for purposes of the Securities Act of 1933, as amended, and the rules and
regulations thereunder. In this regard, it appears that the shares issued to the selling security holders were issued while you were
a shell company or recently thereafter, and that the shares being sold represent a substantial part of your outstanding shares held
by affiliates. Therefore, Rule 144 does not appear to be available to you, and each of the selling stockholders is considered an
underwriter. See Schedule A, Item 16, of the Securities Act and Item 501(b)(3) of Regulation S-K; and SEC Release 33-8869. Please
make appropriate revisions to the prospectus summary and plan of distribution and ensure consistency throughout the registration
statement, by deleting references that the selling shareholder "may be deemed" underwriters.

We have edited the Amendment throughout to clarify
that the selling shareholders are underwriters for purposes of the Securities Act.

3. Please revise to disclose the selling shareholders'
net proceeds on a per share basis and for the total amount of the offering. Refer to Item 501(b)(3) of Regulation S-K.

We have revised the cover page to reflect the
net proceeds per share and aggregate amount for the offering.

Prospectus Summary

Corporate History, page 1

4. In the last paragraph of this section and
also in the first paragraph on page 18, please update revenue generated from guard services to the latest period presented in your filing,
December 31, 2022. Your current disclosure provides revenues for the fiscal year ended December 31, 2021.

We have updated the disclosure to reflect the
most recent period presented which is December 31, 2022.

Impact of COVID, page 5

5. Please revise here and in the Management
Discussion and Analysis to address and quantify, if material, the impact of the staffing shortages, which you state have been the greatest
impact resulting from the COVID pandemic.

We have revised the disclosure to address the
impact COVID-19 had on staffing. We also did further analysis of the actual cost of the increased OT and did not find it to be material
to the overall operations for the year ending December 2022. With the lifting of the federal vaccination mandate, the COVID pandemic no
longer effects our staffing numbers and abilities. Also, we have struck the paragraph in the MD&A section titled potential impact
of COVID 19 due to the lifting of all Covid restrictions nationwide in May 2023. As a result we no longer believe that COVID have an impact
on the Company’s ability to operate or to raise capital.

    2

Risk Factors, page 5

6. We note statements throughout your
risk factor section that compare you to other industries. For example, we note your disclosure that "like all industries
today...[you are] not exempt from staffing shortages," "all industries struggle when operating in times of
inflation," and "like all industries as new or other disruptive technology...could negatively impact the need for [y]our
services." To provide additional context for investors, please provide your basis for these statements, or revise to
characterize them as your own belief.

We have revised the Amendment to remove any references
to other industries.

Risks Related to Our Corporate Business, page
5

7. Please revise your risk factors regarding
“Concentration of Revenue” and “Long process in acquiring contracts” or add a new risk factor to emphasize the
importance of the new contracts for acquisition opportunities discussed in the Management’s Discussion and Analysis and Results
of Operations section, the first of which you state will be completed by the second quarter and at least two in the next eighteen months
and discuss the impact to your financial condition if you do not obtain or fulfill these contracts for acquisition opportunities.

We have added a new Risk Factor regarding our
dependence on acquisitions.

If we are unable to establish appropriate internal
financial reporting controls and procedures...,

page 6

8. Please expand your risk factor to clarify
your disclosure that "[m]anagement has already identified individuals and consultants who can support management’s efforts
to comply with all internal controls and reporting requirements," to state if you have any legally binding agreements with these
individuals and name such individuals.

We have removed the reference to the identified
individuals and consultants.

Risks Related to Our Stockholders and Purchasing
Shares of Common Stock

The market valuation of our business may fluctuate
due to factors beyond our control and the

value of your investment..., page 8

9. We note your reference to emerging growth
company status in this section. Please revise to remove this statement and ensure consistency throughout the registration statement.

We have removed any references to the Company
as an emerging growth company.

Future sales or perceived sales of our common
stock could depress our stock price, page 9

10. We note your reference that this resale
prospectus covers 3,585,946 shares of common stock underlying the warrants. Please advise us and revise the notes to your financial statements
to disclose the nature and terms of your warrants and the nature and terms of the transactions in which the warrants were issued.

We have revised the Amendment to remove any references
to warrants.

    3

The Selling Shareholders, page 14

11. We note your disclosure that “[n]one
of the Selling Shareholders nor any of their associates or affiliates has held any position, office, or other material relationship with
[you] in the past three years.” Please revise this section to clarify disclosure responsive to Item 507 of Regulation S-K, including
the nature of any material relationship which any selling security holder has had within the past three years with you or your affiliates.
In this regard, we note a reference to Lawrence Garcia Jr. as a selling security holder of common stock being registered in this offering
and disclosure on page 1 about the appointment of Lawrence Garcia as the Company’s President, CEO, CFO, Treasurer, Secretary, and
Chairman of the Board of Directors during the prior three years. To the extent that a material relationship between these individuals
does exist, please include disclosure in your amended filing describing such relationship.

We have included disclosure regarding the relationships
of certain selling shareholders with Lawrence Garcia, our CEO, in the Amendment.

Business, page 18

12. Please describe the competitive business
conditions and your company’s competitive position in the industry and methods of competition. In this regard, we note your reference
throughout the document to competitors on pages 5, 8-9, and 24, including to competitors with a high level of security clearance of which
you plan to acquire; and to technology innovations on page 6 which you state could negatively impact the need for your services. Refer
to Item 101(h)(4)(iv) of Regulation S-K.

We have included a paragraph discussing our competitive
position.

13. We note references to restricted and
carveout contracts throughout your registration statement. Please revise to discuss such contracts, their terms and impact on your
business.

We have edited the paragraphs on page 5 and 6
connecting and further describing the impact of the carve out contracts offered from government agencies.

14. Your disclosure suggests that acquisition
of companies is an essential part of your business. Please disclose, if true, that you currently do not have any agreements with potential
acquisition targets.

We have added disclosure that we currently do
not have any agreements with potential targets.

Corporate History, page 18

15. Please revise to clarify which merger agreement
pursuant to which you “…acquired the business of Ameriguard and will continue the existing business of Ameriguard as our
wholly owned subsidiary.” In this regard, we note your earlier reference to a merger agreement that you entered into on February
10, 2012, with Health Revenue Assurance Holdings, Inc. Please make conforming revisions in your Summary section to ensure clear and consistent
disclosure throughout the filing.

We have revised the disclosure throughout the
Amendment to clearly identify the referenced agreement.

    4

Our Industry, page 19

16. Please revise to provide the basis for
your conclusion that “Ameriguard’s approximately $22 million in annual revenue places [you] within the top 25 firms in the
country.” In this regard, we note that your cited source to the 2021 U.S. Contract Security Market White Paper only appears to provide
an overview of the five world leaders with at least $1 billion in revenues as of 2020. Please make conforming revisions throughout the
document. As a related matter, we note that the prospectus includes market data based on information from third-party sources. Please
tell us if you commissioned any of the industry or other data that you reference in the prospectus and, if so, file consents of such parties
pursuant to Rule 436 of the Securities Act as exhibits to your registration statement or advise.

We have removed references citing specific industry
conclusions from the Amendment.

Regulatory Matters/Compliance, page 20

17. We note your disclosure that
"[c]ontracting officers have indicated that they believe the government has no concern relating to the merger as long as the
responsible person(s) remain." Please revise to identify the "responsible person(s)" and their role
"remaining" in the company to ensure compliance with relevant regulations. As a related matter, please also revise to
describe the relevant regulations related to your business. Refer to Item 101(h)(4)(ix) of Regulation S-K.

We have removed the above reference to contracting
officers and added the relevant regulations concerning our business.

Management's Discussion and Analysis and Results
of Operations

Corporate Structure, page 21

18. We note that you have "begun the process
of [y]our first equity raise with Think Equity." Please tell us the exemption from registration on which you relied and the basis
for doing so. Please also file as an exhibit the agreement entered into with Think Equity, or please explain why you are not required
to do so. Refer to Item 601(b)(10) of Regulation S-K.

We have removed the references to Think Equity,
as we have not proceeded with that transaction.

Results of Operations for the fiscal year ending
December 31, 2022

Net Income/(Loss) from Operations, page 22

19. Please provide a discussion of your net
loss for fiscal year end December 31, 2022 rather than combining it with 2021 net income to arrive at "total operational income".
Your discussion and analysis of your results of operations should discuss material changes from period to period in your historical results
for the periods presented in your audited financial statements. Refer to the guidance in Item 303 of Regulation S-K.

We have made the above changes in the Amendment.

    5

Liquidity and Capital Resources, page 23

20. Please reconcile the amounts
presented in your liquidity and capital resources discussion with the amounts presented in your statements of cash flows. For
example, you discuss that cash used from financing activities was approximately $1,160,000 but your statements of cash flow presents
cash provided by financing activities of $71,049. Likewise, your discussion of net cash generated from operations of approximately
$258,000 does not agree with your statements of cash flows.

We have updated our statements regarding cash
activities and updated the cash flow statement as suggested in comment number 29.

21. Please revise here and in your
Summary to discuss the material terms of the loans related to loan payments of $180,000, other long term debt financing, and the
promissory note related to the July 2022 shareholder buyout agreement, including large related-party loans and total current
liabilities. Please also file the related agreements as exhibits to the registration statement. Refer to Item 601(b)(10) and
Instruction 4 to Item 504 of Regulation S-K.

We have included the material terms of any material
debt financing of the Company. The agreements related to the shareholder buyout agreement were included in our Form 8-K filed on December
14, 2022.

Legal Proceedings, page 28

22. Please revise to clarify whether you are
a party to or of which your property is the subject of any current or pending legal proceedings. In this regard, we note that you limit
your disclosure to litigation related to the performance of your guard services. Refer to Item 103 of Regulation S-K.

We have revised the Section in the Amendment to
include the information required.

Conclusion Regarding the Effectiveness of Disclosure
Controls and Procedures, page 32

23. Please provide your conclusion regarding
the effectiveness of your disclosure controls and procedures as of December 31, 2022. Your current disclosure is as of December 31, 2021
and requires updating. In addition, provide all of the disclosures required by Item 307 of Regulation S-K and Rule 13a-15(e) under the
Securities Exchange Act of 1934.

We have updated the disclosure to cover the year
ended December 31, 2022 and included all required information.

Management's Annual Report on Internal Control
over Financial Reporting, page 33

24. Please provide your assessment of the effectiveness
of your internal control over financial reporting as of December 31, 2022. Your current disclosure is as of December 31, 2021 and requires
updating.

We have updated the disclosure to cover 2022.

    6

25. In the second paragraph you state
that your disclosure controls and procedures were ineffective but your disclosure on page 32 says your disclosure controls and
procedures were effective. Please reconcile and revise these disclosures.

We have revised the disclosure to consistently
state that our disclosure controls and procedures were not effective.

Executive Compensation, page 34

26. Please revise to reconcile your
disclosure regarding executive compensation. In this regard, we note your disclosure on page 34 that “[d]uring the years ended
December 31, 2022, and December