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November 8, 2023
Darren Lampert
Chief Executive Officer
GrowGeneration Corp.
5619 DTC Parkway , Suite 900
Greenwood Village, Colorado 80111
Re:GrowGeneration Corp.
Form 10-K for Fiscal Year Ended December 31, 2022
Filed March 16, 2023
File No. 001-39146
Dear Darren Lampert:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 25
1.We note your disclosure on page 3 detailing how you evaluate your operations includes a
discussion of the specific types of products offered (hydroponic garden products,
including nutrients, growing media, lighting, environmental control systems, accessories
for hydroponic gardening, and sales and installation services of commercial fixtures), the
distinction and margin variations between consumables and non-consumables, and how
product mix between new and more mature markets impacts margin, including the impact
of revenue earned from installations. Please expand your discussion of sales and cost of
sales to include a more fulsome discussion, including how the methods you use to
evaluate your business impact the variances from year to year and by segment, as these
appear to constitute known trends. Similar revisions should be made to your quarterly
filings, as appropriate. Refer to the guidance in Items 303(b)(2)(ii) and 303(c)(2) of
Regulation S-X.

 FirstName LastNameDarren Lampert
 Comapany NameGrowGeneration Corp.
 November 8, 2023 Page 2
 FirstName LastName
Darren Lampert
GrowGeneration Corp.
November 8, 2023
Page 2
2.Please tell us your consideration of presenting revenue disaggregated on the same basis as
discussed here. In this regard, we note from your presentation in Note 17 that you
currently present disaggregated revenue by segment based on private label versus non-
private label sales, but do not include this as a means by which you evaluate your
operations per your disclosure on page 3. Include in your response how you determined
the current presentation complies with ASC 606-10-50-5 through 7 and 606-10-55-89
through 91.
3.Please tell us how you considered Rule 5-03 of Regulation S-X in determining that
separate presentation of revenue from installation services on the face of the statement of
operations was not required.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            Please contact Amy Geddes at 202-551-3304 or Theresa Brillant at 202-551-3307 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services