SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C.  20549

       DIVISION OF
CORPORATION FINANCE

 April  19, 2018

David L. Kanen
President
Kanen Wealth Management, LLC
5850 Coral Ridge Drive , Suite 309
Coral Springs , FL 33076

 Re: Aqua Metals, Inc.
PRE C14A preliminary proxy statement filing made on Schedule 14A
Filed on April  11, 2018 by Kanen Wealth Management , et al.
  File No.  001-37515

Dear M r. Kanen :

We have reviewed the above -captioned  filing , and have the following comments.   Some
of our comments may ask for additional information so that we may better understand the
disclosure.

Please respond to this letter by amending the filing and/or by providing the requested
information.  If you do not believe our comments apply to you r facts and circumstances and/or
do not believe an amendment is appropriate, please tell us why in a written  response.

  After reviewing any amendment to the filing and any information provide d in response to
these comments, we may have additional comments.

General

1. The letter  addressed  to stockholders  accounts for the anticipated  date upon which the
participants expect to “furnish ” the proxy statement to stockholders.  Please revise to include
this representation within  the p roxy statement, a define d term under Rule 14a -1(g), as
disting uished from the voluntary correspondence  with stockholders.  Refer to Rule 14a -6(d).

2. Please advise us, with a view toward revised disclosure, how exactly the proxy statement will
be furnished to stockholders.  Refer to Rule 14a -3, Rule 14a -4(f), and Rule 14a -16.

David  L. Kanen
Kanen Wealth Management, LLC
April  19, 2018
Page 2

 Reasons for the  Solicitation, page 6

3. Each statement or assertion of opinion or belief must be clearly characterized as such, and a
reasonable factual basis must exist for each such opinion or belief.  Support for opinions or
beliefs should be self -evident, disclosed in the proxy statement or provided to the staff on a
supplemental basis.   Accordingly, please provide your basis for your statements at the bottom
of page 6 that board members of c ompanies that are the size of Aqua Metals “typically make
$25,000 to $40,000” and that earning approximately $150,000 is “unusual and excessive.”

Proposal No. 1 – Election of Directors , page 12

4. Advise us, with a view towards disclosure,  whether election of a majority or more of your
director  nominees will result in a change of control as defined under any of the regis trant’s
organizational documents , executive compensation arrangements, or debt instruments.

Additional Participant Information , page 19

5. The disclosure indicates each parti cipant may be deemed to beneficially own the 2,6060,878
shares of common stock owned in the aggregate by  all of the participants by  virtue of their
membership in a group as determined under §13(d)(3).  Please provide us  with a legal
analysis in support of this conclusion.  Alternatively, please re move the  implication that
membership in a group, alone and without more, results in the bene ficial ownership held by
each group member being attributed to all members of the group.  Application of Rule 13d -
5(b), titled “Acquisition of securities, ” only results in  an acquisition , by operation of law , by
the group ─ designated as a single, new person under §13(d)(3)  ─ of its members securities.

 We remind you that the participants are responsible for the accuracy and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

  You may contact Joseph McCann , Attorney -Advisor, at (202) 551 -6262  or me at (202)
551-3266 with any questions.

Sincerely,

        /s/ Nicholas P. Panos

Nicholas P. Panos
Senior Special Counsel
Office of Mergers & Acquisitions

cc: Andrew M. Freedman , Esq.
            Olshan  Frome Wolosky LLP