SecProbe.io

CORRESP
1
filename1.htm

November
27, 2019

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

    Attn:
    Thomas
    Jones

    Re:
    Aqua
    Metals, Inc.

    Registration
    Statement on Form S-3

    File
    No. 333-235238

    Acceleration
    Request

    Requested
    Date:
    Monday,
    December 2, 2019

    Requested
    Time:
    4:30
    p.m., Eastern Daylight Time

Ladies
and Gentlemen:

In
accordance with Rule 461 under the Securities Act of 1933, as amended, the undersigned registrant, Aqua Metals, Inc.(the “Registrant”),
hereby requests that the Securities and Exchange Commission (the “Commission”) take appropriate action
to cause the Registration Statement on Form S-3 (File No. 333-235238) (the “Registration Statement”)
to become effective on December 2, 2019, at 4:30 p.m., Eastern Daylight Time, or as soon as practicable thereafter, or at such
later time as the Registrant may orally request via telephone call to the staff of the Commission (the “Staff”).
The Registrant hereby authorizes Daniel Donahue of Greenberg Traurig, LLP, counsel to the Registrant, to make such request on
its behalf.

Once
the Registration Statement has been declared effective, please orally confirm that event with Daniel Donahue of Greenberg Traurig,
LLP, counsel to the Registrant, at (949) 732-6557.

In
connection with this request, the Registrant acknowledges that:

    ●
    should
    the Commission or the Staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does
    not foreclose the Commission from taking any action with respect to the Registration Statement;

    ●
    the
    action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective,
    does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration
    Statement; and

    ●
    the
    Registrant may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by
    the Commission or any person under the federal securities laws of the United States.

    Very
    truly yours,

    Aqua
    Metals, Inc.

    By:
    /s/
    Stephen Cotton

    Stephen
    Cotton,

    President
    and Chief Executive Officer

    cc:
    Daniel
    Donahue, Greenberg Traurig, LLP