SecProbe.io

CORRESP
1
filename1.htm

January
22, 2020

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

    Re:

    Toughbuilt
    Industries, Inc.

    Registration
    Statement on Form S-1

    File
    No. No. 333-235971

Acceleration
Request

    Requested
    Date:
    January
    23, 2020

    Requested
    Time:
    9:10
    a.m. Eastern Time (US)

Ladies
and Gentlemen:

In
connection with the above-referenced Registration Statement, and pursuant to Rule 461 under the Securities Act of 1933, as amended
(the “Act”), we, as representative of the underwriters, hereby join in the request of Toughbuilt Industries, Inc.
(the “Company”) that the effective date of the Registration Statement be accelerated so that it will be declared effective
at 9:10 a.m., Eastern Time (US), on January 23, 2020, or at such later time as the Company, acting through its counsel, Jolie
Kahnn, Esq., may request via a telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange
Commission

This
request supersedes our prior request for acceleration submitted on January 21, 2020.

Pursuant
to Rule 460 under the Act, we wish to advise you that we distributed 483  copies of the Preliminary Prospectus dated January
21, 2020 through the date hereof, to underwriters, dealers, institutions and others.

The
undersigned, as representatives of the several underwriters, have complied and will comply, and we have been informed by the participating
underwriters that they have complied and will comply, with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

    Very
    truly yours,

    Acting
    on behalf of itself and the several Underwriters

    MAXIM
    GROUP LLC

    By:
    /s/
    Clifford Teller

    Name:
    Clifford
    Teller

    title:
    Executive
    Managing Director, Head of Investment Banking