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 June 5, 2025

Don Quinby
Chief Financial Officer
Freight Technologies, Inc.
2001 Timberloch Place, Suite 500
The Woodlands, Texas 77380

 Re: Freight Technologies, Inc.
 Form 10-K for the Fiscal Year ended December 31, 2024
 Filed April 14, 2025
 File No. 001-38172
Dear Don Quinby:

 We have reviewed your filing 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 the Fiscal Year ended December 31, 2024
Management's Discussion and Analysis, page 44
Revenues, page 45

1. Please expand your disclosures to include a summary table of the
non-financial
 operating measures for each period, as pertaining to revenues of the
Freight
 Transportation Brokerage and Dedicated Capacity segments, including
measures that
 are specific to your FTL, LTL, and ocean container shipments, and the
shipping
 capacity sold, to comply with Item 303(a) of Regulation S-K.

 For example, these should include volumetric and unitary measures such
as the
 number of shipments, miles transported, trucks providing capacity,
average prices per
 unit, and any other details that are correlated with your peformance
obligations and
 relevant to understanding the activity that is reflected in your
financial statements.

 Please also disclose the extent to which material changes in revenues
are attributable
 to changes in volumes, and separately to changes in prices, product mix,
and other
 factors to comply with Item 303(b) and (b)(2) of Regulation S-K.
 June 5, 2025
Page 2

Costs of Revenues, page 45

2. Please expand your discussion and analysis pertaining to cost of
revenues as necessary
 to clearly describe the composition and nature of items included in your
costs of
 revenues; and include corresponding details adjacent to your revenue
recognition
 accounting policy disclosures on pages F-14 and F-15 of the financial
statements.

 As you appear to disclose a measure of gross margin that excludes
depreciation and
 amortization that is related to cost of revenue, this would be
considered a non-GAAP
 measure. If the measure is incomplete and you wish to retain the
non-GAAP measure,
 please revise the label and add disclosures to comply with item 10(e) of
Regulation S-
 K, including presenting and discussing the most directly comparable GAAP
measure,
 with equal or greater prominence, and including a reconciliation.

 Under this scenario we believe the most directly comparable GAAP measure
would
 be gross margin, reflecting all costs of sales. However, if depreciation
and
 amortization is not attributable to cost of sales, explain to us your
view and the
 reasons for the parenthetical captions utilized in your financial
presentations.

Other Income and Expenses, page 47

3. We note that you report a gain of $1.6 million in 2024 resulting from
extinguishments
 of convertible notes issued in 2023 and promissory notes issued in 2024,
having
 Freight Opportunities, LLC as the counterparty, according to the
disclosures on pages
 F-20 and F-23. On page 62, you indicate this entity, along with Freight
Opportunities
 II, LLC, collectively beneficially own or control 91.1% of your shares.

 Please expand your disclosure herein to provide further details
regarding the terms of
 the cancellation agreements, and of the obligations that have been
extinguished,
 including the circumstances precipitating the event, the principal and
interest balances
 of the notes that were cancelled, and any related consideration or
contingency.

Changes in and Disagreements with Accountants on Accounting and Financial
Disclosures,
page 50

4. We note that you have endeavored to provide certain required information
about your
 relationships with three accounting firms that had been engaged to
conduct auditing
 and review services. However, various representations and dates within
these
 disclosures are inconsistent with prior disclosures or not clearly
aligned. Please revise
 your disclosures as necessary to correct errors and misrepresentations
to include
 revisions that address the following points.

 Your statement that UHY LLP resigned is not consistent with the
report that you
 filed on July 10, 2024, which indicates that UHY LLP was dismissed.
 June 5, 2025
Page 3

 Your statement that Marcum LLP was engaged on June 20, 2024 is not
consistent
 with the report that you filed on January 10, 2025, which indicates
that Marcum
 LLP was engaged August 22, 2024.

 It appears that you intended to specify the periods prior to your
dismissal of
 Marcum LLP in the sixth paragraph, in making a representation about
whether or
 not there were disagreements or reportable events, although you
reference an
 interim period that is not aligned with the date of their dismissal,
and is not
 consistent with the report that you filed on January 10, 2025, which
covers the
 period up to the date of dismissal.

 You have duplicate representations in the first and fifth
paragraphs stating that
 Marcum LLP "has not provided any audit services to the Company
subsequent to
 July 4, 2024" (which is the date that you also associate with the
resignation of
 UHY LLP). Clarify whether these are accurate with respect to Marcum
LLP, or if
 one of these should pertain to UHY LLP, and if a different date is
needed to align
 with the audit and review work of Marcum LLP.

 Your statement that Marcum LLP resigned is not consistent with the
report that
 you filed on January 10, 2025, which indicates that you dimissed
Marcum LLP.

 You have duplicate representations in the third and seventh
paragraphs about a
 letter from Marcum LLP that is filed as an exhibit. Clarify whether
one of those
 was intended to express something similar with respect to UHY LLP.

 The seventh paragraph indicates that you asked Marcum LLP to
provide a letter
 regarding the views of UHY LLP, which does not correlate with the
disclosure
 requirement or the contents of the letter that you have filed as an
exhibit.

 Your representation in the last paragraph regarding the engagement
of TAAD
 LLP and whether the firm had been consulted with respect to certain
matters prior
 to its engagement, does not fulfill the disclosure requirement
because you
 reference Marcum LLP instead.

5. We note your disclosures indicating that you engaged Marcum LLP as
 your independent registered public accounting firm on June 20, 2024, and
that the
 firm resigned on January 7, 2025.

 Please explain to us the reasons that Marcum LLP resigned, including
details of any
 precipitating circumstances and any communications involving the company
during
 the period of the engagement. Please also describe for us in reasonable
detail the
 extent to which the firm had conducted audit and review work during the
period of
 their engagement, including details of the scope of procedures
performed, and the
 extent of any such work that was conducted in your offices or
facilities, and tell us the
 June 5, 2025
Page 4

 amount of any fees that you paid to Marcum LLP in connection with their
services
 and explain how those fees have been reported in the table on page 64.

Controls and Procedures, page 51

6. We note you disclosure indicating internal control over financial
reporting (ICFR)
 was assessed and found to be not effective at December 31, 2024 due to
significant
 deficiencies and material weaknesses in ICFR, including certain "invoice
and
 fulfilment reconciliations with the customer and general ledger entries
related to
 dedicated service invoices and adjustments thereto were not always
completed in a
 timely manner for internal reporting purposes."

 Given the areas of overlap between ICFR and disclosure controls and
procedures
 (DCP), and considering the nature of the material weaknesses and the
various
 disclosure concerns outlined in the other comments in this letter,
please clarify how
 you would conclude that DCP were effective at December 31, 2024.

Principal Accountant Fees and Services, page 64

7. We note your disclosures about All Other Fees on page 65 indicating the
independent
 accountant may have been compensated "for products and services"
although also
 stating that the principal accountant was not engaged to render any
services during the
 last two fiscal years other than as indicated in the other fee
classifications.

 However, given that you report having paid the independent accountant
$111,750 for
 products and services that were incremental to the audit and review
services, it
 appears that you should expand your disclosure to describe the nature of
the services
 that your accountant provided to comply with Item 14(4) of Form 10-K.

 Please submit the disclosures that you propose to address this
requirement.

 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 Lily Dang at 202-551-3867 or Karl Hiller at 202-551-3686
if you have
questions regarding comments on the financial statements and related matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
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