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 July 24, 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
 Response Letter dated June 26, 2025
 File No. 001-38172
Dear Don Quinby:

 We have reviewed your June 26, 2025 response to our comment letter and
have the
following comment.

 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.
Unless we note otherwise, any references to prior comments are to comments in
our June 5,
2025 letter.

Form 10-K for the Fiscal Year ended December 31, 2024
Management's Discussion and Analysis, page 44
Cost of Revenue, page 45

1. We understand from your response to prior comment 2 that you regard the
cost of
 revenue for freight brokerage and dedicated services to be entirely
comprised of the
 costs incurred and invoiced by the carriers for the services they
provide, and that you
 regard all of the depreciation and amortization expense, including
amounts related to
 your internally developed software, to be operating expenses and not
attributable to
 cost of revenue in accordance with generally accepted accounting
principles.

 However, the accounting policy disclosures on page F-12 refer to
internally developed
 software projects and indicate these are utilized to provide services to
your customers.
 July 24, 2025
Page 2

 The disclosures on pages 7 and 10 through 18 explain that your freight
management
 business is based on offering "a diverse portfolio of proprietary
platform solutions"
 which you describe as being interconnected within a unified platform
that connects
 Carriers and Shippers. You identify several of these applications, such
as Fr8App,
 Fr8Now, Fr8Fleet, Fr8Radar, Waavely, and Fleet Rocket, and describe the
various
 circumstances under which they are differentiated, including the types
of shipping
 arrangements or customers they are designed to manage or serve.

 Based on these disclosures, please explain to us why you believe that
amortization of
 internally developed software costs would not be regarded as a cost of
revenue under
 generally accepted accounting principles, considering the guidance on
analogous costs
 in the context of inventory and contract accounting such as FASB ASC
330-10-30-1
 and 8, and FASB ASC 340-40-25-7(c), also considering the presentation
requirements
 in Rule 5-03.2 of Regulation S-X. We reissue prior comment 2.

 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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