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CORRESP
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 Freight
Technologies, Inc.

 2001
Timberloch Place, Suite 500

 The
Woodlands, TX 77380

 August
7, 2025

 Division
of Corporation Finance

 Office
of Energy & Transportation

 US
Securities & Exchange Commission

 100
F Street, NE

 Washington,
D.C. 20549

 Attn:
Lily Dang and Karl Hiller

 Re:
Freight Technologies, Inc.

 Form
10-K for the Fiscal Year ended December 31, 2024

 Filed
April 14, 2025

 File
No. 001-38172

 Dear
Lily Dang & Karl Hiller:

 We
hereby submit the responses of Freight Technologies, Inc. (the "Company") to the comments of the staff (the "Staff")
of the U.S. Securities and Exchange Commission (the "Commission") set forth in the Staff's letter, dated July 24, 2025,
providing the Staff's comments with respect to the Company's annual report on Form 10-K for the fiscal year ended December
31, 2024 (the "Annual Report").

 For
the convenience of the Staff, the Staff's comments are included and is followed by the response of the Company. Unless the context
indicates otherwise, references in this letter to "we," "us" and "our" refer to the Company on a
consolidated basis.

 Annual
Report on 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. 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.

 1

 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.

 Response :
The Company does not consider the amortization of our internally developed software to be a direct cost of our freight brokerage revenue
because: 1) neither our customers nor our carrier partners pay any type of fee to use the Fr8App platform or to download the mobile app;
and, 2) our customers typically do not interact directly with our platform when booking freight services. Typically, our customers and
carriers communicate via email, messaging services, phone calls, etc. with our operations and support teams, who use the platform to
match, book, manage and track loads. Our operations and support team members then communicate back to our customers and carriers.

 Our
back office operations are managed on our internally developed software, which is essential for providing our services, but our Fr8App
software is typically not customer-facing for our freight brokerage services, which include Fr8App, Fr8Fleet, Fr8Now and Waavely. In
that respect, it is more like our customer relationship management (CRM) software, enterprise resource planning (ERP) software, office
communication applications and other internally used software platforms that are used for managing business operations. The direct margin
Fr8Tech captures on each freight transaction is the difference between what we charge our customers and what we pay our carriers, and
no revenue is generated from the Fr8App platform itself for our brokerage services. We therefore consider the gross profit for our brokerage
services to be the difference between brokerage revenue and carrier costs.

 To
note, we have noticed that other publicly traded companies engaged in freight brokerage services reflect their depreciation and amortization
of internally developed software in a similar way, as an operating expense. Forward Air Corporation (Nasdaq: FWRD) is an example of one
such company.

 Lastly,
when we recognize revenue from the sale of Fleet Rocket, our transportation management system software, we will consider the amortization
of internally developed software for that offering to be a direct cost of revenue and therefore part of our gross profit and gross margin
analysis. As of December 31, 2024, however, the Company had not yet recognized any Fleet Rocket revenue.

 2

 If
you would like to discuss any of the responses to the Staff's comments or if you would like to discuss any other matters, please
contact the undersigned at don.quinby@fr8hub.com or via phone on +1 (916) 501-9059 or Louis A. Bevilacqua of Bevilacqua PLLC at Lou@bevilacquapllc.com
or via phone on (202) 869-0888 (ext. 100).

 Sincerely,

 FREIGHT TECHNOLOGIES, INC.

 By:
 /s/ Donald Quinby

 Donald Quinby

 CFO

 cc: Louis
 A. Bevilacqua

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