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    VIA EDGAR SUBMISSION

    Ms. Cheryl Brown and Mr. Daniel Morris

    Division of Corporation Finance

    Office of Energy & Transportation

    Securities and Exchange Commission

    100 F Street NE

    Washington, D.C. 20549

    August 13, 2024

            Re:

            Piedmont Lithium Inc.

            Form 10-K for the Fiscal Year ended December 31, 2023

            Filed February 29, 2024

            File No. 001-38427

    Dear Mr. Coleman, Ms. Guobadia and Mr. Hiller,

    Please find our response to the comments set forth in a letter dated July 16, 2024 (the “Letter”) from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) relating
      to the above-mentioned Annual Report on Form 10-K.  References to the “Company,” “Piedmont,” “we,” “us” and “our” in this letter refer to Piedmont Lithium Inc., unless otherwise indicated.

    For your convenience, we have restated below in bold the comment from the Letter and supplied our response immediately thereafter.

    Form 10-K for the Fiscal Year ended December 31, 2023

    Properties, page 32

          1.

            Please expand your discussion of the Carolina Lithium mineral reserve to include the associated commodity price as required by Item 1304 (d)(1) of Regulation S-K.  Please also provide the
              commodity price and point of reference along with the summary resource and summary reserve tables as required by Item 1303(b)(3) of Regulation S-K.

    Response:

    The Company acknowledges the Staff’s comment regarding the summary tables and will comply with this comment in its future filings, beginning with the 2024 Form 10-K, by presenting the associated
      commodity price and point of reference with the summary resource and summary reserve tables in substantially the following form:

      1

    Summary Resources Table

    The following table provides a summary of our mineral resources, exclusive of reserves as of December 31, 2023.  Where applicable, the amounts represent our attributable portion based on ownership
      percentages previously noted.  The relevant technical information supporting mineral resources for each material property is included in the “Material Individual Properties” section below.  Relevant technical information supporting mineral resources
      for our non-material properties is included under the “Authier” and “Ewoyaa” sections below and in the technical report summaries attached as Exhibits 96.4 and 96.2 to this Annual Report.

              Measured Mineral

              Resources

              Indicated Mineral

              Resources

              Measured and

              Indicated Mineral

              Resources

              Inferred Mineral

              Resources

            (amounts in millions of metric tons)

            Amount

            Grade

            (Li2O%)

            Amount

            Grade

            (Li2O%)

            Amount

            Grade

            (Li2O%)

            Amount

            Grade

            (Li2O%)

            Lithium - Hard Rock:

            North America

            Carolina Lithium (1)

            —

            —

            9.96

            1.14%

            9.96

            1.14%

            15.93

            1.02%

            NAL (2)

            0.24

            1.00%

            2.22

            1.15%

            2.47

            1.14%

            11.22

            1.23%

            Authier (2)

            0.08

            0.80%

            1.08

            0.98%

            1.16

            0.97%

            2.16

            0.98%

            West Africa

            Ewoyaa (3)

            —

            —

            0.21

            1.09%

            0.21

            1.09%

            0.17

            1.07%

            (1)

              Lithium resources at Carolina Lithium at an effective date of October 20, 2021 were estimated at a spodumene concentrate price of $1,893 per metric ton.

            (2)

                As of December 31, 2023, we owned 34% of NAL and Authier through ownership in Sayona Mining and our Sayona Quebec joint venture (see “Item 2 Properties—Equity Method Investment Projects”). We
                  are therefore reporting 34% of NAL and Authier’s mineral resources. Lithium resources at NAL at an effective date of December 31, 2022 were estimated at a spodumene concentrate price of $1,273 per metric ton and lithium resources at
                  Authier at effective date of October 6, 2021 were estimated at a spodumene concentrate price of $977 per metric ton.

            (3)

                As of December 31, 2023, we owned 9% of Ewoyaa through our ownership in Atlantic Lithium. We are therefore reporting 9% of Ewoyaa’s mineral resources. Lithium resources at Ewoyaa at effective date of January 2023 were estimated at a
                  spodumene concentrate price of $1,587 per metric ton.

      Summary Reserves Table

    The following table provides a summary of our mineral reserves as of December 31, 2023.  Where applicable, the amounts represent our attributable portion based on ownership percentages previously noted.
      The relevant technical information supporting mineral reserves for each material property is included in the “Material Individual Properties” section below.  Relevant technical information supporting mineral
      reserves for our non-material properties is included under the “Authier” and “Ewoyaa” sections below and in the technical report summaries attached as Exhibits 96.4 and
      96.2 to this Annual Report.

      2

              Proven Mineral Reserves

              Probable Mineral Reserves

              Total Mineral Reserves

              (amounts in millions of metric tons)

              Amount

              Grade

              (Li2O%)

              Amount

              Grade

              (Li2O%)

              Amount

              Grade

              (Li2O%)

              Lithium - Hard Rock:

              North America

              Carolina Lithium (1)

              —

              —

              18.26

              1.10%

              18.26

              1.10%

              NAL (2)

              0.11

              1.43%

              6.88

              1.08%

              7.00

              1.09%

              Authier (2)

              2.11

              0.93%

              1.73

              1.00%

              3.84

              0.96%

              West Africa

              Ewoyaa (3)

              —

              —

              2.30

              1.22%

              2.30

              1.22%

            (1)

                Lithium reserves at Carolina Lithium at an effective date of December 31, 2021 were estimated at a spodumene concentrate price of $1,893 per metric ton.

            (2)

                As of December 31, 2023, we owned 34% of NAL and Authier through our ownership in Sayona Mining and Sayona Quebec joint venture (see “Item 2 Properties—Equity Method Investment Projects”). We
                  are therefore reporting 34% of NAL and Authier’s mineral reserves. Lithium reserves at NAL at an effective date of December 31, 2023 were estimated at a spodumene concentrate price of $1,352 per metric ton and lithium reserves at Authier
                  at an effective date of December 31, 2023 were estimated at a transfer price of C$120 per metric ton for run-of-mine ore between the Authier Project and NAL.

            (3)

                As of December 31, 2023, we owned 9% of Ewoyaa through our ownership in Atlantic Lithium. We are therefore reporting 9% of Ewoyaa’s mineral reserves.  Lithium reserves at Ewoyaa at effective date of June 16, 2023 were estimated at a
                  spodumene concentrate price of $1,587 per metric ton.

    Additionally, the Company acknowledges the Staff’s comment regarding Carolina Lithium’s reserves table and will comply with this comment in future Form 10-K filings, beginning with the 2024 Form 10-K, by
      presenting the associated commodity price and point of reference with the mineral reserve table for Carolina Lithium in substantially the following form:

      Carolina Lithium – Estimate of Mineral Reserves Effective as of December 31, 2021 (undiluted)

              Mineral Reserves

              Category

              Ore

              (MT)(1)

              Grade

              (Li2O%)

              Li2O

              (metric tons)(2)

              LCE

              (metric tons)

              Cut-Off Grade

              (% Li2O)

              Metallurgical

              Recovery

              Concentrator (%)(3)

              Proven

              —

              —

              —

              —

              0.4

              77

              Probable

              18.26

              1.10

              200,000

              495,000

            (1)

              Reserves are expressed as tonnages effectively delivered to a run-of-mine pad, prior to the application of losses and recovery factors (i.e., metallurgical recovery as expressed above) incurred during
                concentration and conversion.  Pricing to support mineral reserve economics is based upon the sale of lithium hydroxide, after the processing of run-of-mine reserves in the Company’s planned spodumene concentrator and lithium hydroxide
                conversion facilities.  Mineral reserves estimated exclusive of the mineral resources.

            (2)

              Based on long-term pricing of $1,893 per metric ton of spodumene concentrate.

            (3)

              Metallurgical recovery of 77 percent for lithium ore is associated with the production of a 6-percent spodumene concentrate.

    Consolidated Statements of Operations, page F-5

          2.

            We understand from your disclosure on page F-21 that your cost of sales and gross profit measures may not include depreciation.  We generally believe these measures would need to reflect
              depreciation and amortization that is attributable to cost of sales in accordance with GAAP.  The attributable portion should be included in your cost of sales measure or be presented separately and above your measure of gross  profit, in
              which case you should also adhere to the labeling conventions described in SAB Topic 11:B.

    Please also modify your discussion and analysis of the corresponding measures on page 66 to reflect the composition of the measures and to address any material effects of changes
      in depreciation and amortization on costs of sales.

      3

    Response:

      The Company acknowledges the Staff’s comment and advises the Staff that all revenue is generated through the re-sale of spodumene concentrate from our offtake agreement with Sayona Quebec. Due to the nature of our
        current operations, which do not yet involve the mining or manufacturing of the product we sell, we have no depreciable assets related to the spodumene concentrate we sell. As described in Note 8—Property, Plant
          and Mine Development in our consolidated financial statements in our 2024 Form 10-K, depletion of mining interests and mine development assets does not commence until the assets are placed in service. The vast majority of our property,
        plant and mine development assets as of December 31, 2023 consisted of mining interests and mine development costs associated with Carolina Lithium and construction in process associated with Tennessee Lithium, none of which were placed in service
        as of December 31, 2023. As such, we have not recorded depletion expense for any of our mining interests or mine development assets as of December 31, 2023. For the year ended December 31, 2023, the Company recognized $241,000 in total depreciation
        expense, which was recorded to selling, general and administrative expense as all depreciable assets related to corporate assets associated with facilities, equipment, and leasehold improvements.

    Note 8 - Property, Plant and Mine Development, page F-20

          3.

            We note that you have disclosed various acquisitions without describing the terms governing these transactions or the accounting applied.  For example, on page 35 you refer to an acquisition
              and earn-in agreement to purchase or earn interests in claims, on page 62 you indicate that you purchased a 132-acre disposal facility, and on page F-24 you indicate that you acquired an investment as part of a spin-out, without such details.

    Please disclose the material terms of arrangements under which these and other acquisitions occurred, such as the dates of the transactions, duration of any options, earn-in
      periods, any unresolved or open provisions, the amounts and forms of consideration, milestones or incremental investments required, methodology applied in valuing non-cash components, and any material contingencies or uncertainties.

    Response:

    The Company acknowledges the Staff’s comment and advises the Staff that it believes it has disclosed the material terms of such arrangements and related contingencies and uncertainties.

    The acquisition and earn-in agreement referred to page 35 refers to an agreement between North American Lithium (NAL) and Jourdan Resources, Inc, pursuant to which NAL acquired 20 claims in November
      of 2022 and has the ability to acquire 51% of an additional 28 claims.  Because the Company had only an approximate 34% indirect interest in NAL, its potential indirect interest in the Jourdan claims is not material to the Company as a whole.

    With respect to the 132-acre disposal facility, this acquisition is complete, is not material to the Company as a whole, involves no further options, earn-ins, milestones or contingencies, except to
      the extent the usefulness of this facility depends on the Tennessee Project as a whole, which risks the Company believes are adequately disclosed in its 2024 Form 10-K.

      4

    With respect to the spin-out referred to on page F-24, Atlantic Lithium Limited (“Atlantic Lithium”) conducted a pro rata spin-off of shares in Ricca Resources Limited shares to all of Atlantic
      Lithium’s shareholders in December of 2021.  The Company, by virtue of its ownership in Atlantic Lithium, received shares in Ricca Resources Limited in proportion to its ownership and without the payment of any consideration and without the Company
      taking any action.  We estimated the value of such shares at approximately $484,000 as of December 31, 2023, as disclosed in Note 10—Other Assets and Liabilities to our financial statements.  The Company
      believes that its disclosure in Note 10, in light of the Company’s overall financial position, is sufficient for an understanding of the nature and value of such equity securities.

    Based on the foregoing, the Company respectfully submits that disclosure of additional details with respect to the arrangements referred to above does not require additional footnote disclosure under
      GAAP because it is not material to an understanding of the financial statements.

    Exhibits

    96.3, page 78

          4.

            We note that the North American Lithium DFS technical report includes a cash flow analysis covering the life-of-mine, having differing assumptions regarding pricing through 2026 and after
              year 2026, where 50% of sales through 2026 would be based on contractual pricing and no sales beyond that year would be based on contractual pricing.

    Please explain to us the rational for the change in assumptions and how the assumptions through 2026 and beyond 2026 correlate with the terms of the contractual arrangements that
      are in place for sales of production.  If these assumptions are not consistent with the contractua