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 August 6, 2025

Scott Wallace
Chief Executive Officer
ECD Automotive Design, Inc.
4390 Industrial Lane
Kissimmee, Florida 34758

 Re: ECD Automotive Design, Inc.
 Amendment No. 1 to Form 10-K for the Fiscal Year Ended December 31,
2024
 Filed July 16, 2025
 Form 10-K for the Fiscal Year Ended December 31, 2024
 Filed April 15, 2025
 File No. 001-41497
Dear Scott Wallace:

 We have limited our review of your filing to the financial statements
and related
disclosures 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.

Amendment No. 1 to Form 10-K for the Fiscal Year Ended December 31, 2024
Exhibits 31 and 32

1. We note that Section 302 and 906 certifications were not included in
your Form 10-
 K/A filed on July 16, 2025. Please file a full amended Form 10-K and
 provide currently dated officers' certifications in Exhibits 31 and 32
as required by
 Item 601 of Regulation S-K.
Report of the Independent Registered Public Accounting Firm

2. We note the auditors' report includes some, but not all, disclosures
required in a going
 concern paragraph and also includes additional disclosures such as If
the Company is
 unable to raise sufficient funding, it may struggle to reach its future
obligations and
 the Company has determined that these factors raise substantial
doubt. Please be
 advised that PCAOB Auditing Standard 2415 states the auditor has a
responsibility to
 August 6, 2025
Page 2

 evaluate whether there is substantial doubt about an entity's ability to
continue as a
 going concern for a reasonable period of time, not to exceed one year
beyond the date
 of the financial statements being audited. If your auditor concluded,
after considering
 identified conditions and events and management's plans, there is
substantial doubt
 about your ability to continue as a going concern for a reasonable
period of time,
 please file an amended Form 10-K and have the auditor revise their
report to include
 an explanatory paragraph, immediately following the opinion paragraph
and
 appropriately titled, that complies with the disclosure requirements set
forth in
 paragraph 13 of PCAOB Auditing Standard 2415. If your auditor did not
 conclude there is substantial doubt about your ability to continue as a
going concern
 for a reasonable period of time, please have them explain to us the
purpose of
 the current explanatory paragraph in their report, including how and why
they believe
 it complies with PCAOB Auditing Standard 3101. This comment is also
applicable to
 the auditors' report included in your current registration statement on
Form S-1 filed
 on July 16, 2025.
Form 10-K for the Fiscal Year Ended December 31, 2024
Item 9A. Controls and Procedures
a) Evaluation of Disclosure Controls and Procedures, page 79

3. We note your disclosures do not include management's conclusion that
disclosure
 controls and procedures were not effective as of December 31, 2024 as
required by
 Item 307 of Regulation S-K. Please file an amended Form 10-K to comply
with Item
 307 of Regulation S-K.
 In closing, 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 Dale Welcome at 202-551-3865 or Anne McConnell at
202-551-3709
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
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