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    345 Park Avenue

New York, NY 10154
    Direct     212.407.4831

Main       212.407.4000

Fax          212.407.4000

September 29, 2025

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Thomas Jones

    Erin Purnell

    Re:
    ECD Automotive Design, Inc.

    Amendment No. 3 to Registration Statement on Form S-1

    Filed September 19, 2025

    File No. 333-288692

Ladies and Gentlemen:

On behalf of our client, ECD
Automotive Design, Inc., a Delaware corporation (the “Company”), we respond to the comments of the staff of the Division of
Corporation Finance of the U.S. Securities and Exchange Commission (the “Staff”) with respect to the above-referenced Amendment
No. 3 to Registration Statement (the “Registration Statement”) on Form S-1 filed on September 19, 2025, contained in the Staff’s
letter dated September 25, 2025 (the “Comment Letter”).

The Company has filed via
EDGAR Amendment No. 4 to the Registration Statement on Form S-1 (the “Amended Registration Statement”), which reflects the
Company’s responses to the comments received by the Staff and certain updated information. For ease of reference, each comment contained
in the Comment Letter is printed below and is followed by the Company’s response. All page references in the responses set forth
below refer to the page numbers in the Amended Registration Statement.

Amendment No. 3 to Registration Statement on Form S-1 filed September
19, 2025 Cover Page

1. Please tell us how you determined that it was appropriate to
register 300 million shares of your common stock pursuant to the equity purchase facility agreement.

COMPANY RESPONSE: The Equity
Purchase Facility Agreement (the “EPFA”) the Company entered into on June 20, 2025 provided that the Company can issue and
sell up to $500 million under the EPFA. At that time, the Company’s common stock was trading at approximately $0.31 per share. To
issue and sell $500 million at $0.31 per share, the Company would need to sell more than 1.6 billion shares, which is more than the 1
billion shares the Company has authorized for issuance. The Company determined to register up to 300 million shares in the Registration
Statement for sale under the EPFA. Following the 1:40 reverse split of the Company’s common stock, which occurred on September 18,
2025, the Company determined to continue with the registration of up to 300 million shares in the Registration Statement for sale under
the EPFA. Due to fluctuations in the price of the Company’s common stock, at this time it cannot be determined with certainty how
many shares of the Company’s common stock will need to be sold to raise $500 million under the EPFA. Accordingly, the Company has
determined to register 300 million shares of common stock in connection with the EPFA.

September 29, 2025

Page 2

2. We note your response to prior comment 1. Please revise the
disclosure in the second paragraph of the cover page to clarify that the selling securityholders will sell the warrants at a fixed price
of $460.00 until they are quoted on an exchange or trading market.

COMPANY RESPONSE: Please be advised
the Company is not registering the Private Warrants for resale in the Amended Registration Statement, rather, the Company is registering
the shares of common stock underlying the private warrants for resale. In response to the Staff’s comment, the Company has revised
the disclosure on the cover page and on page ii of the Amended Registration Statement.

There can be no assurance we will be able to comply with the continued
listing standards, page 25

3. We note the statements in your September 22, 2025 press
release that "The Company expects to comply with both the minimum bid price requirement and the equity standard requirement
within the time periods mandated by the Panel" and that "To address the equity standard, in June of 2025, the Company
executed a $500 million equity line of credit, and a lender recently converted $15.5 million in debt to preferred equity and
purchased an additional $1.1 million of preferred stock." Please tell us with specificity where you have disclosed in your
amendment that: (1) the company expects to comply with both the minimum bid price requirement and the equity standard requirement
within the time periods mandated by the Panel; and (2) a lender recently converted $15.5 million in debt to preferred equity and
purchased an additional $1.1 million of preferred stock.

COMPANY RESPONSE: In response
to the Staff’s comment, the Company has enhanced the disclosures on pages 43 and 55 of the Amended Registration Statement.

Management identified a material weakness in our internal control
over financial reporting, page 31

4. Please update the disclosure about the disclosure controls and
procedures as requested in the last sentence of prior comment 4.

COMPANY RESPONSE: In response
to the Staff’s comment, the Company has updated the disclosure on page 32 of the Amended Registration Statement.

Please do not hesitate to
contact James A. Prestiano of Loeb & Loeb LLP at (212) 407-4831 with any questions or comments regarding this letter.

    Sincerely,

    /s/ James A. Prestiano

    James A. Prestiano

    Senior Counsel

    cc:
    Scott Wallace, CEO ECD Automotive Design, Inc.

    David J. Levine, Esq.