SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 10, 2025

David Shan
Chief Executive Officer
Massimo Group
3101 W Miller Road
Garland, Texas 75041

 Re: Massimo Group
 Schedule 13D filed January 15, 2025 by David Shan
 File No. 005-94488
Dear David Shan:

 We have conducted a limited review of the above-captioned filing and
have the
following comments.

 Please respond to this letter by amending the filing or by providing
the requested
information. If you do not believe our comments apply to your facts and
circumstances or
that an amendment is appropriate, please advise us why in a response letter.

 After reviewing any amendment to the filing and any information provided
in
response to these comments, we may have additional comments.

Schedule 13D filed January 15, 2025
General

1. We note that the event reported as requiring the filing of the Schedule
13D was
 December 31, 2024. Rule 13d-1(a) of Regulation 13D-G requires the filing
of a
 Schedule 13D within five business days after the date beneficial
ownership of more
 than five percent of a class of equity securities specified in Rule
13d-1(i)(1) was
 acquired. Based on the December 31, 2024 event date, the Schedule 13D
submitted on
 January 15, 2025 was not timely filed. Please advise us why the Schedule
13D was
 not filed within the required five business days after the date of the
acquisition.
2. The cover page of the above-captioned Schedule 13D indicates that
December 31,
 2024 was the date of the event that required this filing to have been
made. Please
 advise us how this date was determined.
Item 5, page 1

3. Item 5(c) requires the beneficial owner to "describe any transactions in
the class of
 March 10, 2025
Page 2

 securities reported on that were effected during the past sixty days."
Please revise to
 provide the requisite disclosure with respect to all transactions in the
securities
 between the deadline for timely filing the Schedule 13D and the actual
filing of the
 Schedule 13D. If the Schedule 13D is amended to include the required
information,
 please be advised that the Instruction to Item 5(c) requires the
beneficial owner to
 "describe," at a minimum, the following: "(1) The identity of the person
covered by
 Item 5(c) who effected the transaction; (2) the date of transaction; (3)
the amount of
 securities involved; (4) the price per share or unit; and (5) where and
how the
 transaction was effected."
 We remind you that the filing person is responsible for the accuracy
and adequacy of
his disclosures, notwithstanding any review, comments, action or absence of
action by the
staff.

 Please direct any questions to Blake Grady at 202-551-8573 or Nicholas
Panos at
202-551-3266.

 Sincerely,

 Division of
Corporation Finance
 Office of Mergers
& Acquisitions
</TEXT>
</DOCUMENT>