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Massimo
Group

3101
W Miller Road

Garland,
TX 75041

VIA
EDGAR

February
7, 2024

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Manufacturing

Washington,
D.C. 20549

    Attention:
    Stephany
    Yang

    Claire
    Erlanger

    Erin
    Donahue

    Anne
    Parker

    Re:
    Massimo
    Group

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

    Submitted
    February 5, 2024

    File
    No. 333-276095

    CIK
    No. 0001952853

Ladies
and Gentlemen:

Massimo
Group (the “Company”) hereby transmits its response to the comment letter received from the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) on February 6, 2024, relating to Amendment No. 1
to the Registration Statement on Form S-1, submitted by the Company to the Commission on February 5, 2024.

For
the Staff’s convenience, we have repeated below the Staff’s comment in bold and below it have the Company’s response.
Disclosure changes made in response to the Staff’s comments have been made in Amendment No. 2 to the Registration Statement on
Form S-1 (the “Registration Statement”), which is being submitted to the Commission contemporaneously with the submission
of this letter.

Amendment
No. 1 to the Registration Statement on Form S-1, filed February 5, 2024

Executive
Compensation, page 85

    1.
    Please
    disclose the executive compensation paid for the fiscal year ended December 31, 2023.

    Response: The Company respectfully acknowledges
    the Staff’s comment and advises the Staff that it has amended its disclosure on pages 85, 86 and 88 of the Registration
    Statement to include the requested information.

*
* *

We
thank the Staff for its review of this response. Should you have any questions or require any additional information, please do not hesitate
to contact our legal counsel, Richard Anslow, Esq. of Ellenoff Grossman & Schole LLP, at ranslow@egsllp.com or by telephone at (212)
370-1300.

    Very
    truly yours,

    Massimo
    Group

    By:
    /s/
    David Shan

    Name:

    David
    Shan

    Title:
    Chief
    Executive Officer and Chairman

    cc:
    Ellenoff
    Grossman & Schole LLP

    Pryor
    Cashman LLP