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CORRESP
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filename1.htm

Roth
Capital Partners, LLC

888
San Clemente Drive, Suite 400

Newport
Beach, CA 92660

February
14, 2024

VIA
EDGAR CORRESPONDENCE

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.
 Washington, D.C. 20549

 Re: Massimo
                                            Group

                                                                                Registration
                                            Statement on Form S-1 (the “Registration Statement”)

    File
                                            No. 333-276095

    Withdrawal
                                            of Acceleration Request

Ladies
and Gentlemen:

Reference
is made to our letter, filed as correspondence via EDGAR on February 13, 2024, in which we, as underwriter for Massimo Group’s
(the “Company’s”) proposed initial public offering, joined the Company’s request for acceleration of the effective
date of the above-referenced Registration Statement for February 13, 2024 at 5:00 p.m., Eastern Time. Massimo Group is no longer requesting
that such Registration Statement be declared effective at this time and we hereby formally withdraw our request for acceleration of the
effective date.

If
you require any additional information with respect to this letter, please contact Ali Panjwani at (212) 326-0820 of Pryor Cashman LLP.

    Very truly yours,

    ROTH CAPITAL PARTNERS,
    LLC

    By:
    /s/ Aaron M.
    Gurewitz

    Aaron M. Gurewitz

    Head of Equity Capital Markets

cc: M.
                                            Ali Panjwani, Esq.

  Pryor
                                            Cashman LLP