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  14888 Auburn Sky Drive, Draper, UT 84020

  Brian Higley

  (801) 634-1984

  Attorney at Law

  brian@businesslegaladvisor.com
  Licensed in Utah

December 7, 2023

Division of Corporation Finance

Office of Industrial Applications and Services

Securities and Exchange Commission

Washington, DC 20549

    Re:
    Trans American Aquaculture, Inc.

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

    Filed October 5, 2023

    File No. 333-274059

Dear Mr. O'Leary:

We are in receipt of your
letter dated November 1, 2023, setting forth certain comments to the amended Registration Statement on Form S-1 (the “S-1”),
which was filed on October 5, 2023 by Trans American Aquaculture, Inc., a Colorado corporation (the “Company”). In
response to your comments, the Company can provide you with the following information in response to your comments:

Amendment No. 1 to
Registration Statement on Form S-1 filed October 5, 2023

Cover Page

 1. We note your disclosure that "[t]he Selling Security Holder identified in this prospectus may offer
the shares of Common Stock from time to time through public or private transactions at prevailing market prices or at privately negotiated
prices." We also note that your common stock is currently quoted on the OTC Pink marketplace. Please note that the OTC Pink marketplace
is not an established public trading market into which a selling shareholder may offer and sell shares at other than a fixed price. Accordingly,
please revise your cover page disclosure, and make corresponding changes elsewhere in the prospectus, to disclose a fixed price at which
the selling stockholders will offer and sell shares until your shares are listed on a national securities exchange or quoted on the OTCQX
or OTCQB, at which time they may be sold at prevailing market prices. Refer to Item 501(b)(3) of Regulation S-K. Make conforming changes
to the disclosure in your Plan of Distribution.

    RESPONSE: Concurrent with the filing herewith,
the Company filed Amendment No. 2 to the Registration Statement on Form S-1 (the “Registration Statement”) which eliminates
the registration of the “Warrant Exercise Shares” and the “Preferred Conversion Shares.” As the remaining shares
are an “equity line financing,” the shares may be sold at market prices by the Selling Shareholder.

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 2. As a related matter, you disclose here and throughout your filing that your common shares are "publicly
traded on the OTC Markets." Please revise your disclosure to clarify that your shares are quoted on the OTC Pink marketplace. Please
include a risk factor as appropriate describing any related risks specific to the OTC Pink marketplace.

    RESPONSE: Concurrent with the filing herewith,
the Company filed Amendment No. 2 to the Registration Statement which clarifies that the Company is quoted on the OTC Pink marketplace,
as requested. In addition, several previously-disclosed risk factors have been tailored to clarify the risks of the OTC Pink marketplace,
specifically.

 3. We note your disclosure elsewhere in the filing that you have Series B, Series C, and Series D Preferred
Stock outstanding, and that these classes of securities have different voting rights than the common shares you are registering in your
offering. Please revise the disclosure on your cover page to briefly describe the voting rights of these securities, including, if true,
that holders of these securities are entitled to a greater amount of votes per share than your common shares on any matter submitted to
a vote of your shareholders. Describe the influence that holders of these securities may have on matters submitted to a vote of your shareholders.

    RESPONSE: Concurrent
with the filing herewith, the Company filed Amendment No. 2 to the Registration Statement which adds disclosure on the cover page to briefly
describe the voting rights of the shares of Preferred Stock issued and outstanding, including, that the holders of those securities are
entitled to a greater amount of votes per share than the common shares on any matter submitted to a vote of our shareholders. Disclosure
has also been added to describe the influence that holders of those securities may have on matters submitted to a vote of our shareholders.

Prospectus
Summary, page 1

 4. Please substantiate your statements that refer to "superior," "highest standard of care,"
and "premium" here and elsewhere in the prospectus. For example:

 · "[P]romising our customers a superior product developed from the highest standard of care.;"

 · "We have and will continue to utilize superior genetic linage broodstock for cultivation;" and

 · "[W]e are a leading aquaculture company that provides premium quality, farm-raised pacific white
shrimp"

    In addition,
please clarify what is meant by "authentic" and "sustainable" practices, where you refer to how you raise and harvest
your shrimp.

    RESPONSE: Concurrent with the filing herewith,
the Company filed Amendment No. 2 to the Registration Statement which adds disclosure to substantiate statements the Company refers to
“superior,” “highest standard of care,” and “premium.” In addition, disclosure was added to clarify
what is meant by “authentic” and “sustainable” practices where the Company refers to how it raises and harvests
its shrimp.

 5. To provide investors with additional context about your business, please revise your prospectus summary
to disclose, as you do elsewhere in the filing, that you have had an accumulated deficit since inception, the amount of your accumulated
deficit as of the financial periods presented in the filing, and that you have yet to attain profitable operations. Please also disclose
that if you do not obtain additional financing, you will face the risk of going out of business.

    RESPONSE: Concurrent with the filing herewith,
the Company filed Amendment No. 2 to the Registration Statement which adds requested disclosure in the prospectus summary about accumulated
deficit.

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 6. We note your disclosure that "[o]ur management is currently engaged in actively pursuing multiple
financing options in order to obtain the capital necessary to execute our business plan." Please briefly describe the financing options,
including the status of any negotiations or agreements.

    RESPONSE: Concurrent with the filing herewith,
the Company filed Amendment No. 2 to the Registration Statement which eliminates the reference to “multiple financing options.”

We are currently in
default of secured debt . . . ., page 5

 7. We note your disclosure that you are in default on a Secured Promissory Note from June 2017. Please expand
this disclosure here to provide more information on the default, remedies, and any penalties or premiums that would be applied if repayment
is made. Please disclose if any of the proceeds from the Equity Financing Agreement will go toward repaying this note, and discuss any
other financing you have entered into or are pursuing to repay this note. Additionally, please provide an update on the status of the
company entering into a repayment plan. Finally, please make revisions to the disclosure in your "Liquidity" discussion in "Management's
Discussion and Analysis of Financial Condition and Results of Operations," to describe the impact, if any, of this default on your
liquidity and operations.

    RESPONSE: Concurrent with the filing herewith,
the Company filed Amendment No. 2 to the Registration Statement which adds an expanded disclosure on the default, remedies, and any penalties
or premiums that would be applied if repayment is made.

Our stock
price may be volatile., page 13

 8. We note your disclosure that the market price of your stock is likely to be highly volatile, due to a
bulleted list of factors including "[t]he impact of conflict between the Russian Federation and Ukraine on our operations."
Please revise your disclosure to include a risk factor describing the relevant impacts of this conflict on your business.

    RESPONSE: Concurrent with the filing herewith,
the Company filed Amendment No. 2 to the Registration Statement which eliminates the reference to the impact of the conflict between the
Russian Federation and Ukraine as management does not believe it is a material risk to the Company.

Private Placement

Equity Financing Agreement,
page 17

 9. We note that your equity financing agreement can terminate upon the passage of 24 months from the date
of the financing agreement. Please revise to include a discussion of the likelihood that you will receive the full amount of proceeds
available under the equity line agreement. Make conforming changes to your risk factor disclosure, including a discussion of the effects
on your business if you do not receive the full amount of the equity line.

    RESPONSE: Concurrent with the filing herewith,
the Company filed Amendment No. 2 to the Registration Statement which includes disclosure about the estimated financing needs under the
EFA and also risks in case the Company doesn’t have access to its estimated financing needs.

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Use of Proceeds, page
19

 10. You disclose that "[t]o the extent we receive proceeds from the Puts to the Selling Security Holder,
we will use those proceeds for general corporate and working capital purposes and acquisitions or assets, businesses or operations or
for purposes our Board of Directors deems to be in the best interests of the Company." Please clarify if any of the proceeds will
be used to discharge indebtedness, and if so, please include the additional disclosures required under Item 504 of Regulation S-K.

    RESPONSE: No proceeds from sales under
the EFA will be used to discharge indebtedness. Any indebtedness will be repaid from the proceeds of shrimp and broodstock sales.

Market Price of Common
Stock and Other Stockholder Matters, page 21

 11. We note your disclosure here that "the likely effect of designation as a penny stock is to decrease
the willingness of broker-dealers to make a market for the stock, to decrease the liquidity of the stock and increase the transaction
cost of sales and purchases of these stocks compared to other securities." Please revise your risk factor disclosures related to
your penny stock designation to include a similar discussion of these risks.

    RESPONSE: Concurrent with the filing
herewith, the Company filed Amendment No. 2 to the Registration Statement which revised the risk factor titled, “Because the
SEC imposes additional sales practice requirements on brokers who deal in our shares that are penny stocks, some brokers may be unwilling
to trade them. This means that investors may have difficulty reselling their shares and may cause the price of the shares to decline”
to include disclosure of the additional risks, as requested.

Management's Discussion
and Analysis of Financial Condition and Results of Operations Critical Accounting Policies, page 23

 12. Please provide a critical accounting policy disclosure that explains why your inventory balance tripled
between December 31, 2022 and June 30, 2023 even though there were the same number of shrimp at both dates (pp. F-7 and F-21). Disclose
the specific procedures that you use to apply your inventory accounting policies. For example, it is not clear how you reasonably determined
that the net realizable value of each shrimp exceeds $125 each ($498,232/4,000). Further, it is not clear how you reasonably determined
that all 4,000 inventory items existed at each Balance Sheet date thus precluding the need for an inventory allowance. In this regard,
we note the mortality risk factors disclosed on page F-9. Clarify how you determined that your inventory is stated at the lower of cost
or NRV given that your historical cost of sales have substantially exceeded corresponding revenues. See the disclosure guidance in Item
303(b)(3) of Regulation S-K.

    RESPONSE: Concurrent with the filing herewith,
the Company filed Amendment No. 2 to the Registration Statement which added the requested critical accounting policy disclosure.

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Results of Operations
for the Three-Months Ended June 30, 2023 and 2022, page 24

 13. We note your disclosure that the increase in professional fees for the three-months ended June 30, 2023
"was due to increased legal and accounting fees due to [y]our merger with GRPS and the filing of this Registration Statement."
In an appropriate place in your filing, including the description of your business, please provide additional details regarding your merger
with GRPS, including the material terms of the merger, a description of any merger or related agreements, the parties to the merger, the
merger consideration and the date the merger closed. File any relevant merger agreement as an exhibit to your registration statement.
See Item 601(b)(10) of Regulation S-K.

    RESPONSE: Disclosure regarding the merger
with GRPS is included under the subheading “Reverse Acquisition,” in the BUSINESS section. The Definitive Equity Exchange
Agreement dated September 13, 2022 with TAA, the members of TAA, and Adam Thomas was attached at Exhibit 2.2 to the S-1/A.

Results of Operations
For the Years Ended December 31, 2022 and 2021, page 26

 14. We note your disclosure that "[i]n 2022, the Company focused efforts primarily on the development
of genetic lines and did not produce a meaningful harvest." Please revise to disclose whether this trend continued into your 2023
fiscal year, and whether you expect this trend to continue in future financial periods. Refer to Item 303(b)(2)(ii) of Regulation S-K.

    RESPONSE: Concurrent with the filing herewith,
the Company filed Amendment No. 2 to the Registration Statement which added disclosure to clarify whether the 2022 trend of focusing efforts
on the development of genetic lines would continue into the 2023 fiscal year and future financial periods.

Liquidity and Capital
Resources, page 27

 15. We note your reference here to "the farm note." In the description of your liquidity, please
include a detailed discussion of the farm note, including but not limited to the parties to the farm note, the date you entered into the
farm note, the outstanding principal amount of the farm note, and any relevant interest payments. As a related matter, in this section
of your filing, please describe any other debt instruments to which you are a party or were a party in the financial periods presented
in the filing, and describe the material terms of these debt instruments, as appropriate. In this regard, we note your reference to "notes
payable" elsewhere in the filing and your discussion of long-term debt and notes payable in the notes to the financial statements.
Revise your risk factor disclosure to include any risks to investors related to your current debt obligations, including the impact of
the same on your ability to incur additional debt in the future.

    RESPONSE: Concurrent with the filing herewith,
the Company filed Amendment No. 2 to the Registration Statement which added disclosure to the “Liquidity and Capital Resources”
section to further describe the farm note. In addition, additional risk factor disclosure has been added to include risks to investors
related to our current debt obligations, including the impact of our debt obligations on our availability to incur additional debt in
the future.

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Business

Organization, page
29

 16. We note your references throughout this section to "the Company," "Trans American Aquaculture,
LLC," "TAA," "we," Adam Thomas, and Richard Goulding. To provide investors with the clarity needed to understand
the relevant transactions discussed in this section, please revise your disclosure to clearly describe the entity to which each of these
terms refer and the party each of the relevant persons represented or was affiliated with at the time of the Change in Control and Reverse
Acquisition.

    RESPONSE: Concurrent with the filing herewith,