SecProbe.io

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 Stran
& Company, Inc.

 500
Victory Road, Suite 301

 Quincy,
MA 02171

 April
15, 2026

 Securities
and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Attn: Kate Beukenkamp

 Re:
 Stran & Company, Inc.

 Registration
Statement on Form S-3 (File No. 333-294949)

 Ladies
and Gentlemen,

 Pursuant
to Rule 461 under the Securities Act of 1933, as amended, Stran & Company, Inc. hereby respectfully requests that the Securities
and Exchange Commission accelerate the effectiveness of the above-referenced Registration Statement on Form S-3 (the "Registration
Statement") and declare the Registration Statement effective at 5:00 p.m. (Eastern Time) on Friday, April 17, 2026, or as soon
thereafter as practicable.

 It
would be appreciated if, as soon as the Registration Statement is declared effective, you would so inform Joseph
J. Kaufman of Bevilacqua PLLC at (202) 869-0888, ext. 113 .

 Respectfully,

 Stran & Company, Inc.

 By:
 /s/
 Andrew Shape

 Andrew
 Shape

 Chief
 Executive Officer

 cc:
Joseph J. Kaufman

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 15, 2026

Andrew Shape
Chief Executive Officer
Stran & Company, Inc.
500 Victory Road, Suite 301
Quincy, MA 02171

 Re: Stran & Company, Inc.
 Registration Statement on Form S-3
 Filed April 9, 2026
 File No. 333-294949
Dear Andrew Shape:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

 Please contact Kate Beukenkamp at 202-551-3861 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Joseph J. Kaufman
</TEXT>
</DOCUMENT>

United States securities and exchange commission logo
April 26, 2023
Andrew Shape
President and Chief Executive Officer
Stran & Company, Inc.
2 Heritage Drive
Suite 600
Quincy, MA
Re:Stran & Company, Inc.
Registration Statement on Form S-3
Filed April 19, 2023
File No. 333-271337
Dear Andrew Shape:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Nicholas Nalbantian at 202-551-7470 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Joseph J. Kaufman

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Stran & Company, Inc.

2 Heritage Drive, Suite 600

Quincy, MA 02171

April 26, 2023

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Attn: Nicholas Nalbantian

  Re:
  Stran & Company, Inc.

  Registration Statement on Form S-3

  File No. 333-271337

Dear Mr. Nalbantian:

Pursuant to Rule 461 under the Securities Act of 1933,
as amended, Stran & Company, Inc. hereby respectfully requests that the Securities and Exchange Commission accelerate the effectiveness
of the above-referenced Registration Statement on Form S-3 (the “Registration Statement”) and declare the Registration Statement
effective at 5:00 p.m. (Eastern Time) on Friday, April 28, 2023, or as soon thereafter as practicable.

It would be
appreciated if, as soon as the Registration Statement is declared effective, you would so inform Joseph J. Kaufman of Bevilacqua
PLLC at (202) 869-0888, ext. 113.

Respectfully,

Stran & Company, Inc.

     By:
    /s/ Andrew Shape

    Andrew Shape
President and Chief Executive Officer

cc:  Joseph J. Kaufman

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Stran & Company, Inc.

2 Heritage Drive, Suite 600

Quincy, MA 02171

December 30, 2021

Via EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Nicholas Lamparski

 Re: Stran & Company, Inc. (the “Company”)

Registration Statement on
Form S-1

File No. 333-261883
(the “Registration Statement”)

Ladies and Gentlemen:

The
Company hereby requests, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness
of the Registration Statement so that such Registration Statement will become effective as of 5:00 p.m. (Eastern Time) on January 4, 2022,
or as soon thereafter as practicable.

Please
contact Louis A. Bevilacqua, Esq. of Bevilacqua PLLC, U.S. counsel of the Company, at (202) 869-0888, ext. 100, to provide notice of
effectiveness, or if you have any questions or concerns regarding the foregoing.

    Very truly yours,

    Stran & Company, Inc.

    By:
    /s/ Andrew Shape

    Name:
    Andrew Shape

    Title:
    President and Chief Executive Officer

cc: Louis A. Bevilacqua, Esq.

United States securities and exchange commission logo
December 30, 2021
Andrew Shape
Chief Executive Officer
Stran & Company, Inc.
2 Heritage Drive, Suite 600
Quincy, MA 02171
Re:Stran & Company, Inc.
Registration Statement on Form S-1
Filed December 23, 2021
File No. 333-261883
Dear Mr. Shape:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Nicholas Lamparski at 202-551-4695 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Louis A. Bevilacqua

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VIA EDGAR

November 8, 2021

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attn: Taylor Beech

    Re:
    Stran & Company, Inc.

    File No. 333-260109

    Registration Statement on Form S-1

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations
of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, EF Hutton, division of Benchmark Investments,
LLC, acting as representative of the underwriters, hereby joins Stran & Company, Inc. in requesting acceleration of the effective
date of the above-referenced Registration Statement so that it will become effective on November 8, 2021, at 4:00 p.m. Eastern Time, or
as soon thereafter as practicable.

Pursuant to Rule 460 under the Act, we wish to advise
you that we have distributed as many copies of the Preliminary Prospectus dated November 8, 2021, to selected dealers, institutions and
others as appears to be reasonable to secure adequate distribution of the Preliminary Prospectus.

The undersigned confirms that it has complied and
will continue to comply with, and it has been informed or will be informed by participating dealers that they have complied or will comply
with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection with the above-referenced issue.

Very truly yours,

EF Hutton

division of Benchmark Investments, LLC

By: /s/ Sam Fleischman

Name: Sam Fleischman

Title: Supervisory Principal

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Stran & Company, Inc.

2 Heritage Drive, Suite 600

Quincy, MA 02171

November 8, 2021

Via EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Taylor Beech

 Re: Stran & Company, Inc. (the “Company”)

Registration Statement on
Form S-1

File No. 333-260109
(the “Registration Statement”)

Ladies and Gentlemen:

The
Company hereby requests, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness
of the Registration Statement so that such Registration Statement will become effective as of 4:00 p.m. (Eastern Time) on November 8,
2021, or as soon thereafter as practicable.

Please
contact Louis A. Bevilacqua, Esq. of Bevilacqua PLLC, U.S. counsel of the Company, at (202) 869-0888, ext. 100, to provide notice of
effectiveness, or if you have any questions or concerns regarding the foregoing.

    Very truly yours,

    Stran & Company, Inc.

    By:
    /s/ Andrew Shape

    Name:
    Andrew Shape

    Title:
    President and Chief Executive Officer

cc: Louis A. Bevilacqua, Esq.

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Stran & Company, Inc.

2 Heritage Drive, Suite 600

Quincy, MA 02171

October 29, 2021

Via EDGAR and E-Mail

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, DC. 20549

    Attn:
    Nasreen Mohammed

    Theresa Brillant

    Taylor Beech

    Erin Jaskot

Re: Stran & Company, Inc.

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

  Filed October 22, 2021

  File No. 333-260109

Ladies and Gentlemen:

We hereby submit the responses of Stran & Company, Inc. (the “Company”)
to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
set forth in the Staff’s letter, dated October 28, 2021, providing the Staff’s comments with respect to the Company’s
Amendment No. 1 to Registration Statement on Form S-1 (the “Registration Statement”).

For the convenience of the Staff, each of the Staff’s comments
is included and is followed by the corresponding response of the Company.  Unless the context indicates otherwise, references
in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.

Amendment No. 1 to Registration Statement on Form S-1 Filed October
22, 2021

Cover Page

 1. Please revise to disclose the number of units, shares of common
stock, and warrants that are being offered pursuant to the registration statement. Please see Item 501(b)(2) of Regulation S-K and Securities
Act Rules Compliance and Disclosure Interpretation 227.02 for guidance.

Response: The Company has revised the cover page accordingly.

If you would like to discuss any of the responses
to the Staff’s comments or if you would like to discuss any other matters, please contact the undersigned at (617) 501-7423 or Louis
A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).

    Sincerely,

    Stran & Company, Inc.

    By:
    /s/ Andrew Shape

    Andrew Shape

    President and Chief Executive Officer

cc: Louis A. Bevilacqua, Esq.

United States securities and exchange commission logo
October 28, 2021
Andrew Shape
Chief Executive Officer and President
Stran & Company, Inc.
2 Heritage Drive, Suite 600
Quincy, MA 02171
Re:Stran & Company, Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed October 22, 2021
File No. 333-260109
Dear Mr. Shape:
            We have reviewed your amended registration statement and have the following
comment.  In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this comment, we may have additional comments.
Amendment No. 1 to Registration Statement on Form S-1 filed October 22, 2021
Cover Page
1.Please revise to disclose the number of units, shares of common stock, and warrants that
are being offered pursuant to the registration statement.  Please see Item 501(b)(2) of
Regulation S-K and Securities Act Rules Compliance and Disclosure Interpretation
227.02 for guidance.

 FirstName LastNameAndrew Shape
 Comapany NameStran & Company, Inc.
 October 28, 2021 Page 2
 FirstName LastName
Andrew Shape
Stran & Company, Inc.
October 28, 2021
Page 2
            Please contact Taylor Beech at 202-551-4515 or Erin Jaskot at 202-551-3442 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Louis A. Bevilacqua

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Stran & Company, Inc.

2 Heritage Drive, Suite 600

Quincy, MA 02171

October 22, 2021

Via EDGAR and E-Mail

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, DC. 20549

 Attn:  Nasreen Mohammed

Theresa Brillant

Taylor Beech

Erin Jaskot

    Re:
    Stran & Company, Inc.

    Registration Statement on Form S-1

    Filed October 7, 2021

    File No. 333-260109

Ladies and Gentlemen:

We hereby submit the responses of Stran &
Company, Inc. (the “Company”) to the comments of the staff (the “Staff”) of the U.S. Securities
and Exchange Commission (the “Commission”) set forth in the Staff’s letter, dated October 19, 2021, providing
the Staff’s comments with respect to the Company’s Registration Statement on Form S-1 (the “Registration Statement”).

For the convenience of the Staff, each of the
Staff’s comments is included and is followed by the corresponding response of the Company.  Unless the context indicates
otherwise, references in this letter to “we,” “us” and “our” refer to the Company on a consolidated
basis.

Registration Statement on Form S-1 Filed October 7, 2021

Report of Independent Registered Public Accounting Firm, page F-14

1.  We note your response to prior comment 7. Please tell us
your auditor’s consideration of the guidance in paragraph .05 of PCAOB Auditing Standard 3110 relating to dual dating their report for
the stock split. Additionally, please ensure that the report date referenced in the consent is consistent with the report date in the
filing.

Response: The Company’s
auditor has considered the guidance in paragraph .05 of PCAOB Auditing Standard 3110 relating to dual dating their report for the stock
split. Based on this guidance, the Company’s auditor has revised the date of its report included in the Registration Statement
and as referenced in the consent attached as Exhibit 23.1 to the Registration Statement.

Notes to Financial Statements

N. Acquisition, page
F-24

2.  We note your response to prior comment 8. You state your
experience in the industry as the rationale for estimating a useful life of ten years. Please explain how you considered the various
factors listed in your response, including specifically your own historical experience with customers renewing or extending similar arrangements,
and how it relates to the $2.2 million customer list asset acquired in August 2020.

Response: The Company respectfully advises the Staff that it determined the useful life of ten years for the $2.2 million customer
list asset acquired in 2020 in accordance with ASC 350-30-35-3 based on the characteristics of the customer list and the Company’s
experience with customer retention. Below are the factors that the Company utilized and how they were considered when determining the
useful life of the acquired customer list:

 ● The expected use of
                                            the asset by the Company: The Company expects to use the customer list as a source of new
                                            business to generate operating profit as part of the Company’s core business of distributing
                                            promotional products.

 ● The expected useful
                                            life of another asset or a group of assets to which the useful life of the intangible asset
                                            may relate: The Company’s own customer list was used as the comparison asset. As stated
                                            on page 67 of the Registration Statement, the Company’s average customer contract
                                            lifespan is approximately ten years. The acquired customer list was determined to share many
                                            of the same characteristics as its own customer list, including the types of promotional
                                            products purchased by the acquired list’s customers, and various incentives that the
                                            Company offers customers to use the Company as their distributor including the Company’s
                                            ability to hold customer inventory, its technology solutions, or its ability to recognize
                                            customer-specific brand requirements.

 ● The potential legal,
                                            regulatory and contractual provisions that may impact the useful life of the asset: The Company
                                            determined that this factor would not affect the Company’s estimate of the useful life
                                            of the acquired customer list because there are no significant legal or regulatory restrictions
                                            that would limit the Company from seeking to have ongoing relationships with the acquired
                                            customer base and customer contracts with the Company or competitor promotional products
                                            distributors, are generally non-exclusive in nature.

 ● The Company’s
                                            own historical experience in renewing or extending similar arrangements, consistent with
                                            the intended use of the customer list: Based on the Company’s 27 years of experience
                                            working with customers to meet their promotional product needs, customer relationships vary
                                            but average ten years. For some customers, the Company has developed lasting relationships
                                            that have exceeded this period or are expected to do so. The Company has also historically
                                            experienced regular customer attrition as is common in the promotional products industry.
                                            Therefore, many customers have not used or are not expected to use the Company’s services
                                            for more than ten years due to ongoing changes in customer circumstances or other reasons.
                                            As a result, customer retention has averaged approximately ten years for the Company. The
                                            Company therefore uses a conservative estimate of 10% annual attrition when analyzing a customer
                                            base in its industry. The Company believes that the Company’s historical experience
                                            in that regard is generally consistent with such rates throughout the promotional products
                                            industry.

 ● The effects of obsolescence,
                                            demand, competition, and other economic factors: The Company believes such factors have minimal
                                            impact to the extent that they may impact the businesses included in the customer list acquired
                                            by the Company in 2020. The customers mostly shared a similar geography, with at least some
                                            presence in the Midwest, but included companies from various industries including hospitals,
                                            community banks, universities, hardware and grocery store chains, and childhood education,
                                            all of which have unique opportunities and challenges that can impact their business models
                                            and ultimately influence their value as a customer that has ongoing promotional product needs
                                            due to economic factors. Some customers, for example, may decide to sell the business to
                                            a competitor who uses an alternative promotional products distributor. Therefore, the Company
                                            expects that any particular economic or technological changes that may occur will not have
                                            a significant general effect on the customers in the acquired customer list.

To the extent that such economic or
technological changes may affect the promotional products industry itself, the Company expects that it would be able to adapt to such
changes or adequately mitigate any losses that they may cause based on its 27-year operating history during a variety of major economic
and technological developments. As such, the Company did not determine that this factor would significantly affect its estimate of the
useful life of the acquired customer list.

 ● The level of maintenance
                                            expenditures required to obtain the expected future cash flows from the asset: The Company
                                            believes that there are no significant maintenance expenditures needed to retain the acquired
                                            customer list based on its historical experience and expects only routine sales and account
                                            management expenses.

General

3.  We note that Section 5.5 of your bylaws includes a right
of first refusal in favor of the company that applies to all stockholders. Please describe this provision in your filing and discuss
any risks related to such transfer restrictions in your risk factors.

Response: We have amended and restated our bylaws
to remove former Section 5.5. The amended and restated bylaws are filed as Exhibit 3.2 to the Registration Statement.

If you would like to discuss any of the
responses to the Staff’s comments or if you would like to discuss any other matters, please contact the undersigned at (617)
501-7423 or Louis A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).

    Sincerely,

    Stran & Company, Inc.

    By:
    /s/ Andrew Shape

    Andrew Shape

    President and Chief Executive Officer

    cc: Louis A. Bevilacqua, Esq.

United States securities and exchange commission logo
October 19, 2021
Andrew Shape
Chief Executive Officer and President
Stran & Company, Inc.
2 Heritage Drive, Suite 600
Quincy, MA 02171
Re:Stran & Company, Inc.
Registration Statement on Form S-1
Filed October 7, 2021
File No. 333-260109
Dear Mr. Shape:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our October 1, 2021 letter.
Registration Statement on Form S-1 Filed October 7, 2021
Report of Independent Registered Public Accounting Firm, page F-14
1.We note your response to prior comment 7.  Please tell us your auditor's consideration of
the guidance in paragraph .05 of PCAOB Auditing Standard 3110 relating to dual dating
their report for the stock split.  Additionally, please ensure that the report date referenced
in the consent is consistent with the report date in the filing.

 FirstName LastNameAndrew Shape
 Comapany NameStran & Company, Inc.
 October 19, 2021 Page 2
 FirstName LastName
Andrew Shape
Stran & Company, Inc.
October 19, 2021
Page 2
Notes to Financial Statements
N. Acquisition, page F-24
2.We note your response to prior comment 8.  You state your experience in the industry as
the rationale for estimating a useful life of ten years.  Please explain how you considered
the various factors listed in your response, including specifically your own historical
experience with customers renewing or extending similar arrangements, and how it relates
to the $2.2 million customer list asset acquired in August 2020.
General
3.We note that Section 5.5 of your bylaws includes a right of first refusal in favor of the
company that applies to all stockholders.  Please describe this provision in your filing and
discuss any risks related to such transfer restrictions in your risk factors.
            You may contact Nasreen Mohammed at 202-551-3773 or Theresa Brillant at 202-551-
3307 if you have questions regarding comments on the financial statements and related
matters.  Please contact Taylor Beech at 202-551-4515 or Erin Jaskot at 202-551-3442 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Louis A. Bevilacqua

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Stran & Company, Inc.

2
Heritage Drive, Suite 600

Quincy,
MA 02171

October
6, 2021

    Via EDGAR and E-Mail

    United States Securities and Exchange Commission

    Division of Corporation Finance

    Office of Trade & Services

    100 F Street, N.E.

    Washington, DC. 20549

    Attn:
    Nasreen Mohammed

    Theresa Brillant

    Taylor Beech

    Erin Jaskot

    Re:
    Stran & Company,
    Inc.

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

    Submitted September
    16, 2021

    CIK No. 0001872525

Ladies
and Gentlemen:

We
hereby submit the responses of Stran & Company, Inc. (the “Company”) to the comments of the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) set forth in the Staff’s letter, dated October
1, 2021, providing the Staff’s comments with respect to the Company’s Amendment No. 1 to Draft Registration Statement on
Form S-1 (as amended, the “Registration Statement”).

For
the convenience of the Staff, each of the Staff’s comments is included and is followed by the corresponding response of the Company.  Unless
the context indicates otherwise, references in this letter to “we,” “us” and “our” refer to the Company
on a consolidated basis.

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

Cover Page

 1. We
                                            reissue our prior comment 1 in part. Please revise to clearly disclose whether a Nasdaq listing
                                            is a condition to the offering.

Response:
The Company has revised the disclosure on the cover page and elsewhere in the Registration Statement to address the Staff’s comment
by clarifying that approval of the Nasdaq listing is a condition to the completion of the offering.

Prospectus
Summary

COVID-19
Pandemic, page 7

 2. We
                                            note your revised disclosure in response to our prior comments 3 and 5. Please further revise
                                            your disclosure here to indicate the extent to which your U.S. Census contract was responsible
                                            for the increase in your revenue from 2019 to 2020.

Response:
The Company has revised the disclosure in the Registration Statement to indicate the extent to which the U.S. Census contract was responsible
for the increase in the Company’s revenue from 2019 to 2020.

Use
of Proceeds, page 31

 3. Please
                                            tell us whether you have identified any particular business to acquire or otherwise entered
                                            into preliminary negotiations with potential acquisition targets.

Response:
The Company has not identified any particular business to acquire nor has it otherwise entered into preliminary negotiations with potential
acquisition targets. The Company has updated its disclosure in the “Use of Proceeds” section of the Registration Statement
and elsewhere to make this clear.

Management's
Discussion and Analysis of Financial Condition and Results of Operations

Impact
of COVID-19 Pandemic, page 38

 4. We
                                            reissue our prior comment 4 in part. Please revise this section to specifically discuss the
                                            impact that the COVID-19 pandemic has had on your business to date, rather than presenting
                                            such risks as hypothetical.

Response:
The Company has revised the disclosure in the Registration Statement to specifically discuss the impact that the COVID-19 pandemic has
had on its business to date.

Management's
Transactions with Long Blockchain Corp., page 75

 5. We
                                            note your revised disclosure in response to our prior comment 11. Please further revise your
                                            disclosure to identify the overlap in management between Long Blockchain Corp. and the company.
                                            In this regard we note that your Chief Executive Officer and director Andrew Shape was also
                                            the Chief Executive Officer and director of Long Blockchain Corp.

Response:
The Company has revised the disclosure in the Registration Statement to identify the overlap in management between Long Blockchain Corp.
and the Company.

Unaudited
Consolidated Financial Statements for the Six Months Ended June 30, 2021 and 2020,

page
F-3

 6. We
                                            note that for the six months ended June 30, 2021 you present a Statement of Earnings and
                                            Retained Earnings which is reporting loss from operations, loss before income taxes, and
                                            net loss. Please revise the current line item descriptions “earnings” to indicate
                                            the reported loss in the financial statements here, and elsewhere throughout the filing,
                                            as applicable.

Response:
The Company has revised the line item descriptions in its financial statements for the six months ended June 30, 2021 and 2020 to indicate
the reported loss in the financial statements and elsewhere throughout the filing as applicable.

    2

Audited
Consolidated Financial Statements for the Years Ended December 31, 2020 and 2019

Balance
Sheet, page F-16

 7. We
                                            note your response to prior comment 15 and reissue this comment in part. Please revise the
                                            number of shares presented in your December 31, 2020 financial statements to reflect the
                                            forward stock split.

Response:
The Company has revised the number of shares presented in its financial statements for the fiscal years ended December 31, 2020 and 2019
to reflect the forward stock split.

Notes
to Financial Statements

N.
Acquisition, page F-25

 8. We
                                            note per your response to prior comment 19 that you assigned a 10 year life to the acquired
                                            customer list. Please tell us how you evaluated the guidance in ASC 350-30-35-3 in determining
                                            the useful life, including explaining the characteristics of the customer list that support
                                            this assigned life, and all other pertinent factors considered in your analysis.

Response:
The Company respectfully advises the Staff that ten years is the Company’s standard time frame for intangibles. Historically, there
is little if any benefit to the Company received from intangibles after ten years. Due to competition in the industry and fluctuations
in demand, the Company expects to benefit from the customers on the customer list for at most ten years. From the Company’s experience
in the industry, the Company’s conservative estimate of an attrition rate of 10% annually would result in a useful life of ten
years. Therefore, ten years is the expected useful life of the acquired customer list to the Company.

Below
are all of the factors that the Company takes into consideration when determining the useful life of an intangible asset such as the
acquired customer list:

 ● The
                                            expected use of the asset by the Company.

 ● The
                                            expected useful life of another asset or a group of assets to which the useful life of the
                                            intangible asset may relate.

 ● Any
                                            legal, regulatory, or contractual provisions that may limit the useful life. The cash flows
                                            and useful lives of intangible assets that are based on legal rights are constrained by the
                                            duration of those legal rights. Thus, the useful lives of such intangible assets cannot extend
                                            beyond the length of their legal rights and may be shorter.

 ● The
                                            Company’s own historical experience in renewing or extending similar arrangements,
                                            consistent with the intended use of the asset by the entity, regardless of whether those
                                            arrangements have explicit renewal or extension provisions. In the absence of that experience,
                                            the Company considers the assumptions that market participants would use about renewal or
                                            extension consistent with the highest and best use of the asset by market participants.

 ● The
                                            effects of obsolescence, demand, competition, and other economic factors (such as the stability
                                            of the industry, known technological advances, legislative action that results in an uncertain
                                            or changing regulatory environment, and expected changes in distribution channels).

 ● The
                                            level of maintenance expenditures required to obtain the expected future cash flows from
                                            the asset (for example, a material level of required maintenance in relation to the carrying
                                            amount of the asset may suggest a very limited useful life). As in determining the useful
                                            life of depreciable tangible assets, regular maintenance may be assumed but enhancements
                                            may not. Further, if an income approach is used to measure the fair value of an intangible
                                            asset, in determining the useful life of the intangible asset for amortization purposes,
                                            Company considers the period of expected cash flows used to measure the fair value of the
                                            intangible asset.

    3

If
you would like to discuss any of the responses to the Staff’s comments or if you would like to discuss any other matters, please
contact the undersigned at (617) 501-7423 or Louis A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).

    Sincerely,

    Stran & Company, Inc.

    By:
    /s/
    Andrew Shape

    Andrew Shape

    President and Chief Executive Officer

    cc: Louis A. Bevilacqua, Esq.

4

United States securities and exchange commission logo
October 1, 2021
Andrew Shape
Chief Executive Officer and President
Stran & Company, Inc.
2 Heritage Drive, Suite 600
Quincy, MA 02171
Re:Stran & Company, Inc.
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted September 16, 2021
CIK No. 0001872525
Dear Mr. Shape:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form S-1
Cover Page
1.We reissue our prior comment 1 in part.  Please revise to clearly disclose whether a
Nasdaq listing is a condition to the offering.
Prospectus Summary
COVID-19 Pandemic, page 7
2.We note your revised disclosure in response to our prior comments 3 and 5.  Please further
revise your disclosure here to indicate the extent to which your U.S. Census contract was
responsible for the increase in your revenue from 2019 to 2020.

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Andrew Shape
Stran & Company, Inc.
October 1, 2021
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Use of Proceeds, page 31
3.Please tell us whether you have identified any particular business to acquire or otherwise
entered into preliminary negotiations with potential acquisition targets.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Impact of COVID-19 Pandemic, page 38
4.We reissue our prior comment 4 in part.  Please revise this section to specifically discuss
the impact that the COVID-19 pandemic has had on your business to date, rather than
presenting such risks as hypothetical.
Management's Transactions with Long Blockchain Corp., page 75
5.We note your revised disclosure in response to our prior comment 11.  Please further
revise your disclosure to identify the overlap in management between Long Blockchain
Corp. and the company.  In this regard we note that your Chief Executive Officer and
director Andrew Shape was also the the Chief Executive Officer and director of Long
Blockchain Corp.
Unaudited Consolidated Financial Statements for the Six Months Ended June 30, 2021 and 2020,
page F-3
6.We note that for the six months ended June 30, 2021 you present a Statement of Earnings
and Retained Earnings which is reporting loss from operations, loss before income taxes,
and net loss.  Please revise the current line item descriptions "earnings" to indicate the
reported loss in the financial statements here, and elsewhere throughout the filing, as
applicable.
Audited Consolidated Financial Statements for the Years Ended December 31, 2020 and 2019
Balance Sheet, page F-16
7.We note your response to prior comment 15 and reissue this comment in part.  Please
revise the number of shares presented in your December 31, 2020 financial statements to
reflect the forward stock split.
Notes to Financial Statements
N. Acquisition, page F-25
8.We note per your response to prior comment 19 that you assigned a 10 year life to the
acquired customer list.  Please tell us how you evaluated the guidance in ASC 350-30-35-
3 in determining the useful life, including explaining the characteristics of the customer
list that support this assigned life, and all other pertinent factors considered in your
analysis.

 FirstName LastNameAndrew Shape
 Comapany NameStran & Company, Inc.
 October 1, 2021 Page 3
 FirstName LastName
Andrew Shape
Stran & Company, Inc.
October 1, 2021
Page 3
            You may contact Nasreen Mohammed at 202-551-3773 or Theresa Brillant at 202-551-
3307 if you have questions regarding comments on the financial statements and related
matters.  Please contact Taylor Beech at 202-551-4515 or Erin Jaskot at 202-551-3442 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Louis A. Bevilacqua

United States securities and exchange commission logo
August 20, 2021
Andrew Shape
Chief Executive Officer and President
Stran & Company, Inc.
2 Heritage Drive, Suite 600
Quincy, MA 02171
Re:Stran & Company, Inc.
Draft Registration Statement on Form S-1
Submitted July 23, 2021
CIK No. 0001872525
Dear Mr. Shape:
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form S-1 Submitted July 23, 2021
Prospectus Cover
1.We note your disclosure on page 25 that you may seek quotation on the OTCQX Best
Market or OTCQB Venture Market if you fail to obtain a Nasdaq listing.  Please disclose
this on your prospectus cover and in your prospectus summary. Please clearly state, if
true, that listing on Nasdaq is not a condition to the offering.
2.We note your disclosure on page 26 that your key officers and directors will own a
majority of your outstanding common stock after this offering and will therefore have the
ability to control all matters submitted for stockholder approval.  Please disclose this on
your prospectus cover and in your prospectus summary, including the percentage of the
voting power they will control after this offering.  In addition, to the extent you may

 FirstName LastNameAndrew Shape
 Comapany NameStran & Company, Inc.
 August 20, 2021 Page 2
 FirstName LastName
Andrew Shape
Stran & Company, Inc.
August 20, 2021
Page 2
qualify as a “controlled company” under Nasdaq rules, please disclose this in your filing,
including risk factor disclosure, and state whether you intend to rely on any controlled
company exemptions.
COVID-19 Pandemic, page 7
3.Please revise here and elsewhere that you discuss the significant increase in your sales and
net earnings in 2020 to indicate the extent to which your contract with the U.S. Census
program customer was responsible for this increase.  Please also indicate the extent to
which your sales decline in the first quarter of 2021 is due to the loss of this customer, as
your current disclosure suggests that it is due to the impact of COVID.  To the extent the
decrease in sales in the first quarter of 2021 was due to COVID, please explain why
COVID did not have an impact on your 2020 sales and net earnings.
Risk Factors
Our business could be materially adversely impacted by the COVID-19 pandemic, page 15
4.Please revise this risk factor to specifically discuss the impact that the COVID-19
pandemic has had on your business to date, rather than presenting such risks as
hypothetical.  Please quantify the impact on your revenues and any COVID-related costs
incurred.  In this regard, we note your disclosure that the cost of raw materials and
shipping related costs increased significantly in the last twelve months as a result of the
COVID-19 pandemic.  Please make confirming revisions in the Management’s Discussion
and Analysis section.
There is a risk of dependence on one or a group of customers..., page 19
5.You state that unsophisticated investors or investors that are not aware of the impact of
revenue from the U.S. Census customer on your 2020 results may have an expectation of
much faster revenue growth.  Given your obligation to disclose all material information to
potential investors, please make clear throughout your registration statement that your
2019 and 2020 results include the revenue generated from the U.S. census customer, that
your engagement with this customer will not continue, and that the revenue increases in
these periods do not represent your long-term growth expectations.  To the extent you
expect that future revenues and net sales could decrease following the loss of this
customer, please state this clearly.
Use of Proceeds, page 31
6.Please disclose the interest rate and maturity date of your bank line of credit, the balance
of which you intend to repay with the offering proceeds.  Refer to Instruction 4 to Item
504 of Regulation S-K.  Please also provide the disclosure required by Instruction 6 to
Item 504 of Regulation S-K in regards to your planned acquisitions and partnerships.

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Andrew Shape
Stran & Company, Inc.
August 20, 2021
Page 3
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
37
7.We note your disclosure that you generate a majority of your revenue from program
business and you believe you can convert your transactional customer base into program
customers with much greater revenue potential.  Please disclose how you define program
revenue as compared to transactional revenue and why you believe program revenue has
greater revenue potential.  Please also include a breakdown of historical program and
transactional revenue.  We also note your disclosure that you earn revenue from the sale
of promotional products and from service fees.  To the extent these categories are different
from transactional and program revenue, please include a historical breakdown of these
revenue streams as well.
Management's Discussion and Analysis
Results of Operations
Comparison of the Year Ended December 31, 2019 and 2020, page 42
8.Please expand your discussion to provide quantified analysis of the significant drivers
behind material changes and any known trends or uncertainties that you reasonably expect
will have a material impact on your sales or income.  For example, for the year ended
December 31, 2020, you attribute the 24.5% increase in sales to an acquisition and organic
growth without quantifying the impact.  Please also discuss known trends regarding major
customers. For each period discussed, please quantify the change in revenue and the
impact of changes on the material drivers and discuss the underlying causes for these
changes. Refer to Item 303(a)(3) of Regulation S-K and SEC Release 33-8350.
Liquidity and Capital Resources, page 43
9.We note your disclosure that you believe your current cash levels, with or without the
proceeds of this offering, will be sufficient to meet your anticipated cash needs for at least
the next 12 months.  We also note your disclosure on page 24 that you do not know
whether your line of credit will be renewed, and if it is not, you may default on your line
of credit as well as your other obligations.  Given your intention to repay the balance
under your line of credit with the proceeds of this offering, please disclose whether your
liquidity discussion assumes the renewal and availability of your line of credit.
Business, page 52
10.Please include a description of the material terms of your agreements with CarltonOne,
Harte Hanks, and Facilisgroup and file such agreements as exhibits to your registration
statement.  Refer to Item 601(b)(10) of Regulation S-K.  Alternatively, please tell us why
this is not required.

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 Comapany NameStran & Company, Inc.
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Andrew Shape
Stran & Company, Inc.
August 20, 2021
Page 4
Management, page 73
11.We note your disclosure on page 85 that the SEC revoked Long Blockchain Corp’s
registration under the Exchange Act on February 22, 2021.  Given the overlap in
management of Stran & Company and Long Blockchain Corp, in an appropriate place in
this section, please disclose this matter and the underlying facts that resulted in such
revocation.
Executive Compensation
Employment Agreements, page 78
12.We note that you have listed four Named Executive Officers but have only provided a
description of the employment arrangements for three of the four.  Please include a
description of Christopher Rollin’s employment arrangements.
Certain Relationships and Related Party Transactions, page 82
13.Please include disclosure covering the last three fiscal years.  Please refer to Instruction 1
to Item 404 of Regulation S-K, particularly the three-year requirement for registration
statements.
Principal Shareholders, page 86
14.Given Mr. Stranberg has voting and investment power over the shares of common stock
held by Theseus Capital via an irrevocable proxy, please add the shares held by Theseus
to the total shares held by Mr. Stranberg.  Refer to Instructions 2 and 5 to Item 403 of
Regulation S-K.
Financial Statements, page F-1
15.We note per page 1 that you completed a forward stock split on May 24, 2021, and that
references to number of shares have given effect to this split; however, we note that the
number of shares presented in the financial statements have not been adjusted.  Please tell
us your consideration of SAB Topic 4:C in regard to the number of shares presented in
your December 31, 2020 and March 31, 2021 financial statements.
Inventory , page F-10
16.We note that you purchase products and branding through various third-party
manufacturers and decorators and resell the finished goods to customers.  We also note a
finished goods inventory balance of branded products.  It would appear that these products
have been purchased for resale to specific customers, and therefore, these branded
products can not be resold to another customer.  In this regard, please tell us the nature of
the products that comprise this balance, including whether the balance represents products
expected to be sold to specific customers, and if not, how you determined the value of the
inventory can be recovered.

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Andrew Shape
Stran & Company, Inc.
August 20, 2021
Page 5
Revenue Recognition, page F-22
17.We note per pages 1 and F-8 that in addition to selling branded products, you offer your
clients additional services.  We also note per page F-23 that you facilitate a reward card
program and recognize transaction fees.  Please tell us your consideration of presenting
net sales of tangible products separately from revenues from services in accordance with
Item 5-03(a) of Regulation S-X.
18.We note per page 61 that your top five categories of products sold are wearables, writing,
drinkware, technology, and events.  Please tell us how you considered these different
types of categories when determining your disaggregated revenue disclosure.  Refer to
ASC 606-10-50-5 to 7 and 55-89 to 91.

Note N: Acquisition, page F-26
19.Please disclose the amortization period for the acquired customer list in accordance with
ASC 350-30-50-1(a)(3).
Exhibits
20.We note you identified several director nominees in your Management section on page 73.
 Please file consents for each director nominee as exhibits to your registration statement.
Refer to Rule 438 of Regulation C
General
21.Please supplementally provide us with copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communications.  Please contact the staff member associated
with the review of this filing to discuss how to submit the materials, if any, to us for our
review.
            You may contact Nasreen Mohammed at 202-551-3773 or Theresa Brillant at 202-551-
3307 if you have questions regarding comments on the financial statements and related
matters.  Please contact Taylor Beech at 202-551-4515 or Erin Jaskot at 202-551-3442 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services