SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 3, 2026

Joseph Visconti
Chief Executive Officer
Twin Vee PowerCats, Co.
3101 S. US-1
Ft. Pierce, Florida 34982

 Re: Twin Vee PowerCats, Co.
 Registration Statement on Form S-3
 Filed on February 27, 2026
 File No. 333-293911
Dear Joseph Visconti:

 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 Bradley Ecker at 202-551-4985 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>

CORRESP
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 Twin Vee PowerCats Co.

 3101 S. US-1

 Ft. Pierce, Florida 34982

 March 3, 2026

 VIA EDGAR

 United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549

 Re:
 Twin Vee Powercats Co.
Registration Statement on Form S-3 (File No. 333-293911)

 Ladies and Gentlemen:

 Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned respectfully requests that the effective date for
the Registration Statement referred to above be accelerated so that it will be declared effective at 4:30 p.m. Eastern Time on Thursday,
March 5, 2026, or as soon thereafter as practicable.

 Please
contact Arthur S. Marcus, Esq. of Sichenzia Ross Ference Carmel LLP at (516) 459-8161, as soon as the Registration Statement has been
declared effective, or if you have any other questions or concerns regarding this matter.

 Very truly yours,

 TWIN VEE POWERCATS CO.

 By:
 /s/ Joseph C. Visconti

 Name:
 Joseph C. Visconti

 Title:
 Chief Executive Officer

CORRESP
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October 8, 2024

VIA EDGAR

United States Securities

and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Patrick Fullem

    Re:
    Twin Vee PowerCats, Co.

    Registration Statement on Form S-4

    Filed
        August 27, 2024

    File
    No: 333-281788

Dear Mr. Fullem:

Twin Vee PowerCats, Co. (the “Registrant”)
hereby requests that the effective date of the above-referenced Registration Statement on Form S-4 (File No. 333-281788), be accelerated
by the U.S. Securities and Exchange Commission (the “Commission”) to become effective on Thursday, October 10, 2024,
at 4:00 p.m., Eastern Time, or as soon as reasonably practicable thereafter.

The Registrant understands that
the Staff of the Commission will consider this request as confirmation by the Registrant that it is aware of its responsibilities under
the federal securities laws as they relate to the issuance of the securities covered by the Registration Statement.

The Registrant hereby authorizes
Leslie Marlow of Blank Rome LLP to orally modify or withdraw this request for acceleration. Please contact Leslie Marlow at (212) 885-5358
or Hank Gracin at (212) 885-5362 with any questions you may have concerning this request, and please notify either of them when this request
for acceleration has been granted.

    Very truly yours,

    TWIN VEE POWERCATS, CO.

    By:
    /s/
    Joseph Visconti

    Name:
     Joseph
    Visconti

    Title:
    Chief Executive Officer

  cc:
  Leslie Marlow, Blank Rome LLP

  Hank Gracin, Blank Rome LLP

CORRESP
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    Phone:
    (212) 885-5358

    Fax:
    (917) 332-3824

    Email:
    leslie.marlow@blankrome.com

October 3, 2024

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Division of Corporate Finance, Office of Manufacturing

   Re:     Twin Vee PowerCats Co.

              Registration
Statement on Form S-4

              Filed
August 27, 2024

              File
No. 333-281788

Dear Sir or Madam:

On behalf of our client, Twin Vee PowerCats Co. (the “Company”),
we submit this letter in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”) contained in its letter dated September 11, 2024 (the “Comment Letter”), relating
to the above-referenced Registration Statement on Form S-4 (the “Registration Statement”). We have submitted via EDGAR
a revised draft of the Registration Statement (“Revised Registration Statement No. 1”).

Set forth below in bold face type
are the comments from the Comment Letter. For your convenience, the numbered paragraph below corresponds to the numbered comment in the
Staff’s Comment Letter and includes the caption used in the Comment Letter. Immediately following the comment is the Company’s
response to that comment, including, where applicable, a cross-reference to the location of changes made in the Registration Statement
No. 1 in response to the Staff’s comment.

Registration Statement on Form S-1 filed August
27, 2024

General

    1.
    It does not appear that Twin Vee PowerCats Co satisfies the requirements of General Instruction B.1.a of Form S-4 and General Instruction I.B.1 of Form S-3, which would allow you to incorporate certain required information by reference. Please advise us why Twin Vee PowerCats Co is eligible to incorporate by reference its financial statements or revise your filing to include the financial statements.

Response: We have revised the filing
to include the Company’s financial statements and other information relating to the Company.

2.
Please include the financial statements for Forza X1,
Inc. We note it does not appear the financial statements have been included. We also note it does not appear that Forza XI, Inc. satisfies
the requirements of General Instruction C.1.a of Form S-4 and General Instruction I.B.1 of Form S-3, which would allow you to incorporate
certain required information by reference.

United
States Securities

and
Exchange Commission

October
3, 2024

Page
2

Response: We have revised the filing
to include Forza X1, Inc.’s financial statements and other information relating to Forza X1, Inc.

Certain U.S. Federal Income Tax Consequences
of the Merger, page 61

3.
We note your disclosure
that the merger should constitute a reorganization within the meaning of Section 368(a) of the Code. Please file a tax opinion as Exhibit
8.1 that supports this statement. If counsel will be filing a short form opinion as Exhibit 8.1, please ensure that the short-form opinion
and the tax disclosure in the prospectus both clearly state that the disclosure in the tax consequences section of the prospectus is
the opinion of the named counsel. Refer to Section III.B.2 of Staff Legal Bulletin No. 19.

Response: We have revised the filing
to include a tax opinion as Exhibit 8.1.

If you have any questions or need
additional information, please contact the undersigned at (212) 885-5358 or Hank Gracin at (212) 885-5362.

    Sincerely,

    /s/
    Leslie Marlow

    Leslie
    Marlow

cc:
Joseph Visconti

Chief Executive Officer, Twin
Vee PowerCats Co.

Hank Gracin, Esq.

Blank Rome LLP

September 11, 2024
Joseph Visconti
Chief Executive Officer
Twin Vee PowerCats, Co.
3101 S. U.S. Highway 1
Fort Pierce, FL 34982
Re:Twin Vee PowerCats, Co.
Registration Statement on Form S-4
Filed August 27, 2024
File No. 333-281788
Dear Joseph Visconti:
            We have conducted a limited review of your registration statement and have the following
comment(s).
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a 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 letter, we may have additional comments.
Registration Statement on Form S-4 filed August 27, 2024
General
1.It does not appear that Twin Vee PowerCats Co satisfies the requirements of General
Instruction B.1.a of Form S-4 and General Instruction I.B.1 of Form S-3, which would
allow you to incorporate certain required information by reference. Please advise us why
Twin Vee PowerCats Co is eligible to incorporate by reference its financial statements or
revise your filing to include the financial statements.
2.Please include the financial statements for Forza X1, Inc. We note it does not appear the
financial statements have been included. We also note it does not appear that Forza XI,
Inc. satisfies the requirements of General Instruction C.1.a of Form S-4 and General
Instruction I.B.1 of Form S-3, which would allow you to incorporate certain required
information by reference.

September 11, 2024
Page 2
Certain U.S. Federal Income Tax Consequences of the Merger, page 61
3.We note your disclosure that the merger should constitute a reorganization within the
meaning of Section 368(a) of the Code. Please file a tax opinion as Exhibit 8.1 that
supports this statement. If counsel will be filing a short form opinion as Exhibit 8.1,
please ensure that the short-form opinion and the tax disclosure in the prospectus both
clearly state that the disclosure in the tax consequences section of the prospectus is the
opinion of the named counsel. Refer to Section III.B.2 of Staff Legal Bulletin No. 19.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Patrick Fullem at 202-551-8337 or Erin Purnell at 202-551-3454 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:Leslie Marlow, Esq.

CORRESP
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3101 S. US-1

Ft. Pierce, Florida 34982

(772) 429-2525

October 26, 2022

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Twin Vee PowerCats Co.

    Registration Statement on Form S-4, as amended

    File No: 333-267372

    Request for Acceleration

Ladies and Gentlemen:

Twin Vee PowerCats Co. (the “Registrant”)
hereby requests that the United States Securities and Exchange Commission (the “Commission”) take appropriate action
to cause the above-referenced Registration Statement on Form S-4, as amended (File No. 333-267372), to become effective on Friday,
October 28, 2022, at 5:00 p.m., Eastern Time, or as soon thereafter as is practicable.

The
Registrant understands that the Staff of the Commission will consider this request as confirmation by the Registrant that it is aware
of its responsibilities under the federal securities laws as they relate to the issuance of the securities covered by the Registration
Statement.

The Registrant hereby authorizes
its counsel, Leslie Marlow, Esq. or Patrick J. Egan, Esq. of Blank Rome LLP, to orally modify or withdraw this request for acceleration.
Please contact Ms. Marlow at (212) 885-5358 or Mr. Egan at (212) 885-5346 with any questions you may have concerning this request, and
please notify either Ms. Marlow or Mr. Egan when this request for acceleration has been granted.

    Very truly yours,

    TWIN VEE POWERCATS CO.

    By:
    /s/ Joseph C. Visconti

    Name: Joseph C. Visconti

Title: Chief Executive Officer

    cc:

    Leslie Marlow, Esq., Blank Rome LLP

    Patrick J. Egan, Esq., Blank Rome LLP

CORRESP
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1271 Avenue of the Americas | New York, New York 10020

Blankrome.com

    Phone:
    (212)
    885-5358

    Fax:
    (917)
    332-3824

    Email:
    Leslie.Marlow@Blankrome.com

October 20, 2022

VIA EDGAR

United States Securities

and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Patrick Fullem

    Re:

    Twin
    Vee PowerCats Co.

    Amendment
    No. 1 to Registration Statement on Form S-4

    Filed
    October 11, 2022

    File
    No. 333-267372

Dear Mr. Fullem:

On behalf of our client, Twin
Vee PowerCats Co. (the “Company”), we submit this letter in response to comments from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) contained in its letter dated October 19, 2022 (the “Comment
Letter”), relating to the above-referenced Amendment No. 1 to Registration Statement on Form S-4 (the “Registration
Statement”). We are concurrently submitting via EDGAR a revised draft of the Registration Statement (“Revised Registration
Statement No. 2”).

Set forth below in bold are comments
from the Comment Letter. For your convenience, each of the numbered paragraphs below corresponds to the numbered comment in the Staff’s
Comment Letter and includes the caption used in the Comment Letter. Immediately following each comment is the Company’s response
to that comment, including, where applicable, a cross-reference to the location of changes made in the Revised Registration Statement
No. 2 in response to the Staff’s comment. Defined terms used but not otherwise defined herein have the meanings ascribed to such
terms in the Registration Statement.

United States Securities

and Exchange Commission

October , 2022

Page 2

Amendment No. 1 to Registration Statement on Form
S-4 filed October 11, 2022

The Merger Transaction

Certain U.S. Federal Income Tax Consequences of the Merger, page 96

 1. We note your response to comment 1. Please revise your prospectus disclosure to provide a firm conclusion
regarding treatment of the transaction under Section 368(a). In addition, if tax counsel will file a short form opinion as Exhibit 8.1,
please clearly state that the conclusion in the prospectus is the opinion of counsel. Please also remove any statement that assumes the
material tax consequences at issue (e.g., “The following summary sets forth the material federal income tax consequences... assuming,
that the merger will constitute a ‘reorganization’ within the meaning of Section 368(a) of the Code”). Refer to Section
III of Staff Legal Bulletin No. 19.

Response: We have revised the prospectus disclosure to provide
a firm conclusion regarding treatment of the transaction under Section 368(a). We have also stated that the conclusion in the prospectus
is the opinion of counsel and have removed any statement that assumes the material tax consequences at issue.

* * *

If you have any questions or need
additional information, please contact the undersigned at (212) 885-5358 or (516) 496-2223.

    Sincerely,

    /s/ Leslie Marlow

    Leslie Marlow

    cc:
    Joseph Visconti

    CEO, Twin Vee PowerCats Co.

United States securities and exchange commission logo
October 19, 2022
Joseph C. Visconti
Chief Executive Officer
Twin Vee PowerCats Co.
3101 S. U.S. Highway 1
Fort Pierce, FL 34982
Re:Twin Vee PowerCats Co.
Amendment No. 1 to Registration Statement on Form S-4
Filed October 11, 2022
File No. 333-267372
Dear Joseph C. Visconti:
            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 September 29, 2022 letter.
Amendment No. 1 to Registration Statement on Form S-4 filed October 11, 2022
The Merger Transaction
Certain U.S. Federal Income Tax Consequences of the Merger, page 96
1.We note your response to comment 1.  Please revise your prospectus disclosure to provide
a firm conclusion regarding treatment of the transaction under Section 368(a).  In addition,
if tax counsel will file a short form opinion as Exhibit 8.1, please clearly state that the
conclusion in the prospectus is the opinion of counsel.  Please also remove any statement
that assumes the material tax consequences at issue (e.g., "The following summary sets
forth the material federal income tax consequences... assuming, that the merger will
constitute a 'reorganization' within the meaning of Section 368(a) of the Code").  Refer to
Section III of Staff Legal Bulletin No. 19.

 FirstName LastNameJoseph C. Visconti
 Comapany NameTwin Vee PowerCats Co.
 October 19, 2022 Page 2
 FirstName LastName
Joseph C. Visconti
Twin Vee PowerCats Co.
October 19, 2022
Page 2
            Please contact Patrick Fullem at (202) 551-8337 or Erin Purnell at (202) 551-3454 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Leslie Marlow

CORRESP
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1271 Avenue of the Americas | New York, New York 10020

Blankrome.com

    Phone:
    (212) 885-5358

    Fax:
    (917) 332-3824

    Email:
    Leslie.Marlow@Blankrome.com

October 7, 2022

VIA EDGAR

United States Securities

and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Patrick Fullem

    Re:
    Twin Vee PowerCats Co.

    Registration Statement on Form S-4

    Filed September 9, 2022

    File No. 333-267372

Dear Mr. Fullem:

On behalf of our client, Twin
Vee PowerCats Co. (the “Company”), we submit this letter in response to comments from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) contained in its letter dated September 29, 2022 (the
“Comment Letter”), relating to the above-referenced Registration Statement on Form S-4 (the “Registration
Statement”). We are concurrently submitting via EDGAR a revised version of the Registration Statement (“Revised Registration
Statement No. 1”).

Set forth below in bold are comments
from the Comment Letter. For your convenience, each of the numbered paragraphs below corresponds to the numbered comment in the Staff’s
Comment Letter and includes the caption used in the Comment Letter. Immediately following each comment is the Company’s response
to that comment, including, where applicable, a cross-reference to the location of changes made in the Revised Registration Statement
No. 1 in response to the Staff’s comment. Defined terms used but not otherwise defined herein have the meanings ascribed to such
terms in the Registration Statement.

Registration Statement on Form S-4 filed September
9, 2022

The Merger Transaction

Certain U.S. Federal Income Tax Consequences of the Merger, page
96

 1. Please provide a tax opinion covering the material federal tax consequences
of the transaction to investors and revise your disclosure accordingly. Please refer to Item 601(b)(8) of Regulation S-K and Items 4(a)(6)
and 21(a) of Form S-4. For guidance in preparing the opinion and related disclosure, please refer to Section III of Staff Legal Bulletin
No. 19.

Response: A tax opinion prepared by Blank
Rome LLP has been included as Exhibit 8.1 to the Revised Registration Statement No. 1 in response to the Staff’s comment.

United States Securities

and Exchange Commission

October 7, 2022

Page 2

Security Ownership of Certain Beneficial Owners and Management...

Ownership of Twin Vee Co. Common Stock Following the Merger, page
151

 2. We note your disclosure on page 32 that following the merger Joseph Visconti
will own 33.9% of the combined company. Please reconcile this with your disclosure on page 151.
If true, please revise to prominently disclose that the combined company will be a controlled company, identify the controlling
shareholders and the shareholders’ total voting power, and include appropriate risk factor disclosure.

Response: The Revised Registration Statement
No. 1 discloses that Joseph Visconti will beneficially own 25.4% of the combined company following the merger. Following the closing of
the merger, the combined company will not be a “controlled company” since no single person, entity or group will have or own
more than 50% of its voting power.

* * *

If you have any questions or need
additional information, please contact the Company’s counsel, Leslie Marlow at (212) 885-5358 or (516) 496-2223 or Patrick Egan
at (212) 885-5346.

    Sincerely,

    /s/ Leslie Marlow

    Leslie Marlow

    cc:
    Joseph Visconti

    CEO, Twin Vee PowerCats Co.

    Patrick Egan, Esq.

    Blank Rome LLP

United States securities and exchange commission logo
September 29, 2022
Joseph C. Visconti
Chief Executive Officer
Twin Vee PowerCats Co.
3101 S. U.S. Highway 1
Fort Pierce, FL 34982
Re:Twin Vee PowerCats Co.
Registration Statement on Form S-4
Filed September 9, 2022
File No. 333-267372
Dear Mr. Visconti:
            We have limited our review of your registration statement to those issues we have
addressed in our 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.
Registration Statement on Form S-4 filed September 9, 2022
The Merger Transaction
Certain U.S. Federal Income Tax Consequences of the Merger, page 96
1.Please provide a tax opinion covering the material federal tax consequences of the
transaction to investors and revise your disclosure accordingly.  Please refer to Item
601(b)(8) of Regulation S-K and Items 4(a)(6) and 21(a) of Form S-4.  For guidance in
preparing the opinion and related disclosure, please refer to Section III of Staff Legal
Bulletin No. 19.

 FirstName LastNameJoseph C. Visconti
 Comapany NameTwin Vee PowerCats Co.
 September 29, 2022 Page 2
 FirstName LastName
Joseph C. Visconti
Twin Vee PowerCats Co.
September 29, 2022
Page 2
Security Ownership of Certain Beneficial Owners and Management...
Ownership of Twin Vee Co. Common Stock Following the Merger, page 151
2.We note your disclosure on page 32 that following the merger Joseph Visconti will own
33.9% of the combined company.  Please reconcile this with your disclosure on page 151.
If true, please revise to prominently disclose that the combined company will be a
controlled company, identify the controlling shareholders and the shareholders’ total
voting power, and include appropriate risk factor disclosure.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Patrick Fullem at (202) 551-8337 or Erin Purnell at (202) 551-3454 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Leslie Marlow

United States securities and exchange commission logo
August 22, 2022
Joseph Visconti
Chief Executive Officer and President
Twin Vee PowerCats, Co.
3101 S. US-1
Ft. Pierce, Florida 34982
Re:Twin Vee PowerCats, Co.
Registration Statement on Form S-3
Filed August 15, 2022
File No. 333-266858
Dear Mr. Visconti:
            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 Gregory Herbers at 202-551-8028 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Leslie Marlow

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3101 S. US-1

Ft. Pierce, Florida 34982

(772) 429-2525

August 22, 2022

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Twin Vee PowerCats Co.

Registration Statement on Form S-3

File No: 333-266858

Request for Acceleration

Ladies and Gentlemen:

Twin Vee PowerCats Co. (the “Registrant”)
hereby requests that the United States Securities and Exchange Commission (the “Commission”) take appropriate action
to cause the above-referenced Registration Statement on Form S-3 (File No. 333-266858), to become effective on Wednesday, August
24, 2022, at 1:00 p.m., Eastern Time, or as soon thereafter as is practicable.

The Registrant hereby authorizes
its counsel, Leslie Marlow, Esq. or Patrick J. Egan, Esq. of Blank Rome LLP, to orally modify or withdraw this request for acceleration.
Please contact Ms. Marlow at (212) 885-5358 or Mr. Egan at (212) 885-5346 with any questions you may have concerning this request, and
please notify either Ms. Marlow or Mr. Egan when this request for acceleration has been granted.

    Very truly yours,

    TWIN VEE POWERCATS CO.

    By:
    /s/ Joseph Visconti

    Name: Joseph Visconti

Title: Chief Executive Officer

    cc:
    Leslie Marlow, Esq., Blank Rome LLP

Patrick J. Egan, Esq., Blank Rome LLP

CORRESP
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Twin Vee PowerCats Co.

July 16, 2021

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Twin Vee Powercats Co.

Registration Statement on Form S-1, as amended

File No: 333-255134

Request for Acceleration

Ladies and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, Twin Vee Powercats Co. (the “Registrant”) hereby
requests that the United States Securities and Exchange Commission (the “Commission”) take appropriate action to cause
the above-referenced Registration Statement on Form S-1, as amended (File No. 333-255134), to become effective on Tuesday, July 20,
2021, at 5:00 p.m., Eastern Time, or as soon thereafter as is practicable.

The
Registrant understands that the Staff of the Commission will consider this request as confirmation by the Registrant that it is aware
of its responsibilities under the federal securities laws as they relate to the issuance of the securities covered by the Registration
Statement.

The Registrant hereby authorizes its counsel, Leslie Marlow, Esq. or Hank Gracin, Esq. of Gracin & Marlow, LLP, to orally
modify or withdraw this request for acceleration. Please contact Ms. Marlow at (516) 496-2223 or (212) 907-6457 or Mr. Gracin at (561)
926-7995 or (212) 907-6457 with any questions you may have concerning this request, and please notify her when this request for acceleration
has been granted.

    Very
    truly yours,

    TWIN
    VEE POWERCATS CO.

    By:
    /s/
    Joseph C. Visconti

    Name:
    Joseph
    C. Visconti

    Title:
    Chief
    Executive Officer

    cc:
    Leslie Marlow, Esq., Gracin & Marlow, LLP

Hank Gracin, Esq., Gracin & Marlow, LLP

CORRESP
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ThinkEquity

A division of Fordham Financial Management, Inc.

17 State Street, 22nd Floor

New York, NY 10004

July
16, 2021

VIA EDGAR

U.S. Securities and Exchange Commission

100 F St., NE

Washington, D.C. 20549

    Re:
    Twin Vee PowerCats Co.

Registration Statement on Form S-1 (File No. 333-255134)

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, ThinkEquity, a division of
Fordham Financial Management, Inc., as representative of the underwriters, hereby requests acceleration of the effective date of the above-referenced
Registration Statement so that it will become effective at 5:00 p.m. Eastern Time on July 20, 2021, or as soon thereafter as practicable.

Pursuant to Rule 460 under the Securities
Act, please be advised that there will be distributed to each underwriter, who is reasonably anticipated to be invited to participate
in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure
adequate distribution of the preliminary prospectus.

The undersigned confirms that it has complied
with and will continue to comply with, and it has been informed or will be informed by participating dealers that they have complied with
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,

    ThinkEquity

    A division of Fordham Financial Management, Inc.

    By:
    /s/ Eric Lord

    Name:
    Eric Lord

    Title:
    Head of Investment Banking

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    HANK GRACIN†† | PARTNER

LESLIE MARLOW† | PARTNER PATRICK EGAN† | PARTNER

† Admitted in New York only

†† Admitted in New York, Florida & Colorado

    GRACIN & MARLOW, LLP

COUNSELLORS AT LAW

    THE CHRYSLER BUILDING

    26th FLOOR

    405 LEXINGTON AVENUE

    NEW YORK, NEW YORK 10174

(212) 907-6457

    FAX (212) 208-4657

    www.gracinmarlow.com

IN BOCA RATON

1825 NW CORPORATE BLVD.

SUITE 110

 BOCA RATON, FLORIDA 33431

(561) 237-0804

FAX (561) 237-0803

WRITER E-MAIL: hgracin@gracinmarlow.com

June 17, 2021

VIA EDGAR

United States Securities

and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Charles Eastman

    Re:

    Twin
    Vee PowerCats, Co.

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

    Filed
    April 8, 2021

    File
    No. 333-255134

Dear Mr. Eastman:

On behalf of our client, Twin
Vee PowerCats, Co. (the “Company”), we submit this letter in response to comments from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) contained in its letter dated June 14, 2021 (the “Comment
Letter”), relating to the above-referenced Amendment No. 1 to Registration Statement on Form S-1 (the “Registration
Statement”). We are concurrently submitting via EDGAR a revised draft of the Registration Statement (“Revised Registration
Statement No. 2”).

Set forth below in bold are comments
from the Comment Letter. For your convenience, each of the numbered paragraphs below corresponds to the numbered comment in the Staff’s
Comment Letter and includes the caption used in the Comment Letter. Immediately following each comment is the Company’s response
to that comment, including, where applicable, a cross-reference to the location of changes made in the Revised Registration Statement
No. 2 in response to the Staff’s comment. Defined terms used but not otherwise defined herein have the meanings ascribed to such
terms in the Revised Registration Statement No. 2.

GRACIN & MARLOW, LLP

COUNSELLORS AT LAW

United States Securities

and Exchange Commission

June 17, 2021

Page 2

Amendment No. 1 to Form S-1 filed June 2, 2021 Cover Page

1. Please tell us the basis for your disclosure that the gross proceeds of this offering will not be less
than $15,000,000 given that the price range is $5 to $6.

Response: We believe the gross proceeds of this offering
will not be less than $15,000,000 for the following reasons. The public offering, as stated on the cover page of the prospectus, is contingent
upon the listing of the Company’s common stock on the Nasdaq Capital Market. In order for the Company to comply with the Nasdaq
Capital Market initial listing requirements it must have a market value of unrestricted publicly held shares of at least $15,000,000.
The shares held by the only shareholder of the Company are not unrestricted publicly held shares. The gross proceeds of the offering therefore
must be at least $15,000,000 in order for the Company to meet the Nasdaq Capital Market initial listing requirements. The representative
of the underwriter is aware of this requirement and consented to the language that was included on the cover page of the prospectus.

Our Certificate of Incorporation and our bylaws provide that the Court
of Chancery of the State of Delaware, page 23

2. We note your response to prior comment 3. Please revise to state that your exclusive forum provision
does not apply to suits to enforce a duty or liability created by the Securities Act or the Exchange Act. In that regard, we note the
last sentence of Article VII of your certificate of incorporation. It does not appear that your bylaws have an exclusive forum provision.
Please revise your disclosure accordingly.

Response: We have revised the disclosure to state that
our exclusive forum provision does not apply to suits to enforce a duty or liability created by the Securities Act or the Exchange Act
and corrected the disclosure regarding our bylaws.

Certain Relationships and Related Party Transactions, page 55

3. We note your disclosure that during the three months ended March 31, 2021 you had purchases of $90,417
from a related party, received cash of $24,300 from your affiliate companies, paid $15,808 to your affiliate companies, and recorded management
fees of $10,500 paid to your shareholder parent company. Please revise to identify the related or affiliated parties, disclose the services
or products provided to or received from such related parties and elaborate on the nature of the related party transactions.

GRACIN & MARLOW, LLP

COUNSELLORS AT LAW

United States Securities

and Exchange Commission

June 17, 2021

Page 3

Response: We have revised the disclosure to identify the
related or affiliated parties, add disclosure regarding the services or products provided to or received from such related parties and
elaborate on the nature of the related party transactions.

General

4. We note that you obtained a loan under the Small Business Administration Paycheck Protection Program,
pursuant to which the company borrowed $608,224. Please disclose the following: (i) how you intend to use the loan proceeds; and (ii)
whether you expect the loan to be forgiven. Please revise your risk factor section to disclose any associated risks with the loan, including,
but not limited to the risk that all or parts of the loan may not be forgiven.

Response: We have disclosed (i) how we intend to use the
loan proceeds; and (ii) whether we expect the loan to be forgiven. We have also added a risk factor to disclose the associated risks with
the loan, including, but not limited to the risk that all or parts of the loan may not be forgiven.

* * *

If you have any questions or need
additional information, please contact the undersigned at (561) 237-0804 or (561) 926-7995 or Leslie Marlow at (212) 907-6457 or (516)
496-2223.

    Sincerely,

    /s/
    Hank Gracin

    Hank
    Gracin

cc:  	Joseph Visconti

        CEO, Twin Vee PowerCats Co.

United States securities and exchange commission logo
June 14, 2021
Joseph Visconti
Chief Executive Officer and President
Twin Vee PowerCats, Co.
3101 S. US-1
Ft. Pierce, Florida 34982
Re:Twin Vee PowerCats, Co.
Amendment No. 1 to Registration Statement on Form S-1
Filed June 2, 2021
File No. 333-255134
Dear Mr. Visconti:
            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.
Amendment No. 1 to Form S-1 filed June 2, 2021
Cover Page
1.Please tell us the basis for your disclosure that the gross proceeds of this offering will not
be less than $15,000,000 given that the price range is $5 to $6.

Our Certificate of Incorporation and our bylaws provide that the Court of Chancery of the State
of Delaware, page 23
2.We note your response to prior comment 3.  Please revise to state that your exclusive
forum provision does not apply to suits to enforce a duty or liability created by the
Securities Act or the Exchange Act. In that regard, we note the last sentence of Article VII
of your certificate of incorporation.  It does not appear that your bylaws have an exclusive

 FirstName LastNameJoseph Visconti
 Comapany NameTwin Vee PowerCats, Co.
 June 14, 2021 Page 2
 FirstName LastName
Joseph Visconti
Twin Vee PowerCats, Co.
June 14, 2021
Page 2
forum provision.  Please revise your disclosure accordingly.

Certain Relationships and Related Party Transactions, page 55
3.We note your disclosure that during the three months ended March 31, 2021 you had
purchases of $90,417 from a related party, received cash of $24,300 from your affiliate
companies, paid $15,808 to your affiliate companies, and recorded management fees of
$10,500 paid to your shareholder parent company.  Please revise to identify the related or
affiliated parties, disclose the services or products provided to or received from such
related parties and elaborate on the nature of the related party transactions.
General
4.We note that you obtained a loan under the Small Business Administration Paycheck
Protection Program, pursuant to which the company borrowed $608,224. Please disclose
the following: (i) how you intend to use the loan proceeds; and (ii) whether you expect the
loan to be forgiven. Please revise your risk factor section to disclose any associated risks
with the loan, including, but not limited to the risk that all or parts of the loan may not be
forgiven.
            You may contact Charles Eastman at 202-551-3794 or Melissa Gilmore at 202-551-3777
if you have questions regarding comments on the financial statements and related
matters.  Please contact Asia Timmons-Pierce at 202-551-3754 or Jay Ingram at 202-551-3397
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
filename1.htm

GRACIN
& MARLOW, LLP

COUNSELLORS
AT LAW

THE
CHRYSLER BUILDING

26th
FLOOR
 IN
BOCA RATON

 HANK
GRACIN†† | PARTNER
405
LEXINGTON AVENUE
1825
NW CORPORATE BLVD.

LESLIE
MARLOW † | PARTNER
 NEW
YORK, NEW YORK 10174
SUITE
110

PATRICK
EGAN† | PARTNER

BOCA
RATON, FLORIDA 33431

(561)
237-0804

FAX
(561) 237-0803

†
Admitted in New York only
(212)
907-6457

 ††Admitted
in New York, Florida &
FAX
(212) 208-4657
WRITER
E-MAIL:

Colorado

www.gracinmarlow.com
hgracin@gracinmarlow.com

June 1, 2021

VIA EDGAR

United States Securities

and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Charles Eastman

Re:
Twin Vee PowerCats, Co.

Registration Statement on
Form S-1

Filed April 8, 2021

File No. 333-255134

Dear Mr. Eastman:

On behalf of our client,
Twin Vee PowerCats, Co. (the “Company”), we submit this letter in response to comments from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) contained in its letter dated May 3, 2021 (the
“Comment Letter”), relating to the above-referenced Registration Statement on Form S-1 (the “Registration
Statement”). We are concurrently submitting via EDGAR a revised draft of the Registration Statement (“Revised
Registration Statement No. 1”).

Set forth below
in bold are comments from the Comment Letter. For your convenience, each of the numbered paragraphs below corresponds to the numbered
comment in the Staff’s Comment Letter and includes the caption used in the Comment Letter. Immediately following each comment
is the Company’s response to that comment, including, where applicable, a cross-reference to the location of changes made
in the Revised Registration Statement No. 1 in response to the Staff’s comment. Defined terms used but not otherwise defined
herein have the meanings ascribed to such terms in the Revised Registration Statement No. 1.

Form S-1 filed April 8, 2021

GRACIN & MARLOW,
LLP

COUNSELLORS AT LAW

United States Securities

and Exchange Commission

June 1,
2021

Page 2

We
depend on our network of independent dealers, face increasing competition for dealers, and have little control over their activities,
page 11

1.
Please elaborate on the extent to which dealers have not purchased
boats for which they have provided indications of interest.

Response: We have elaborated on the extent
to which dealers have not purchased boats for which they provided indications of interest.

We may be required to repurchase inventory of certain
dealers, page 11

2.
Please disclose whether you have had to repurchase your products from your dealers under applicable laws regulating dealer relations.

Response: We have disclosed whether the
Company has had to repurchase products from its dealers under applicable laws regulating dealer relations.

Our Certificate of Incorporation and our bylaws provide
that the Court of Chancery of the State of Delaware, page 23

3. Please revise your disclosure to clearly state that the provision
does not apply to claims arising under the Securities Act or Exchange Act. In that regard, we note that Article VII of your Certificate
of Incorporation states that your exclusive forum provision “shall not apply to suits to enforce a duty or liability created by
the Securities Act of 1933, as amended, or the Securities Exchange Act of 1934, as amended.” It appears that your Bylaws does not
contain an exclusive forum provision. Please revise your disclosure accordingly.

Response: We have revised the disclosure
regarding the Company’s Certificate of Incorporation to clearly state that the provision does not apply to claims arising
under the Securities Act or Exchange Act.

Summary Compensation Table, page 52

 4. We note that Mr. Visconti received $40,000 in other compensation.
Please provide a footnote explanation to “All Other Compensation” so that investors will understand what is included in this
column.

Response: We have revised Mr. Visconti’s
compensation to clarify what was included in “All Other Compensation.”

Statements of Cash Flows, page F-5

GRACIN & MARLOW,
LLP

COUNSELLORS AT LAW

United States Securities

and Exchange Commission

June 1, 2021

Page 3

5.
Please revise to disclose your proceeds and subsequent gain on loan
forgiveness for the proceeds you received under the Paycheck Protection Program noted in Note 8 Notes Payable - Paycheck Protection
Program.

Response: We have revised the Statements
of Cash Flow to disclose the Company’s proceeds and subsequent gain on loan forgiveness for the proceeds received under the
Paycheck Protection Program.

* * *

If you have any
questions or need additional information, please contact the undersigned at (561) 237-0804 or (561) 926-7995 or Leslie Marlow at
(212) 907-6457 or (516) 496-2223.

Sincerely,

/s/ Hank
Gracin

Hank Gracin

cc:   Joseph Visconti

        CEO, Twin Vee PowerCats
Co.

United States securities and exchange commission logo
May 3, 2021
Joseph Visconti
Chief Executive Officer and President
Twin Vee PowerCats, Co.
3101 S. US-1
Ft. Pierce, Florida 34982
Re:Twin Vee PowerCats, Co.
Registration Statement on Form S-1
Filed April 8, 2021
File No. 333-255134
Dear Mr. Visconti:
            We have reviewed your 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.
Form S-1 filed April 8, 2021
We depend on our network of independent dealers, face increasing competition for dealers, and
have little control over their activities, page 11
1.Please elaborate on the extent to which dealers have not purchased boats for which they
have provided indications of interest.
We may be required to repurchase inventory of certain dealers, page 11
2.Please disclose whether you have had to repurchase your products from your dealers
under applicable laws regulating dealer relations.

 FirstName LastNameJoseph Visconti
 Comapany NameTwin Vee PowerCats, Co.
 May 3, 2021 Page 2
 FirstName LastName
Joseph Visconti
Twin Vee PowerCats, Co.
May 3, 2021
Page 2
Our Certificate of Incorporation and our bylaws provide that the Court of Chancery of the State
of Delaware , page 23
3.Please revise your disclosure to clearly state that the provision does not apply to claims
arising under the Securities Act or Exchange Act. In that regard, we note that Article VII
of your Certificate of Incorporation states that your exclusive forum provision "shall not
apply to suits to enforce a duty or liability created by the Securities Act of 1933, as
amended, or the Securities Exchange Act of 1934, as amended."  It appears that your
Bylaws does not contain an exclusive forum provision.  Please revise your disclosure
accordingly.
Summary Compensation Table, page 52
4.We note that Mr. Visconti received $40,000 in other compensation.  Please provide a
footnote explanation to “All Other Compensation” so that investors will understand what
is included in this column.
Statements of Cash Flows, page F-5
5.Please revise to disclose your proceeds and subsequent gain on loan forgiveness for the
proceeds you received under the Paycheck Protection Program noted in Note 8 Notes
Payable - Paycheck Protection Program.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Charles Eastman at 202-551-3794 or Melissa Gilmore at 202-551-3777
if you have questions regarding comments on the financial statements and related
matters.  Please contact Asia Timmons-Pierce at 202-551-3754 or Jay Ingram at 202-551-3397
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing