May 26, 2020
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, DC 20549
Attention: Mr. Edward M. Kelly
| Re: | ToughBuilt Industries, Inc. Registration Statement on Form S-1, as amended Originally filed April 8, 2020 File No. 333-237606 |
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as the underwriter of the proposed offering of Toughbuilt Industries, Inc. (the “Company”), we hereby join the Company’s request for acceleration of the above-referenced Registration Statement, requesting effectiveness for 5:30 p.m., Eastern Time, on May 28, 2020, or as soon thereafter as is practicable.
| Very truly yours, | ||
| Maxim Group LLC | ||
| By: | /s/ John H. Shaw III | |
| Name: | John H. Shaw III | |
| Title: | Senior Managing Director, Investment Banking | |
