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                             May 19, 2021

       Michael McConnell
       Chief Executive Officer
       EzFill Holdings, Inc.
       2125 Biscayne Blvd, #309
       Miami, Fl. 33137

                                                        Re: EzFill Holdings,
Inc.
                                                            Amendment No. 1 to
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted April 21,
2021
                                                            CIK No. 0001817004

       Dear Mr. McConnell:

             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 note your response
to our prior comment 3 and reissue in part. We note your
                                                        disclosure that you
have applied to list your common stock on Nasdaq. Please revise to
                                                        identify the trading
symbol for your securities on such market. If your offering is not
                                                        conditioned upon
listing approval, please state as much and provide disclosure in your risk
                                                        factors about the lack
of liquidity available to purchasers in this offering. Refer to Item
                                                        501(b)(4) of Regulation
S-K.
 Michael McConnell
FirstName  LastNameMichael McConnell
EzFill Holdings, Inc.
Comapany
May        NameEzFill Holdings, Inc.
     19, 2021
May 19,
Page 2 2021 Page 2
FirstName LastName
Business , page 26

2.       We note that you recently entered into a Technology License Agreement.
Please revise
         this section to discuss this agreement in greater detail to include
how it will affect your
         business and operations. We also note that the agreement contains a
revenue sharing
         provision. Please discuss this provision and its potential impact on
your current and future
         revenue streams.
Consolidated Statements of Operations, page F-4

3.       Please separately present revenue from delivery fees and revenue from
gasoline sales in
         your statement of operations. See Rule 5-03(b)(1) of Regulation S-X.

        You may contact Tatanisha Meadows at 202-551-3322 or Theresa Brillant
at 202-551-
3307 if you have questions regarding comments on the financial statements and
related
matters. Please contact Donald Field at 202-551-3680 or Mara Ransom at
202-551-3264 with
any other questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Trade &
Services