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                              June 25, 2021

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

                                                        Re: EzFill Holdings,
Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed June 14, 2021
                                                            File No. 333-256691

       Dear Mr. McConnell:

             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 June
14, 2021 letter.

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

       Dilution, page 13

   1.                                                   It appears the pro
forma net tangible book value after giving effect to the offering and
                                                        reverse stock split has
been disclosed as dilution to new investors and vice versa.
                                                        Consequently, the
increase in net tangible book value per share attributable to new
                                                        investors should also
be revised. Please revise or otherwise advise.
 Michael McConnell
FirstName  LastNameMichael McConnell
EzFill Holdings, Inc.
Comapany
June       NameEzFill Holdings, Inc.
     25, 2021
June 25,
Page 2 2021 Page 2
FirstName LastName
        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