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                          June 24, 2022

       James Warren
       SVP and General Counsel
       Energy Focus, Inc.
       32000 Aurora Road, Suite B
       Solon, Ohio 44139

                                                        Re: Energy Focus, Inc.
                                                            Form S-3
                                                            File No. 333-265685
                                                            Filed June 17, 2022

       Dear Mr. Warren:

              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 Alex
King at 202-551-8631 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Manufacturing