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                           October 31, 2022

       Anthony Goodman
       Chief Executive Officer
       Elray Resources, Inc.
       3651 Lindell Road, Suite D101
       Las Vegas, Nevada 89103

                                                        Re: Elray Resources,
Inc.
                                                            Offering Statement
on Form 1-A
                                                            Post-qualification
Amendment No. 1
                                                            Filed October 25,
2022
                                                            File No. 024-11942

       Dear Anthony Goodman:

                                                        This is to advise you
that we do not intend to review your amendment.

               We will consider qualifying your offering statement at your
request. If a participant in
       your offering is required to clear its compensation arrangements with
FINRA, please have
       FINRA advise us that it has no objections to the compensation
arrangements prior to
       qualification.

               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 Alexandra Barone, Staff Attorney, at (202) 551-8816
or Jan Woo, Legal
       Branch Chief, at (202) 551-3453 with any questions.





                           Sincerely,


                           Division of Corporation Finance

                           Office of Technology
       cc:                                              Eric Newlan