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                          March 13, 2023

       Grant Russel
       Chief Financial Officer
       Vuzix Corp
       25 Hendrix Road, Suite A
       West Henrietta, New York 14586

                                                        Re: Vuzix Corp
                                                            Registration
Statement on Form S-3
                                                            Filed March 6, 2023
                                                            File No. 333-270311

       Dear Grant Russel:

              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 Gregory
Herbers at 202-551-8028 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Manufacturing
       cc:                                              Jeff Cahlon