United States securities and exchange commission logo April 12, 2023 Michael Panosian Chief Executive Officer ToughBuilt Industries, Inc. 8669 Research Drive Irvine, CA 92618 Re: ToughBuilt Industries, Inc. Registration Statement on Form S-1 Filed April 7, 2023 File No. 333-271181 Dear Michael Panosian: 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 Patrick Fullem at (202) 551-8337 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Philip Magri, Esq.