United States securities and exchange commission logo August 29, 2023 Michael Panosian Chief Executive Officer Toughbuilt Industries, Inc 8669 Research Drive Irvine, CA 92618 Re: Toughbuilt Industries, Inc Registration Statement on Form S-3 Filed August 24, 2023 File No. 333-274189 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.