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                            December 28, 2023

       Scott Absher
       Chief Executive Officer
       ShiftPixy, Inc.
       4101 NW 25th Street
       Miami, FL 33142

                                                        Re: ShiftPixy, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed December 21,
2023
                                                            File No. 333-276208

       Dear Scott Absher:

              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 Brian
Fetterolf at 202-551-6613 with any questions.




                            Sincerely,


                            Division of Corporation Finance

                            Office of Trade & Services
       cc:                                              Jeff Cahlon