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                              December 4, 2020

       Julia Otey-Raudes
       Chief Executive Officer and Chief Financial Officer
       ECO INNOVATION GROUP, INC.
       16525 Sherman Way, Suite C-1
       Van Nuys, CA 91406

                                                        Re: ECO INNOVATION
GROUP, INC.
                                                            Amendment No. 2 to
Registration Statement on Form S-1
                                                            Filed November 20,
2020
                                                            File No. 333-248871

       Dear Ms. Otey-Raudes:

             We have reviewed your amended registration statement and have the
following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form S-1 Amendment #2

       Dilution to Stockholders, page 27

   1.                                                   Please revise your
dilution disclosures to address the following:
                                                            Net tangible book
value per share before the offering should be the same under each
                                                            offering scenario
and it appears to us that this amount should be zero since all
                                                            amounts expressed
in dollars should be limited to two decimal places.
                                                            It appears to us
that the amounts disclosed as    increase per share attributable to
                                                            investors
actually represent the pro forma net tangible book value per share after the
                                                            offering and should
be appropriately labeled.
                                                            Dilution per share
attributable to investors in this offering should represent the
                                                            difference between
the offering price per share and the pro forma net tangible book
                                                            value per share
after the offering as noted above.
 Julia Otey-Raudes
FirstName  LastNameJulia  Otey-Raudes
ECO INNOVATION       GROUP,   INC.
Comapany4,
December   NameECO
              2020    INNOVATION GROUP, INC.
December
Page  2    4, 2020 Page 2
FirstName LastName
Certain Relationships . . ., , page 31

2.       We note your revisions in response to prior comment 16. Please revise
the thresholds you
         cite to be consistent with Item 404(d) of Regulation S-K and revise
your disclosure, as
         necessary, to include any transactions that meet the revised
thresholds.
Description of Business
Business Model, page 35

3.       We note your response and revised disclosures related to prior comment
10 on pages 8,
         9, 35, and 36. Please also address the following:
             Disclose your CEO's and controlling Stockholder's ownership
interest in Eco-Gen;
             Disclose why Eco-Gen would require you to enter into an
outsourcing agreement for
              them and explain why Eco-Gen would not enter into an outsourcing
agreement on
              their own;
             Disclose if and who you have identified to perform the outsourced
services;
             As previously requested, provide additional information related to
Eco-Gen,
              including whether Eco-Gen's shares are publicly traded and
summary financial
              information, such as total assets and operating results as of the
most recent date
              practicable, in order to allow investors to better access
Eco-Gen's ability to fulfill
              their commitments under this agreement. Also, based on the signed
purchase orders,
              tell us your consideration for disclosing Eco-Gen's customers;
and
             Explain how you determined that recording revenues and expenses
under this
              agreement on a gross basis will be appropriate under ASC 606
particularly given your
              disclosure that you will incur negligible financial risk.
Eco-Gen Energy, page 35

4.       We note your revisions in response to prior comment 3. You disclose
that you receive
         advance payments from Eco-Gen prior to performing services; however,
section 5 of
         Exhibit 10.1 indicates that you receive payment only after you perform
services. Please
         revise or advise. Please also revise to clarify the status of work you
have performed to
         date with respect to the purchase orders you reference.
Financial Statements
Report of Independent Registered Public Accounting Firm, page 49

5.       We note the revision related to prior comment 17; however, in light of
the inclusion of an
         additional footnote in your financial statements, please have your
auditor revise the going
         concern paragraph in their report to refer to the appropriate footnote
number in your
         financial statements.

        You may contact SiSi Cheng at (202) 551-5004 or Anne McConnell, Senior
Accountant,
at (202) 551-3709 if you have questions regarding comments on the financial
statements and
related matters. Please contact Geoff Kruczek at (202) 551-3641 or Jay Ingram,
Legal Branch
 Julia Otey-Raudes
ECO INNOVATION GROUP, INC.
December 4, 2020
Page 3

Chief, at (202) 551-3397 with any other questions.



                                                     Sincerely,
FirstName LastNameJulia Otey-Raudes
                                                     Division of Corporation
Finance
Comapany NameECO INNOVATION GROUP, INC.
                                                     Office of Manufacturing
December 4, 2020 Page 3
cc:       Alan Hawkins
FirstName LastName