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                            December 21, 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. 3 to
Registration Statement on Form S-1
                                                            Filed December 11,
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.

       Form S-1/A filed on December 11, 2020

       General, page 1

   1.                                                   Please revise your
filing to correct the following inconsistencies:
                                                            Correct the date of
the unaudited interim financial statements included in your filing
                                                            on page 12 which
should be September 30, 2020; and
                                                            Correct the date of
the auditors' report included in your filing on page 33 which
                                                            should be November
20, 2020.

       Description of Business
       Our Technology Agreements, page 35

   2.                                                   We note your response
to prior comment 3 and the additional disclosures you provided.
 Julia Otey-Raudes
ECO INNOVATION GROUP, INC.
December 21, 2020
Page 2
      Please revise your filing to address the following:
          Since your filing does not include financial statements or an
auditors'
          report/consent related to Eco-Gen, indicate the amounts presented
related to Eco-Gen
          are unaudited;
          Based on Eco-Gen's cash balance and based on the disclosed terms of
the purchase
          order with its customer, including the fact that the customers will
not be required to
          pay 50% of the purchase until the units they purchased are delivered
to them, provide
          a risk factor related to your dependence on Eco-Gen and its customers
relative to
          your business and the anticipated revenue you except to generate
under your
          agreement with Eco-Gen; and
          You state Eco-Gen's total assets include patents and other
intellectual property
          "valued" at $48,300,350. Since it appears that this amount may not
represent an
          amount recorded in accordance with US GAAP, delete the amounts
related to total
          assets and the amounts related to patents and other intellectual
property from your
          filing. Be advised, that unless Eco-Gen purchased the patents and
other intellectual
          property from an unrelated third party for cash, it would appear the
amounts
          disclosed may not comply with US GAAP.


       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 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 21, 2020 Page 2
cc:       Alan Hawkins
FirstName LastName