May 28, 2019

Suren Ajjarapu
Chief Executive Officer
Trxade Group, Inc.
3840 Land O' Lakes Boulevard
Land O' Lakes, Florida 34639

       Re: Trxade Group, Inc.
           Registration Statement on Form S-1
           Filed May 6, 2019
           File No. 333-231246

Dear Mr. Ajjarapu:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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 Filed May 6, 2019

General

1.     We note that you plan to incorporate by reference information pursuant
to General
       Instruction VII of Form S-1. However, it appears that the company is a
penny stock issuer
       as defined in Rule 3a51-1 of the Exchange Act and, therefore, is not
eligible to use
       incorporation by reference. Please revise or advise. Please also update
your financial
       disclosure for the quarterly period ended March 31, 2019.
        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.
 Suren Ajjarapu
Trxade Group, Inc.
May 28, 2019
Page 2

        Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

      Please contact Ronald (Ron) Alper at 202-551-3329 or Brigitte Lippmann at
202-551-
3713 with any questions.



                                                           Sincerely,

FirstName LastNameSuren Ajjarapu                           Division of
Corporation Finance
                                                           Office of Beverages,
Apparel and
Comapany NameTrxade Group, Inc.
                                                           Mining
May 28, 2019 Page 2
cc:       Blair Krueger, Esq.
FirstName LastName