April 13, 2020

Michael Panosian
Chief Executive Officer
ToughBuilt Industries, Inc
25371 Commercentre Drive, Suite 200
Lake Forest, CA 92630

       Re: ToughBuilt Industries, Inc
           Registration Statement on Form S-1
           Filed April 8, 2020
           File No. 333-237606

Dear Mr. 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 Edward M. Kelly, Senior Counsel, at (202) 551-3728 with
any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Manufacturing