ShiftPixy, Inc.

4101 NW 25th Street

Miami, FL 33142

December 28, 2023

Securities and Exchange Commission

Division of Corporation Finance

100 F Street N.E.

Washington, D.C. 20549

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

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, ShiftPixy, Inc. hereby respectfully requests acceleration of the effectiveness of the above-referenced Registration Statement so that such Registration Statement will become effective as of 4:30 p.m. Eastern Time, January 2, 2024 or as soon as practicable thereafter.

Very truly yours,
ShiftPixy, Inc.
By:	/s/ Scott W. Absher
	Scott W. Absher
	Chief Executive Officer