July 12, 2019

Samer Tawfik
President, Chief Executive Officer and Chairman
LMP Automotive Holdings Inc.
601 N. State Road 7
Plantation, FL 33317

       Re: LMP Automotive Holdings Inc.
           Registration Statement on Form S-1
           Filed June 18, 2019
           File No. 333-232172

Dear Mr. Tawfik:

       We have reviewed your 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 filed June 18, 2019

Reorganization and Securities Issuances, page 3

1.     We understand that you have offered shares and convertible promissory
notes in private
       placements that began before you filed this registration statement, and
your disclosure on
       page 34 states that you intend to continue offering shares and
convertible promissory
       notes until this offering closes. Because it appears that you relied
upon Rule 506(b) of
       Regulation D to conduct the private placement at the same time you made
offers under
       Regulation A, please provide us with a detailed analysis of how your
private placement
       complies with the prohibition found in Rule 506(b) on general
solicitation or advertising
       to market securities. Please also tell us how you intend to continue the
offering under
       Regulation D at the same time you make offers under this registration
statement. In this
       regard, to conduct a concurrent offering under Rule 506(b), you must be
able to conclude
 Samer Tawfik
FirstName LastNameSamer Inc.
LMP Automotive Holdings Tawfik
Comapany NameLMP Automotive Holdings Inc.
July 12, 2019
July 12, 2019 Page 2
Page 2
FirstName LastName
         that the purchasers in the Rule 506(b) offering were not solicited by
your publicly filed
         offering statement and registration statement. For guidance, see
Securities Act Release
         No. 8828 (Aug. 3, 2007).
Summary Consolidated Financial Data, page 6

2.       Please correct the typographical error related to the fiscal 2017
amount of property,
         equipment and leasehold improvements, net. The disclosed amount of
$158,659 does not
         agree to the audited consolidated balance sheet amount of $185,659.
Risk Factors
Risks Related to This Offering and Ownership of our Common Stock
"Anti-takeover provisions in our charter documents and under Delaware law . .
..", page 24

3.       We note your disclosure that your Certificate of Incorporation and
Bylaws include
         provisions that, among other things, "restrict the forum for certain
litigation against [you]
         to Delaware," but we were unable to find these provisions in your
organizational
         documents. Please revise your disclosure for consistency, or direct us
to the location of
         these exclusive forum provisions in your organizational documents. If
your
         organizational documents include exclusive forum provisions, please
clearly
         disclose whether these provisions apply to federal securities law
claims. Your Certificate
         of Incorporation or Bylaws should also clearly state, if true, that
the provisions do not
         apply to federal securities law claims. If the exclusive forum
provisions do apply to
         federal securities law claims, please also disclose that, by agreeing
to the provision,
         investors will not be deemed to have waived your compliance with the
federal securities
         laws and the rules and regulations promulgated thereunder. Finally, if
applicable, please
         provide risk factor disclosure related to the exclusive forum
provisions, including but not
         limited to, costs to bring a claim, and that these provisions can
discourage claims or limit
         investors' ability to bring a claim in a judicial forum that they find
favorable.
Capitalization, page 31

4.       Please ensure the amount for total capitalization excludes the amount
for cash and cash
         equivalents as it is not a component of capitalization.
5.       Clarify for us how you calculated $78 pro forma par value of common
stock. In this
         regard, tell us why the amount would not be $73, based on the number
of shares
         outstanding post offering, taking into consideration the repurchase of
53,600 shares and
         the 18,500,000 shares that will be cancelled. Please also address this
comment in your
         post offering par value calculation, assuming the exercise of the
over-allotment.
Dilution , page 32

6.       Please show us how you calculated the pro forma as adjusted net
tangible book value per
         share, and dilution in pro forma net tangible book value per share,
assuming the exercise
 Samer Tawfik
FirstName LastNameSamer Inc.
LMP Automotive Holdings Tawfik
Comapany NameLMP Automotive Holdings Inc.
July 12, 2019
July 12, 2019 Page 3
Page 3
FirstName LastName
         of the over-allotment option.
7.       Please revise your disclosure to clarify, if true, that a $1.00
increase in the offering price
         would increase the dilution to new investors by $0.84 per share.
Similarly, clarify within
         your disclosure, if true, that a 1 million share increase would
decrease the dilution to new
         investors by $0.40 per share.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Quarter Ended March 31, 2019 Compared to Quarter Ended March 31, 2018
Revenues, page 38

8.       We note your disclosure here that revenues in 2019 include $172,433
from your rental
         program and $292,422 from your subscription program, and your
disclosure
         elsewhere that revenues in 2018 include $539,952 from your rental
program and $356,323
         from your subscription program. Please disclose whether you expect
your subscription
         program or rental program to contribute a larger percentage of revenue
in future financial
         periods and, given that you do not expect sales of pre-owned vehicles
to continue at
         historical levels, whether these sources of revenue are expected to
offer you sufficiently
         liquidity to finance your operations
Year Ended December 31, 2018 Compared to the Year Ended December 31, 2017
Revenues, page 40

9.       We note your disclosure that the increase in costs of revenues
included $889,388 of costs
         of revenues for rental revenues and subscription fees in 2018. Please
clarify the
         portion of increased costs contributed by rental revenues and the
portion contributed by
         subscription fees.
Business
Our Current Business, page 43

10.      We note your disclosure that your fleet consists of 215 automobiles,
of which 118 are
         offered for subscription, and that your current facility contains
storage for 10 vehicles on
         the interior and up to 90 vehicles on the exterior. Considering that
you currently have
         only 118 vehicles for subscription, and that your facility can store
only up to 100 vehicles,
         please provide further detail supporting your statement that you
expect you can facilitate
         over 1,000 subscribers in your current facility. In this regard, tell
us how many
         subscribers you currently have at this facility, in order to give
proper context to this
         statement.
Industry Overview, page 44

11.      Please provide support for the following statements, or disclose that
they are
         management's opinions or beliefs:
 Samer Tawfik
FirstName LastNameSamer Inc.
LMP Automotive Holdings Tawfik
Comapany NameLMP Automotive Holdings Inc.
July 12, 2019
July 12, 2019 Page 4
Page 4
FirstName LastName
             "Consumer confidence and employment are currently at a 17-year
high;"

             "Sales of 'off-lease vehicles,' or automobiles that are resold
after being leased, have
             increased steadily from 17% growth in 2010 to nearly 25% in 2017;"

             "The subscription model has been widely adopted in several
different sectors, such as
             consumer goods, streaming media and data cloud services. Driven by
consumer
             demand, the automobile industry has begun adopting a subscription
model as an
             alternative to ownership and leasing;"

             "In 2017, the U.S. automotive industry generated approximately
$1.2 trillion in sales,
             which represented approximately 21% of the U.S. retail economy;"

             "The pre-owned automobile retail industry is highly fragmented.
Currently, there are
             approximately 43,000 used car dealerships in the U.S., with the
largest dealer
             compromising [sic] approximately 1.7% of the market in the United
States;" and

             "Automobile-related companies that operate through an
Internet-based business model
             are demonstrating significant growth."
Description of Capital Stock, page 67

12.      We note your disclosure here that "[i]mmediately following the closing
of this offering,
         and giving effect to the cancellation of 18,500,000 shares currently
held by Samer Tawfik,
         . . . [you] will have 7,381,694 shares of common stock issued and
outstanding." We also
         note your disclosure in footnote 3 to the table on page 31 that the
number of outstanding
         shares of common stock after completion of the offering "was derived
from 24,506,694
         shares of common stock outstanding as of May 31, 2019, less 18,500,000
shares
         previously beneficially owned by Samer Tawfik that were cancelled for
no
         consideration." Please clarify the circumstances surrounding the
cancellation of Mr.
         Tawfik's shares, including a brief description of the terms of the
cancellation, and whether
         he currently holds the shares or if the shares have already been
cancelled. Please provide
         cross-references to this disclosure under your discussion of Related
Party transactions and
         Changes in Control. In doing so, please reconcile the fact that Mr.
Tawfik has also
         expressed an indication of interest to purchase shares in this
offering.
Inventory , page F-8

13.      We note you depreciate your fleet inventory monthly based on 1% of
initial cost starting
         in 2018 concurrent with your launch of the subscription and rental
businesses. Please
         explain to us how management arrived at the determination of the
useful life of the fleet.
         Clarify for us how long management intends to hold these assets.
 Samer Tawfik
LMP Automotive Holdings Inc.
July 12, 2019
Page 5
14.   Please explain to us why your used car inventory that is offered for sale
is classified
      together with the fleet inventory that are offered as part of your
subscription and rental
      businesses. Tell us your basis for combined presentation, and whether you
considered
      separately classifying these assets on your balance sheet or disclosing
them separately
      within the footnotes along with related impairment and depreciation,
respectively.
Note 2 - Summary of Significant Accounting Policies
Subscription Revenue, page F-10

15.   Please provide us with your accounting analysis that supports recognizing
subscription
      revenue upon delivery to a customer as opposed to recognizing
subscription revenue
      prospectively over the subscription period. An example of a
representative subscription
      arrangement and the provision in ASC 606 that supports your treatment
would facilitate
      our review.
16.   We note the Company's subscription plan includes scheduled maintenance
and, in certain
      cases, insurance. Please summarize for us how a representative
subscription plan provides
      for coverage and whether it is a separate deliverable. Please also tell
us how you
      considered whether your subscription plans have one or more than one
performance
      obligation, and provide the basis for your conclusion using the relevant
literature from
      ASC 606.
        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.

       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.

        You may contact Robert Babula, Staff Accountant, at 202-551-3339 or
James Allegretto,
Senior Assistant Chief Accountant, at 202-551-3849 if you have questions
regarding comments
on the financial statements and related matters. Please contact Katherine
Bagley, Staff
Attorney, at 202-551-2545 or Mara Ransom, Assistant Director, at 202-551-3264
with any other
questions.



                                                             Sincerely,
FirstName LastNameSamer Tawfik
                                                             Division of
Corporation Finance
Comapany NameLMP Automotive Holdings Inc.
                                                             Office of Consumer
Products
July 12, 2019 Page 5
cc:       Ali Panjwani
FirstName LastName