February 4, 2019

Xiaohao Tan
President
Ezagoo Ltd
Yijiaren Business Hotel No. 168
Tong Zipo Xi Lu
Yuelu District Changsha
Hunan 410205
China

       Re: Ezagoo Ltd
           Registration Statement on Form S-1
           Filed December 6, 2018
           File No. 333-228681

Dear Mr. Tan:

       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.

Form S-1 filed December 6, 2018

Prospectus Summary, page 2

1.     Please provide a brief discussion of what type of business the company
is engaged in.
2.     You state that in the event of any extension of the offering, investors
will be notified by an
       information statement. Please revise to state instead that you will file
a prospectus
       supplement. We note that you also incorrectly refer to this registration
statement as an
       information statement on page 26. Please revise.
 Xiaohao Tan
FirstName LastNameXiaohao Tan
Ezagoo Ltd
Comapany NameEzagoo Ltd
February 4, 2019
February 4, 2019 Page 2
Page 2
FirstName LastName



Risk Factors
If we do not manage our growth effectively . . . , page 6

3.       You state that your business has grown rapidly and that your quarterly
and annual
         operating results have fluctuated in the past; however, your company
has nominal
         operations and assets. If retained, please explain the bases for these
statements.
Description of Business, page 18

4.       We note that you identify Hunan Ezagoo Zhicheng Internet Technology
Limited, your
         operating subsidiary, as a variable interest entity of the company.
Please provide a
         discussion of what a Variable Interest Entity is, why this business
structure was chosen,
         and what the principle risks are.
Use of Proceeds, page 20

5.       Please revise the introductory paragraph to clarify that $6,000,000,
not $30,000,000, is
         being raised in the offering on behalf of the company.
Selling Shareholders, page 22

6.       Please revise the first paragraph, which seems to indicate that there
is only one selling
         shareholder.
Interests of Named Experts and Counsel, page 25

7.       You state that the validity of the shares offered will be passed upon
by Benjamin Bunker,
         Esq., although the opinion filed as Exhibit 5.1 is in the name of Carl
Ranno. Please
         revise.
Executive Compensation, page 27

8.       We note that you refer to your date of inception as May 9, 2018 here
and throughout your
         prospectus; however, your financial statements reflect operations
prior to that date. Please
         advise or revise.
Consolidated Statements of Cash Flows, page F-6

9.       We note a capital contribution valued at $39,368 was made sometime
during the fiscal
         year ended December 31, 2017. Please disclose the nature of the
transaction, confirm the
         contribution was for cash, tell us when it was made, and by whom. If
otherwise, please
         revise your statements of cash flows to reflect any non-cash
contributions within non-cash
         activities or advise us in detail why you believe no revision is
required.
 Xiaohao Tan
FirstName LastNameXiaohao Tan
Ezagoo Ltd
Comapany NameEzagoo Ltd
February 4, 2019
February 4, 2019 Page 3
Page 3
FirstName LastName
Note 1. Description of Business and Organization, page F-7

10.      Please tell us how your disclosures address ASC 810-10-50-12(a), which
requires
         disclosure of the methodology for determining whether you are the
primary beneficiary of
         a VIE, including, but not limited to, significant judgments and
assumptions made.
11.      We note your disclosure of the contractual agreements that provide the
Company with
         effective control over the VIE, presumably enabling the Company to
have power to direct
         the activities that most significantly affects the economic
performance of the VIE. Please
         clearly describe how the contractual agreements convey power to direct
the activities of
         the VIE and what those powers entail.
12.      We note you used "the pooling-of-interests method to account for the
combination
         between businesses under common control as the uniting of the
ownership interests of all
         entities." Please help us understand and clarify which businesses were
under common
         control and why it was appropriate to account for the transactions in
a manner akin to the
         pooling-of-interests method.
Note 6. Due to Related Parties, page F-13

13.      We note your disclosure that related party loans have been provided on
an interest-free
         basis, loans that have increased to approximately $769,216 as of
September 30, 2018 .
         Tell us where you have recorded imputed interest for such loans for
each period presented
         in accordance with ASC 835-30. To the extent you have not imputed
interest, please
         revise to record such interest expense and provide us with the related
calculations as part
         of your response. Alternatively, please explain to us and in the notes
to your financial
         statements why you do not believe you are not required to do so.
Note 13. Common Stock, page F-29

14.      We note that there were several issuances of restricted shares in
2018. Please disclose the
         pertinent rights and privileges of the various securities outstanding
that are not presently
         disclosed in the financial statements, including dividend and
liquidation preferences,
         participation rights, call prices and dates, conversion or exercise
process and significant
         terms of contracts to issue additional shares. Please refer to ASC
505-10-50-3.
General

15.      Please advise whether your company is related to the blank check
company also called
         Ezagoo Inc. (SEC File No. 0-55095) that was a public reporting company
until 2014.
        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
 Xiaohao Tan
Ezagoo Ltd
February 4, 2019
Page 4

time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Joseph Cascarano, Senior Staff Accountant, at (202)
551-3376 or
Robert Littlepage, Accountant Branch Chief, at (202) 551-3361 if you have
questions regarding
comments on the financial statements and related matters. Please contact
Gregory Dundas,
Attorney-Advisor, at (202) 551-3436 or Larry Spirgel, Assistant Director, at
(202) 551-
3810 with any other questions.



FirstName LastNameXiaohao Tan                                Sincerely,
Comapany NameEzagoo Ltd
                                                             Division of
Corporation Finance
February 4, 2019 Page 4                                      Office of
Telecommunications
FirstName LastName