May 1, 2019

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

       Re: Ezagoo Ltd
           Amendment No. 2 to Registration Statement on Form S-1
           Filed April 29, 2018
           File No. 333-228681

Dear Mr. Tan:

      We have reviewed your amended 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/A filed April 29, 2019

Risk Factors
We operate through "Hunan Ezagoo Zhicheng Internet Technology Limited," a
Chinese, "PRC"
Company . . . , page 7

1.     We note your response to our prior comment 3. Please revise your risk
factor to highlight
       the risks relating to the fact that you do not directly own the entities
that operate your
       business, that you rely on contractual arrangements with your VIEs and
their shareholders
       to operate your business, and do not exercise the same degree of control
over the
 Xiaohao Tan
Ezagoo Ltd
May 1, 2019
Page 2
      operations as if you owned the operating businesses directly as
subsidiaries. Also discuss
      any potential conflicts of interest that arise from this indirect
ownership arrangement.
        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 Joseph Cascarano, Senior Staff Accountant, at (202)
551-3376 or
Robert S. 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.



                                                           Sincerely,
FirstName LastNameXiaohao Tan
                                                           Division of
Corporation Finance
Comapany NameEzagoo Ltd
                                                           Office of
Telecommunications
May 1, 2019 Page 2
cc:       Jeffrey DeNunzio
FirstName LastName