November 22, 2019

Tyler B. Wilson
Chief Financial Officer
Taronis Fuels, Inc.
300 W. Clarendon Ave., Unit 230
Phoenix, AZ 85013

       Re: Taronis Fuels, Inc.
           Amendment No. 1 to Registration Statement on Form 10-12G
           Filed November 8, 2019
           File No. 000-56101

Dear Mr. Wilson:

       We have reviewed your filing 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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

     After reviewing your response and any amendment you may file in response
to these
comments, we may have additional comments. Unless we note otherwise, our
references to prior
comments are to comments in our October 25, 2019 letter.

Form 10-12G/A filed November 8, 2019

Description of Capital Stock
Forum Provisions, page 70

1.    We note your response to prior comment 11 and reissue it in part. Please
disclose on page
      70 that investors cannot waive compliance with the federal securities
laws and the rules
      and regulations thereunder. Also clarify in your related risk factor on
page 28 that the
      forum provision does not apply to actions arising under the Securities
Exchange Act of
      1934.
 Tyler B. Wilson
FirstName LastNameTyler B. Wilson
Taronis Fuels, Inc.
November NameTaronis Fuels, Inc.
Comapany 22, 2019
Page 2
November 22, 2019 Page 2
FirstName LastName
Financial Statements
Note 4 - Acquisitions, page F-14

2.       We note your response to prior comment 13. Please tell us how you
considered Rule 8-
         04(c)(3) of Regulation S-X in evaluating whether individually
insignificant businesses
         acquired were significant in the aggregate and whether you are
required to include audited
         financial statements and pro forma information. As part of your
response, provide us with
         the results of your significance tests for individually insignificant
businesses in the
         aggregate, utilizing amounts for total assets and net income (loss)
for Taronis Fuels in
         your analysis.
        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.

        You may contact Claire DeLabar, Staff Accountant, at 202-551-3349 or
Christine Dietz,
Senior Staff Accountant, at 202-551-3408 if you have questions regarding
comments on the
financial statements and related matters. Please contact Michael Foland, Staff
Attorney, at 202-
551-6711 or Kathleen Krebs, Special Counsel, at 202-551-3350 with any other
questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Technology
cc:      Laura Anthony