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                            July 13, 2023

       Benjamin Piggott
       Chief Executive Officer
       EF Hutton Acquisition Corp I
       24 Shipyard Drive, Suite 102
       Hingham, MA 02043

                                                        Re: EF Hutton
Acquisition Corp I
                                                            Registration
Statement on Form S-4
                                                            Filed June 26, 2023
                                                            File No. 333-272914

       Dear Benjamin Piggott:

              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-4

       Ownership of the Post-Business Combination Company After the Closing,
page 23

   1.                                                   Please reconcile for us
the ownership interest percentages of ECD Automotive Design,
                                                        Inc. in the
organization chart on page 23 to the ownership percentages in the "Equity
                                                        Capitalization Summary"
table on the same page.
       EFHAC's Board of Directors' Reasons for the Approval of the Business
Combination, page 63

   2.                                                   Please revise the
production plan and margin expansion opportunity table on page 63 to
                                                        label each column.
 Benjamin Piggott
FirstName  LastNameBenjamin
EF Hutton Acquisition Corp I Piggott
Comapany
July       NameEF Hutton Acquisition Corp I
     13, 2023
July 13,
Page  2 2023 Page 2
FirstName LastName
Adjustments to Unaudited Pro Forma Condensed Combined Balance Sheet, page 131

3.       We note that pro forma adjustment (J) reflects the impact of a $35
million PIPE
         financing. However, your disclosures throughout the filing, including
on page
         43, indicate that there currently "is no commitment for the proposed
additional financing"
         and that there "is no assurance" that you will enter into
subscriptions at the presumed
         terms "or at all." Please remove the PIPE Financing adjustment from
your pro forma
         financial statements until if and when there are formal agreements in
place. Prominently
         disclose, to the extent applicable, that the redemption scenarios
depicted would not meet
         the conditions necessary for the merger transaction to be consummated.
3. Adjustments to Unaudited Pro Forma Condensed Combined Financial Information,
page 137

4.       We note your response to prior comment 26 and your disclosure that the
pro forma
         combined statement of operations "does not reflect a provision for
income taxes or any
         amounts that would have resulted had the Combined Company filed
consolidated income
         tax returns during the periods presented." Please disclose and confirm
that you have used
         the separate return method in calculating the pro forma tax provision
and tax effects
         of your pro forma adjustments. Refer to Rule 11-02(b)(5) of Regulation
S-X.
Financial Statements - Humble Imports, Inc. d/b/a ECD Auto Design 6. Lease,
page F-49

5.       We note your response to prior comment 31 and that the square footage
related to
         the ECD UK lease in Burton Upon Trent, Staffordshire is still blank on
page 108. As
         previously requested, please populate the square footage related to
this lease.
General

6.       We note your response to prior comment 43. Please revise to disclose
how EF Hutton is
         assisting EFHAC with the PIPE Financing.
        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 Ernest Greene at 202-551-3733 or Andrew Blume at
202-551-3254 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Erin Donahue at 202-551-6063 or Evan Ewing at 202-551-5920 with any
other
questions.
 Benjamin Piggott
EF Hutton Acquisition Corp I
July 13, 2023
Page 3

FirstName LastNameBenjamin Piggott          Sincerely,
Comapany NameEF Hutton Acquisition Corp I
                                            Division of Corporation Finance
July 13, 2023 Page 3                        Office of Manufacturing
FirstName LastName