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                              August 16, 2022

       Akinobu Yorihiro
       Chief Technology Officer
       Sacks Parente Golf, Inc.
       551 Calle San Pablo
       Camarillo, CA 93012

                                                        Re: Sacks Parente Golf,
Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed August 5,
2022
                                                            File No. 333-266610

       Dear Mr. Yorihiro:

              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 on August 5, 2022

       Prospectus Summary
       Risks Associated with our Business, page 7

   1.                                                   We note that you added
a statement to summary risk factors in response to comment 2, but
                                                        have not added
corresponding risk factor disclosure. Please revise to add a discussion in
                                                        risk factors that
addresses the fact that your independent auditor has expressed substantial
                                                        doubt about your
ability to continue as a going concern. Please ensure that all other
                                                        summary risk factor
disclosures have corresponding disclosures in Risk Factors.
       Risk Factors
       Certain of our stockholders, if they choose to act together..., page 29

   2.                                                   Please revise to
disclose whether you will be a controlled company under applicable
 Akinobu Yorihiro
FirstName LastNameAkinobu     Yorihiro
Sacks Parente Golf, Inc.
Comapany
August 16, NameSacks
           2022        Parente Golf, Inc.
August
Page 2 16, 2022 Page 2
FirstName LastName
         listing standards. If so, please revise to disclose this fact on your
cover page. Please
         identify the controlling shareholder and its ownership percentage
after the offerings
         described in the two prospectuses.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Impact of Supply Chain Disruption, page 35

3.       We note your revisions in response to comment 6 and reissue. Please
discuss whether
         supply chain disruptions materially affect your outlook or business
goals. Specify whether
         these challenges have materially impacted your results of operations
or capital resources
         and quantify, to the extent possible, how your sales, profits, and/or
liquidity have been
         impacted.
Comparison of the Three Months Ended March 31, 2022 to the Three Months Ended
March 31,
2021, page 36

4.       We have read your response to prior comment 10. As previously
requested, please also
         revise your discussion on page 38 related to cost of goods sold for
the comparison of the
         year ended December 31, 2021 compared to the year ended December 31,
2020 to state
         your actual gross margin and discuss the reasons for the changes in
your actual gross
         margin in order to not give more prominence to your discussion of
gross margin excluding
         changes in inventory reserves.
Certain Relationships and Related Party Transactions, page 58

5.       Please revise your disclosure in this section to include the
disclosure provided on page 40,
         rather than a cross-reference. Furthermore, Section 402 of the
Sarbanes-Oxley Act of
         2002 prohibits public companies from extending or maintaining credit
in the form of
         personal loans to or for any director or executive officer. To the
extent necessary, disclose
         the action that will be taken to ensure any applicable arrangements
will be extinguished
         prior to the completion of the initial public offering or tell us why
this provision does not
         apply to any of the loans disclosed in this section.
Financial Statements
General, page F-1

6.       Please note the financial statement updating requirements of Rule 8-08
of Regulation S-
         X, as applicable.
Report Of Independent Registered Public Accounting Firm, page F-2

7.       We have read your response to comment 14. We note that your auditor
has provided an
         appropriately signed opinion. As previously requested, please also
have your independent
         registered public accountants provide an appropriately "signed"
consent in Exhibit 23.1.
         Please note that your current consent does not have a conforming
signature of your
         independent registered public accountant.
 Akinobu Yorihiro
Sacks Parente Golf, Inc.
August 16, 2022
Page 3
Note 9 - Subsequent Events, page F-17

8.       We have read your response to prior comment 15. Please provide the
following:
             We note that you have revised your disclosure to indicate that
subsequent events were
            evaluated from April 1, 2022 through June 27, 2022. Given that the
auditor   s opinion
            is dated June 24, 2022, please revise your subsequent events
footnote to reflect that
            management evaluated subsequent events through June 24, 2022 rather
than June 27,
            2022;
             As previously requested, please also revise your disclosure to
indicate whether the
            date through which your subsequent events were evaluated is also
the date the
            financial statements were issued or the date the financial
statements were available to
            be issued; and
             We note that you disclosed under Note 8 - Stockholders' Deficit
that you evaluated
            subsequent events through August 5, 2022. Please revise your filing
to move this
            disclosure to Note 9 - Subsequent Events on page F-32. In addition,
please also
            similarly revise your disclosure to state whether August 5, 2022 is
the date the
            financial statements were issued or the date the financial
statements were available to
            be issued, as applicable. See ASC 855-10-50-1.
Exhibit Index, page II-4

9.       We note that your Certificate and Bylaws include a forum selection
provision. Please
         revise your disclosure to clearly and prominently describe the
provision, including the
         relevant forum for litigation and any subject matter jurisdiction
carve out. Please clearly
         describe any risks or other impacts on investors and address any
uncertainty about
         enforceability.
        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 Kevin Woody at
202-551-3629 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Alex King at 202-551-8631 or Erin Purnell at 202-551-3454 with any
other questions.



FirstName LastNameAkinobu Yorihiro                              Sincerely,
Comapany NameSacks Parente Golf, Inc.
August 16, 2022 Page 3                                          Division of
Corporation Finance
FirstName LastName                                              Office of
Manufacturing