July 7, 2023

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

Re: Energy Focus, Inc.

Registration Statement on Form S-3 (Registration No. 333-272604)

Ladies and Gentlemen:

On behalf of Energy Focus, Inc. (“Energy Focus”), the undersigned hereby requests, pursuant to Rule 461(a) promulgated under the Securities Act of 1933, that the Registration Statement on Form S-3 (File No. 333-272604) of Energy Focus be declared effective at 5:00 p.m., New York City time, on Tuesday, July 11, 2023, or as soon thereafter as practicable. Energy Focus respectfully requests that you notify Michael J. Solecki of such effectiveness by a telephone call to (216) 586-7103.

Please contact Michael J. Solecki of Jones Day at (216) 586-7103 if you have any questions concerning this matter. Thank you for your continued attention to this matter.

Very truly yours,

ENERGY FOCUS, INC.

By:    /s/ James R. Warren         

Name: James R. Warren

Title: Senior Vice President, General Counsel

and Corporate Secretary

cc: Michael J. Solecki, Esq.