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                               February 12, 2021

       Mark Hess
       Chief Financial Officer
       ENGLOBAL CORP
       654 North Sam Houston Parkway East
       Suite 400
       Houston, TX 77060-5914

                                                        Re: ENGLOBAL CORP
                                                            Registration
Statement on Form S-3
                                                            Filed January 29,
2021
                                                            File No. 333-252572

       Dear Mr. Hess:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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-3 filed January 29, 2021

       Sales Agreement Prospectus
       Cover Page, page i

   1.                                                   Describe the recent
price volatility in your common stock and briefly disclose any known
                                                        risks of investing in
your common stock under these circumstances.
   2.                                                   Please add, for
comparison purposes, disclosure of the sale price of your common stock
                                                        prior to the recent
price volatility in your stock. For example, please disclose the price at
                                                        which your stock was
trading 30 days prior to your filing.
   3.                                                   Describe any recent
change in your financial condition or results of operations, such as
                                                        your earnings, revenues
or other measure of company value that is consistent with the
 Mark Hess
FirstName LastNameMark Hess
ENGLOBAL     CORP
Comapany12,
February  NameENGLOBAL
            2021          CORP
February
Page 2 12, 2021 Page 2
FirstName LastName
         recent change in your stock price. If no such change to your financial
condition or results
         of operations exists, disclose that fact.
Prospectus Summary
The Offering, page 3

4.       We note that the number of    Common Stock to be outstanding after
this offering    reflects
         the number of shares to be issued in this offering based on the market
price of your
         common stock at $7.44 per share (which significantly exceeds your
historical average
         price per share). Please revise to disclose the price at which your
common stock was
         trading 30 days prior to your filing and the corresponding number of
shares of common
         stock that would be issued in this offering based on that historical
price.
Risk Factors, page 4

5.       We note your registration statement for $100,000,000, which includes
up to $25,000,000
         of common stock in your sales agreement prospectus, as well as an
additional $75,000,000
         of common stock and/or preferred stock. To the extent you expect to
conduct additional
         offerings in the future to fund your operations or provide liquidity,
include risk factor
         disclosure that addresses the dilutive impact of those offerings on
investors that may
         purchase shares in this offering at a significantly higher price.
Risks Related to our Common Stock and the Offering
"There may be future dilution of our common stock ... ", page 4

6.       We note your disclosure on the cover page of your sales agreement
prospectus that you
         intend to sell up to $25,000,000 of common stock. Please revise this
risk factor to state
         that the sale of shares in this offering will increase the supply of
available shares, which
         may result in a decrease in your stock price.
"Our Stock price could be volatile ... ", page 5

7.       We note your disclosure that    [t]he stock market has from time to
time experienced
         significant price and volume fluctuations that may be unrelated to the
operating
         performance of particular companies    and your disclosure that
[d]uring the past twelve
         months, the sales price of our stock ranged from a low of $0.46 per
share in March 2020,
         to a high of $9.40 per share in January 2021.    Your disclosure
should also address the
         potential for rapid and substantial decreases in your stock price,
including decreases
         unrelated to your operating performance or prospects. To the extent
recent increases in
         your stock price are significantly inconsistent with improvements in
actual or expected
         operating performance, financial condition or other indicators of
value, discuss the
         inconsistencies and where relevant, quantify them. If you lack
information to do, explain
         why.
8.       Please consider whether your recent increase in price volatility
exposes your common
         stock to short sale risk. If so, please consider disclosing the risks
associated with your
 Mark Hess
ENGLOBAL CORP
February 12, 2021
Page 3
         common stock being    shorted    and the ultimate effects that such
actions could have on
         this at-the-market offering. Please also include a risk factor
addressing the effects of a
         potential    short squeeze    due to a sudden increase in demand for
your common stock.
         Among other things, your disclosure should describe what typically
happens following a
         short squeeze and address the impact on investors that purchase shares
during that time.
        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.

       Please contact Cara Wirth at 202-551-7127 or Mara Ransom at 202-551-3264
with any
other questions.



FirstName LastNameMark Hess                                    Sincerely,
Comapany NameENGLOBAL CORP
                                                               Division of
Corporation Finance
February 12, 2021 Page 3                                       Office of Trade
& Services
FirstName LastName