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                 August 7, 2020

       Rodney C. Keller, Jr.
       Chief Executive Officer
       AYRO, Inc.
       900 E. Old Settlers Boulevard, Suite 100
       Round Rock, TX 78664

                                                        Re: AYRO, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed August 3,
2020
                                                            File No. 333-240314

       Dear Mr. Keller, Jr.:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

             Please contact Edwin Kim, Attorney-Advisor, at (202) 551-3297 or
Jan Woo, Legal
       Branch Chief, at (202) 551-3453 with any questions.




                 Sincerely,


                 Division of Corporation Finance

                 Office of Technology
       cc:                                              Rick Werner, Esq.