United States securities and exchange commission logo August 8, 2022 Ingo Mueller Chief Executive Officer AgriFORCE Growing Systems Ltd. 300 2233 Columbia Street Vancouver, BC V5Y 0M6 Canada Re: AgriFORCE Growing Systems Ltd. Registration Statement on Form S-1 Filed August 1, 2022 File No. 333-266441 Dear Mr. Mueller: 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 Alex King at 202-551-8631 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing