EF Hutton

17 Battery Place, Suite 625

New York, New York 10004


July 2, 2021




U.S. Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington, D.C. 20549


  RE: Agriforce Growing Systems, Ltd.
    Registration Statement on Form S-1
    File No. 333- 251380


Dear Sir or Madam:


Pursuant to Rule 461 under the Securities Act of 1933, as amended, EF Hutton, division of Benchmark Investments, LLC, in its capacity as representative of the underwriters, pursuant to that certain registration statement on Form S-1, File No. 333- 251380 (the “Registration Statement”) of Agriforce Growing Systems, Ltd. (the “Company”), we wish to advise you that we hereby join with the Company’s request that the effective date of the Registration Statement be accelerated so that the same will become effective at 4:45 P.M., Eastern Time, on July 7, 2021, or as soon as practicable thereafter.


The undersigned advises that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.


  EF Hutton,  
  division of Benchmark Investments, LLC
  By: /s/ Sam Fleischman
  Name: Sam Fleischman
  Title: Supervisory Principal