501 Brickell Key Drive, Suite 300

Miami, FL 33131


October 6, 2020




U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549


Attention: Mr. Daniel Morris


Re:ShiftPixy, Inc.

Registration Statement on Form S-1

File No. 333-240136

Request for Acceleration


Dear Mr. Morris:


Pursuant to Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended, ShiftPixy, Inc. (the “Registrant”) hereby requests acceleration of the effective date of its Registration Statement on Form S-1 (File No. 333-240136), so that it may become effective at 5:00 p.m. (Washington, D.C. time) on October 8, 2020, or as soon thereafter as practicable. In prior correspondence, dated August 19, 2020, the Registrant had previously requested effectiveness which was verbally withdrawn by the Registrant on August 20, 2020.


Please call Ivan Blumenthal, of Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., counsel to the Registrant, at (212) 692-6784 with any comments or questions regarding this matter.


  Very truly yours,

ShiftPixy, Inc.
  By:   /s/ Scott Absher  
    Name:   Scott Absher  
    Title:   Chief Executive Officer  


cc:ShiftPixy, Inc.

Scott Absher


Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

Ivan K. Blumenthal, Esq.