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                             June 14, 2021

       Michael McConnell
       Chief Executive Officer
       EzFill Holdings, Inc.
       2125 Biscayne Blvd, #309
       Miami, Fl. 33137

                                                        Re: EzFill Holdings,
Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed June 1, 2021
                                                            File No. 333-256691

       Dear Mr. McConnell:

              We have reviewed your registration statement and have the
following 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-1

       Dilution, page 13

   1.                                                   It appears you have
included goodwill in the determination of net tangible book value.
                                                        Please revise or
otherwise advise.
   2.                                                   Please revise the net
tangible book value per share as of March 31, 2021 in the second
                                                        sentence to agree with
the $(0.14) per share disclosed elsewhere.
   3.                                                   Please reconcile the
pro forma net tangible book value per share of $1.13 disclosed in the
                                                        third paragraph to the
$1.05 per share disclosed in the table.
 Michael McConnell
FirstName  LastNameMichael McConnell
EzFill Holdings, Inc.
Comapany
June       NameEzFill Holdings, Inc.
     14, 2021
June 14,
Page 2 2021 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
15

4.       We note your response to prior comment 3. Please disclose that
delivery fees, including
         one-time delivery fees and monthly subscription fees, minimally
contribute to revenue,
         and that their contribution has been decreasing in the periods being
presented.
         See Section III of SEC Release No. 33-8350.
        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.

        You may contact Tatanisha Meadows at 202-551-3322 or Theresa Brillant
at 202-551-
3307 if you have questions regarding comments on the financial statements and
related
matters. Please contact Donald Field at 202-551-3680 or Mara Ransom at
202-551-3264 with
any other questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Trade &
Services