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                         September 14, 2022

       Andrew Norstrud
       Chief Financial Officer
       Upexi, Inc.
       17129 US Hwy 19 N.
       Clearwater, FL 33760

                                                        Re: Upexi, Inc.
                                                            Registration
Statement on Form S-3
                                                            Filed September 9,
2022
                                                            File No. 333-267355

       Dear Mr. Norstrud:

              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 Conlon
Danberg at 202-551-4466 with any questions.




                         Sincerely,


                         Division of Corporation Finance

                         Office of Life Sciences
       cc:                                              Clint J. Gage, Esq.