November 6, 2018

Fred W. Wagenhals
President and Chief Executive Officer
Ammo, Inc.
6401 East Thomas Road, #106
Scottsdale, Arizona 85251

       Re: Ammo, Inc.
           Amendment No. 1 to Registration Statement on Form S-1
           Filed October 16, 2018
           File No. 333-226087

Dear Mr. Wagenhals:

      We have reviewed your amended 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. Unless
we note
otherwise, our references to prior comments are to comments in our August 3,
2018 letter.

Form S-1/A filed October 16, 2018

General

1.     We note your response to prior comment 2, however, your disclosure
continues to indicate
       that the selling stockholders intend to sell their shares at prevailing
market prices. Please
       disclose a fixed price at which the selling stockholders will sell their
shares until there is
       an established trading market therefor. Please note that the OTC Pink
marketplace is not
       an existing trading market for purposes of satisfying Item 501(b)(3) of
Regulation S-K.
 Fred W. Wagenhals
FirstName LastNameFred W. Wagenhals
Ammo, Inc.
Comapany 6, 2018
November NameAmmo, Inc.
Page 2
November 6, 2018 Page 2
FirstName LastName
Market Information, page 27

2.       Please revise to state that there is no established trading market for
your common stock
         pursuant to Item 201(a)(1)(i) of Regulation S-K, which provides that
"the existence of
         limited or sporadic quotations" such as the pink sheets "should not of
itself be deemed to
         constitute an 'established public trading market.'" In addition,
please revise your table to
         include data for all interim period for which financial statements are
included. Please see
         Item 201(a)(ii) of Regulation S-K.
Recent Sales of Unregistered Securities; Use of Proceeds from Unregistered
Securities, page 28

3.       Please revise your disclosure to name the persons or identify the
class of persons to whom
         the securities were sold. In addition, please revise your disclosure
to identify the
         exemption from registration relied upon for each transaction and the
facts relied upon.
         Please see Item 701(b) and (d) of Regulation S-K.
4.       We note your disclosure on page 30 that on October 5, 2018, you
completed the
         acquisition of SW Kenetics in exchange for cash and 1,700,002
restricted shares of
         common stock that "will be issued." Please confirm that no shares have
been issued. To
         the extend that shares have already been issued, please revised your
disclosure
         accordingly.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Overview, page 29

5.       We note your disclosures related to your recent acquisition of SW
Kenetics Inc. Please
         revise your disclosures to quantify the purchase price for the
acquisition and more fully
         discuss the related contingencies, including how they impacted your
determination of the
         purchase price.
Financial Statements
Recent Accounting Pronouncements, page 75

6.       We note your disclosures in regard to ASU 2014-09 and the status of
your adoption of the
         standard. Please clarify whether you have in fact adopted ASC 606 here
and on page 97.
          Further we note your response to prior comment 17. Please revise your
disclosures to
         comply with ASC 606-10-50.
 Fred W. Wagenhals
Ammo, Inc.
November 6, 2018
Page 3

        You may contact Kevin Stertzel, Staff Accountant, at (202) 551-3723 or
Anne
McConnell, Staff Accountant, at (202) 551-3709 if you have questions regarding
comments on
the financial statements and related matters. Please contact Sergio Chinos,
Staff Attorney, at
(202) 551-7844 or Amanda Ravitz, Assistant Director, at (202) 551-3412 with any
other
questions.



                                                           Sincerely,

FirstName LastNameFred W. Wagenhals                        Division of
Corporation Finance
                                                           Office of
Manufacturing and
Comapany NameAmmo, Inc.
                                                           Construction
November 6, 2018 Page 3
cc:       Jon S. Cohen
FirstName LastName