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                           July 14, 2020

       William B. Hoagland
       Principal Financial Officer
       Ecoark Holdings, Inc.
       5899 Preston Road #505
       Frisco, TX 75034-9591

                                                        Re: Ecoark Holdings,
Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed July 2, 2020
                                                            File No. 333-239646

       Dear Mr. Hoagland:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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

       General

   1.                                                   We note your recent
acquisition of Banner Midstream Corp. Please tell why you have not
                                                        included financial
statements of this business and pro forma information reflecting the
                                                        transaction. Refer to
Rules 8-04 and 8-05 of Regulation S-X.
               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.
 William B. Hoagland
Ecoark Holdings, Inc.
July 14, 2020
Page 2

       Please contact Asia Timmons-Pierce, Special Counsel, at 202-551-3754 or
Jay Ingram,
Legal Branch Chief, at 202-551-3397 with any other questions.



                                                         Sincerely,
FirstName LastNameWilliam B. Hoagland
                                                         Division of
Corporation Finance
Comapany NameEcoark Holdings, Inc.
                                                         Office of
Manufacturing
July 14, 2020 Page 2
cc:       Ross Carmel
FirstName LastName