July 24, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, NE

Washington, D.C. 20549

Attention: Asia Timmons-Pierce

Jay Ingram

Re:	Ecoark Holdings, Inc.
	Registration Statement on Form S-1, as amended
	File No. 333-239646
	Acceleration Request
	Requested Date:	July 28, 2020
	Requested Time:	5:00 P.M. Eastern Time

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Ecoark Holdings, Inc. (the “Company”) hereby respectfully requests that the above-referenced Registration Statement on Form S-1 (File No. 333-239646) (the “Registration Statement”) be declared effective at the “Requested Date” and “Requested Time” set forth above, or as soon as practicable thereafter, or at such later time as the Company or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission. The Company hereby authorizes Arif Soto, counsel to the Company, to make such request on its behalf.

Please confirm the effectiveness of the Registration Statement with Arif Soto of Carmel, Milazzo & Feil LLP by telephone at (646) 561-9000 or email at asoto@cmfllp.com.

Sincerely,

ECOARK HOLDINGS, INC.

/s/ Randy S. May

Randy S. May
Chief Executive Officer