March 27, 2019

Christopher Cashion
Chief Financial Officer
Superior Drilling Products, Inc.
1583 South 1700 East
Vernal, Utah 84078

       Re: Superior Drilling Products, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed March 13, 2019
           Response letter dated February 12, 2019
           File No. 001-36453

Dear Mr. Cashion:

       We have reviewed your February 12, 2019 response to our comment letter
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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

     After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
December 4, 2018 letter.

Form 10-K for the Fiscal Year Ended December 31, 2018

Note 5. Related Party Note Receivable, page 47

1.     We note your response to prior comment 3 regarding the modifications
made to the
       Tronco Energy Corporation loan. Please respond to the following:

           In regards to the modification on June 29, 2014, explain further how
the reduction of
           the interest rate did not cause the loan to be considered a troubled
debt restructuring.
           Specifically, your response indicates that the Meier stock pledge of
8,814,860 shares
           served as adequate compensation for the decrease in interest rate
and extension of the
           loan repayment. However, it is unclear how the stock pledge
compensates the
           Company for the substantial reduction in interest rate for the
modified contractual
 Christopher Cashion
FirstName LastNameChristopher Cashion
Superior Drilling Products, Inc.
Comapany2019
March 27, NameSuperior Drilling Products, Inc.
Page 2
March 27, 2019 Page 2
FirstName LastName
             period. Provide your analysis for determining that the collateral
served as adequate
             compensation, particularly since the Meier's had already provided
guaranties on the
             loan prior to the modification. Additionally, provide your
analysis as to whether you
             believe the modified interest rate resulted in a market rate of
interest for the loan.
             In regards to the modification in November 2015, explain further
how the extension of
             the note and the extended reduction in interest rate did not cause
the loan to be
             considered a troubled debt restructuring. Specifically, explain
why the Meiers' salary
             reduction and lack of a bonus served to offset the concession
provided regarding the
             extension. As part of your response, explain whether there was any
contractual
             documentation linking these actions to the loan modification and
provide details
             quantifying the value of these actions relative to the concession
value of the
             modification.
             In regards to the August 8, 2017 modification, explain further how
the extension of the
             note and the extended reduction in interest rate did not cause the
loan to be considered
             a troubled debt restructuring. Specifically, your response
indicates that you received
             530,725 restricted stock units pledged as additional collateral
upon the modification in
             2017. However, on page 37 of your 2017 Form 10-K, you state that
as part of the sale
             of real estate to Superior Auto Body, you released 547,000 shares
of Meiers' common
             stock from the collateral for the Tronco note (and the reduction
can be seen in the
             disclosure on page 48 of the 2017 Form 10-K where the shares held
in escrow are
             reduced to 8,267,860, from 8,814,860 in prior periods), so it is
unclear how these
             additional shares serve as additional collateral when there was an
overall reduction in
             the shares held as collateral for the year.


2.       We note that the Seconded Amended and Restated Loan Agreement that is
dated effective
         August 8, 2017 and filed as Exhibit 10.2 includes Schedule 1.3 that
lists the collateral
         documents for the loan agreement. Explain why this Schedule lists that
there are
         8,814,860 shares pledged pursuant to the Security Agreement Pledge
when you state on
         page 37 of your 2017 Form 10-K that you released 547,000 shares of the
Meiers' common
         stock from the collateral in February 2017 upon the sale of real
estate to Superior Auto
         Body.
3.       Explain the business purpose of the August 8, 2017 modification of the
Tronco loan to
         extend the maturity date an additional 5 years. Specifically, in light
of the fact that
         Tronco has no remaining assets, it is unclear why the loan was
modified to extend the
         maturity date and reduced interest rate period rather than execute
under the Stock Pledge
         Agreement. Additionally, address the following:

             Tell us what percentage of the Meiers' holdings of the Company's
common stock is
             held in escrow under the Stock Pledge Agreement.
             In light of the substantial percentage of the Meiers' holdings of
the Company's
             common stock that is held in escrow, tell us how you determined
that the Company
 Christopher Cashion
Superior Drilling Products, Inc.
March 27, 2019
Page 3
             would execute under its contractual rights under the guaranties.
As part of your
             response, address the fact that this modification represented the
longest loan maturity
             period extension to date (5 years), and was done despite the fact
that Tronco Energy
             Corporation has no remaining assets.
4.       We note that you continue to recognize interest income on the Tronco
loan despite the fact
         that there have not been any cash payments received for the related
interest payments.
         Furthermore, the only collateral remaining for the Tronco loan is the
shares and restricted
         stock units pledged under the Stock Pledge Agreement. Lastly, the
Tronco loan continues
         to be modified with the contractual period extended for several years
upon nearing the
         revised maturity. In light of these factors, tell us how you concluded
it was appropriate to
         continue to recognize interest income on this loan. As part of your
response, tell us
         whether you considered the cost-recovery method for the recognition of
interest income,
         as outlined in ASC 310-10-35-11.
       You may contact John Cannarella, Staff Accountant, at (202) 551-3337 or
Jenifer
Gallagher, Staff Accountant, at (202) 551-3706 with any questions.



FirstName LastNameChristopher Cashion                          Sincerely,
Comapany NameSuperior Drilling Products, Inc.
                                                               Division of
Corporation Finance
March 27, 2019 Page 3                                          Office of
Natural Resources
FirstName LastName