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                              July 15, 2020

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

                                                        Re: Superior Drilling
Products, Inc.
                                                            Registration
Statement on Form S-3
                                                            Filed July 1, 2020
                                                            File No. 333-239608

       Dear Mr. Cashion:

              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-3 filed July 1, 2020

       General

   1.                                                   We note that this
registration statement covers the resale of up to 4 million shares by Troy
                                                        and Annette Meier, your
founders and CEO and COO, respectively. Further, we note
                                                        your disclosure on page
5 of the resale prospectus that the Meiers have agreed with you
                                                        that the proceeds of
any share sales under this prospectus shall be used to reduce the
                                                        amounts outstanding
under the Tronco note receivable. In light of both the
                                                        Meiers' relationship to
the company and the fact that the proceeds of any resales will be
                                                        going to the company,
please provide a detailed legal analysis of why this transaction
                                                        should be considered a
secondary offering. Consider Question 212.15 and Interpretation
                                                        612.09 of our
Securities Act Rules Compliance and Disclosure Interpretations.
 Christopher Cashion
Superior Drilling Products, Inc.
July 15, 2020
Page 2
2.     Please tell us whether there is a written agreement with the Meiers
requiring them to use
       the proceeds from any resales to reduce the amounts outstanding under
the Tronco note
       receivable, and if so, please file this agreement.
        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.

       Please contact Michael C. Foland, Attorney-Advisor, at (202) 551-6711 or
Jan Woo,
Legal Branch Chief, at (202) 551-3453 with any other questions.



                                                            Sincerely,
FirstName LastNameChristopher Cashion
                                                            Division of
Corporation Finance
Comapany NameSuperior Drilling Products, Inc.
                                                            Office of
Technology
July 15, 2020 Page 2
cc:       Kevin J. Poli, Esq.
FirstName LastName