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                              January 2, 2024

       John Keeler
       Chief Executive Officer
       Blue Star Foods Corp.
       3000 NW 109th Avenue
       Miami, FL 33172

                                                        Re: Blue Star Foods
Corp.
                                                            Registration
Statement on Form S-1
                                                            Filed December 8,
2023
                                                            File No. 333-275955

       Dear John Keeler:

              We have conducted a limited review of your registration statement
and have the
       following comment(s).

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.

       Registration Statement on Form S-1 filed December 8, 2023

       General

   1.                                                   Please revise your
registration statement to clearly identify the securities that are being
                                                        offered. In this
regard, we note that the heading and disclosure on the prospectus cover
                                                        page refers to
19,876,735 shares of common stock, yet additional disclosure and Exhibit
                                                        107 refers to warrants.
Revise to clarify whether you are registering the warrants and/or
                                                        the shares underlying
such warrants.
   2.                                                   We note there does not
appear to be an established public trading market for the
                                                        warrants to purchase up
to 435,035 shares of common stock. Please revise your prospectus
                                                        to disclose a fixed
price at which the selling stockholders will offer and sell the warrants.
                                                        Refer to Item 501(b)(3)
of Regulation S-K. Also, disclose, if true, that there is no
                                                        established public
trading market for the warrants and that you do not intend to apply to
                                                        list the warrants on a
national securities exchange or recognized trading system.
 John Keeler
Blue Star Foods Corp.
January 2, 2024
Page 2
3.       Please revise your registration statement to identify ClearThink
Capital Partners, LLC as
         an underwriter. Refer to Securities Act Sections Compliance and
Disclosure
         Interpretations Question 139.22.
4.     We note your disclosure on the prospectus cover page that on May 16,
2023 you and
       ClearThink Capital Partners, LLC entered into a purchase agreement.
Please revise your
       filing throughout to discuss the material terms of this agreement,
including:
           the term of the agreement;
           the material conditions under which you may access the funds
available under the
            agreement;
           the possibility that you may not have access to the full amount
available to you under
            the agreement; and
           whether an investor can engage in short-selling activities and, if
so, how any sales
            activities after announcement of a put may negatively affect the
company   s share
            price.
FirstName LastNameJohn       Keeler
Comapany
5.          NameBlue
       Please            Starcompensation
               update your    Foods Corp. disclosure to reflect the fiscal year
ended December 31,
January2023.
         2, 2024 Page 2
FirstName LastName
 John Keeler
FirstName  LastNameJohn Keeler
Blue Star Foods Corp.
Comapany
January    NameBlue Star Foods Corp.
        2, 2024
January
Page 3 2, 2024 Page 3
FirstName LastName
        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 Patrick Fullem at 202-551-8337 or Jennifer Angelini at
202-551-3047 with
any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of
Manufacturing
cc:      Cassie Olson