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                              August 21, 2020

       Max Munn
       President
       Applied UV, Inc.
       150 N. Macquesten Parkway
       Mount Vernon, NY 10550

                                                        Re: Applied UV, Inc.
                                                            Amendment No. 2 to
                                                            Registration
Statement on Form S-1
                                                            Filed August 14,
2020
                                                            File No. 333-239892

       Dear Mr. Munn:

             We have reviewed your amended registration statement 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 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.
Unless we note
       otherwise, our references to prior comments are to comments in our
August 11, 2020 letter.

       Amended Registration Statement on Form S-1

       Capitalization, page 32

   1.                                                   Please revise the
accumulated deficit line item in your table to say "retained earnings
                                                        (deficit)."
       Dilution, page 33

   2.                                                   We note your response
to prior comment one; however, to the extent that you make a pro
                                                        forma adjustment to
common stock and additional paid-in capital to reflect the issuance of
                                                        230,083 shares of
common stock, valued at $5.00 per share, as compensation for officers
                                                        and directors of the
Company, it appears to us that pro forma retained earnings should also
 Max Munn
Applied UV, Inc.
August 21, 2020
Page 2
         be adjusted for a corresponding decrease of $1,150,415 to reflect the
related compensation
         expense.
Underwriting, page 72

3.       Since you are not relying on Rule 430A of the Securities Act with
respect to pricing terms,
         please fill in the tables on pages 72 and 73 in a pre-effective
amendment to the registration
         statement.
Exhibit 5.1, page II-6

4.       We note that the opinion is addressed to the addressees listed on
Schedule I, which is
         currently blank. Please have counsel revise the opinion to make clear
that all purchasers
         of the securities in the offering are entitled to rely on the opinion.
For more information,
         refer to Section II.B.3.a.d. of Staff Legal Bulletin No. 19.
5.       We note that the introductory paragraph references only the
underwriting agreement.
         Please have counsel revise the first paragraph of the opinion to
indicate that it is being
         filed in connection with the registration statement.
6.       Please have counsel add a statement confirming that they have
consented to the use of the
         their name in the registration statement.
7.       Please remove the language in paragraph (c) of page 3 of the opinion
stating that counsel
         has relied "solely on representations that [they] have received from
the Company". The
         staff considers it inappropriate to assume any of the material facts
underlying the opinion.
         Please revise to state that it is counsel's opinion that the shares of
common stock have
         been duly authorized, validly issued and are fully paid and
nonassessable. For more
         information, please refer to Section II.B.3.a. of Staff Legal Bulletin
No. 19.
       You may contact Dale Welcome at 202-551-3865 or Kevin Stertzel at
202-551-3723 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Erin Purnell at 202-551-3454 or Asia Timmons-Pierce at 202-551-3754
with any other
questions.



FirstName LastNameMax Munn                                      Sincerely,
Comapany NameApplied UV, Inc.
                                                                Division of
Corporation Finance
August 21, 2020 Page 2                                          Office of
Manufacturing
FirstName LastName