Energy Focus, Inc.

32000 Aurora Road, Suite B

Solon, OH 44139

November 29, 2018

VIA EDGAR

US Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

Re:    Energy Focus, Inc.

Registration Statement on Form S-3

Filed November 7, 2018

File No. 333-228255

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Energy Focus, Inc. (the “Company”) hereby respectfully requests that the above-referenced Registration Statement be declared effective at 4:30 p.m., Eastern time, on December 4, 2018 or as soon thereafter as practicable.

Please contact Janet Spreen of Baker & Hostetler LLP at (216) 861-7564 with any questions regarding the foregoing and to confirm the effectiveness of the Registration Statement.

Very truly yours,

Energy Focus, Inc.

By: _/s/ Jerry Turin            

Jerry Turin

Chief Financial Officer