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United States securities and exchange commission logo





                               October 19, 2021

       Andrew Shape
       Chief Executive Officer and President
       Stran & Company, Inc.
       2 Heritage Drive, Suite 600
       Quincy, MA 02171

                                                        Re: Stran & Company,
Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed October 7,
2021
                                                            File No. 333-260109

       Dear Mr. Shape:

             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
October 1, 2021 letter.

       Registration Statement on Form S-1 Filed October 7, 2021

       Report of Independent Registered Public Accounting Firm, page F-14

   1.                                                   We note your response
to prior comment 7. Please tell us your auditor's consideration of
                                                        the guidance in
paragraph .05 of PCAOB Auditing Standard 3110 relating to dual dating
                                                        their report for the
stock split. Additionally, please ensure that the report date referenced
                                                        in the consent is
consistent with the report date in the filing.
 Andrew Shape
FirstName LastNameAndrew   Shape
Stran & Company, Inc.
Comapany
October 19,NameStran
            2021      & Company, Inc.
October
Page 2 19, 2021 Page 2
FirstName LastName
Notes to Financial Statements
N. Acquisition, page F-24

2.       We note your response to prior comment 8. You state your experience in
the industry as
         the rationale for estimating a useful life of ten years. Please
explain how you considered
         the various factors listed in your response, including specifically
your own historical
         experience with customers renewing or extending similar arrangements,
and how it relates
         to the $2.2 million customer list asset acquired in August 2020.
General

3.       We note that Section 5.5 of your bylaws includes a right of first
refusal in favor of the
         company that applies to all stockholders. Please describe this
provision in your filing and
         discuss any risks related to such transfer restrictions in your risk
factors.
        You may contact Nasreen Mohammed at 202-551-3773 or Theresa Brillant at
202-551-
3307 if you have questions regarding comments on the financial statements and
related
matters. Please contact Taylor Beech at 202-551-4515 or Erin Jaskot at
202-551-3442 with any
other questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Trade &
Services
cc:      Louis A. Bevilacqua
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