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United States securities and exchange commission logo





                          October 14, 2022

       Stephen Cotton
       Chief Executive Officer
       Aqua Metals, Inc.
       5370 Kietzke Lane, Suite 201
       Reno, Nevada 89511

                                                        Re: Aqua Metals, Inc.
                                                            Registration
Statement on Form S-3
                                                            Filed October 7,
2022
                                                            File No. 333-267780

       Dear Stephen Cotton:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

                                                        Please contact Gregory
Herbers at 202-551-8028 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Manufacturing
       cc:                                              Daniel K. Donahue
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