United States securities and exchange commission logo February 5, 2021 Paul Travers Chief Executive Officer Vuzix Corporation 25 Hendrix Road, Suite A West Henrietta, New York 14586 Re: Vuzix Corp Registration Statement on Form S-3 Filed February 2, 2021 File No. 333-252673 Dear Mr. Travers: 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 Eiko Yaoita Pyles at 202-551-3587 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing