October 28, 2024 Raymond Nobu Chang Chief Executive Officer Agrify Corporation 2468 Industrial Row Drive Troy, MI 48084 Re: Agrify Corporation Amendment No. 1 to Registration Statement on Form S-1 Filed October 23, 2024 File No. 333-282387 Dear Raymond Nobu Chang: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and/or providing the requested information. If you do not believe a comment applies 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/or the information you provide in response to this letter, we may have additional comments. Amendment No. 1 to Registration Statement on Form S-1 Cover Page 1. We note your disclosure on the cover page that the selling stockholder may sell its shares to or through underwriters or dealers, directly to purchasers or through agents designated from time to time. Please confirm your understanding that the retention by a selling stockholder of an underwriter would constitute a material change to your plan of distribution requiring a post-effective amendment. Refer to your undertaking provided pursuant to Item 512(a)(1)(iii) of Regulation S-K. October 28, 2024 Page 2 Please contact Juan Grana at 202-551-6034 or Jane Park at 202-551-7439 with any other questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services cc: Robert A. Petitt, Esq.