November 27, 2019 Stephen Cotton Chief Executive Officer Aqua Metals, Inc. 2500 Peru Drive McCarran, Nevada 89437 Re: Aqua Metals, Inc. Registration Statement on Form S-3 Filed November 22, 2019 File No. 333-235238 Dear Mr. 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 Thomas Jones at 202-551-3602 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Daniel K. Donahue