22nd Century Group, Inc.
8560 Main Street, Suite 4

Williamsville, New York 14221



July 27, 2020




United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Erin Purnell


Re:22nd Century Group, Inc.

Registration Statement on Form S-3 (Registration No. 333-239981)


Ms. Purnell:


Pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned registrant, 22nd Century Group, Inc., hereby requests that the above-referenced Registration Statement be declared effective at 12:00 p.m., eastern time, on July 30, 2020, or as soon as practicable thereafter.


  Very truly yours,  
  22nd Century Group, Inc.  
  By:  /s/ James A. Mish  
    James A. Mish
Chief Executive Officer