May 30, 2019 Michael Recca Chief Financial Officer Air Industries Group 1460 Fifth Avenue Bay Shore, New York 11706 Re: Air Industries Group Form 10-K/A for the Fiscal Year Ended December 31, 2018 Filed April 8, 2019 File No. 001-35927 Dear Mr. Recca: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K/A for the fiscal year ended December 31, 2018 Note 1: Formation and Basis of Presentation Going Concern, page F-7 1. Based on your disclosure here, it is not clear whether management's evaluation of substantial doubt regarding the company's ability to continue as a going concern determined that there was or was not substantial doubt. In addition, if substantial doubt existed, it is not clear whether it was alleviated because management's plans were probable of being effectively implemented and were probable of mitigating the conditions or events that raised the substantial doubt. Please revise your disclosure here and in future periodic reports - to the extent that conditions or events, considered in the aggregate, raise substantial doubt - to disclose management's evaluation and conclusions as required by ASC 205-40-50-12 or 13-14, as applicable. Michael Recca Air Industries Group May 30, 2019 Page 2 Note 3: Summary of Significant Accounting Policies, page F-10 2. We note that as of December 31, 2018 the company changed its policy to account for engineering costs. Please file a letter from your independent accountant concurring with your conclusion as to the new method's preferability in accordance with Item 601 of Regulation S-K. 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. You may contact Theresa Brillant at 202-551-3307 or Lyn Shenk at 202-551-3380 if you have questions regarding comments on the financial statements and related matters. FirstName LastNameMichael Recca Sincerely, Comapany NameAir Industries Group Division of Corporation Finance May 30, 2019 Page 2 Office of Transportation and Leisure FirstName LastName