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