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                           August 3, 2023

       Christen Romero
       General Counsel
       Xos, Inc.
       3550 Tyburn Street
       Los Angeles, CA 90065

                                                        Re: Xos, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed on July 27,
2023
                                                            File No. 333-273479

       Dear Christen Romero:

              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 Sarah
Sidwell at 202-551-4733 with any questions.




                           Sincerely,


                           Division of Corporation Finance

                           Office of Manufacturing
       cc:                                              Dave Peinsipp