September 11, 2024

Joseph Visconti
Chief Executive Officer
Twin Vee PowerCats, Co.
3101 S. U.S. Highway 1
Fort Pierce, FL 34982

       Re: Twin Vee PowerCats, Co.
           Registration Statement on Form S-4
           Filed August 27, 2024
           File No. 333-281788
Dear Joseph Visconti:

     We have conducted a limited review of your registration statement and have
the following
comment(s).

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe a comment applies to your facts
and circumstances
or do not believe an amendment is appropriate, please tell us why in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to this letter, we may have additional comments.

Registration Statement on Form S-4 filed August 27, 2024
General

1.     It does not appear that Twin Vee PowerCats Co satisfies the requirements
of General
       Instruction B.1.a of Form S-4 and General Instruction I.B.1 of Form S-3,
which would
       allow you to incorporate certain required information by reference.
Please advise us why
       Twin Vee PowerCats Co is eligible to incorporate by reference its
financial statements or
       revise your filing to include the financial statements.
2.     Please include the financial statements for Forza X1, Inc. We note it
does not appear the
       financial statements have been included. We also note it does not appear
that Forza XI,
       Inc. satisfies the requirements of General Instruction C.1.a of Form S-4
and General
       Instruction I.B.1 of Form S-3, which would allow you to incorporate
certain required
       information by reference.
 September 11, 2024
Page 2
Certain U.S. Federal Income Tax Consequences of the Merger, page 61

3.     We note your disclosure that the merger should constitute a
reorganization within the
       meaning of Section 368(a) of the Code. Please file a tax opinion as
Exhibit 8.1 that
       supports this statement. If counsel will be filing a short form opinion
as Exhibit 8.1,
       please ensure that the short-form opinion and the tax disclosure in the
prospectus both
       clearly state that the disclosure in the tax consequences section of the
prospectus is the
       opinion of the named counsel. Refer to Section III.B.2 of Staff Legal
Bulletin No. 19.

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Patrick Fullem at 202-551-8337 or Erin Purnell at
202-551-3454 with any
questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Manufacturing
cc:   Leslie Marlow, Esq.