May 28, 2019

Alberto Menache
Chief Executive Officer
Linx S.A.
Avenida Doutora Ruth Cardoso, 7,221
S o Paulo -- SP, 05425-902, Brazil

       Re: Linx S.A.
           Amendment No. 1 to Draft Registration Statement on Form F-1
           Submitted on May 10, 2019
           CIK No. 0001770883

Dear Mr. Menache:

      We have reviewed your amended draft registration statement 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 this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
March 29, 2019 letter.

Amendment No. 1 to Draft Registration Statement submitted May 10, 2019

Cover Page

1.     Your response to prior comment 1 and your revised disclosure indicates
that the price per
       common share and the price per ADS will be determined based on the book
building
       process and the closing price of the company's common shares on the B3
on the pricing
       date of the global offering. Please clarify that you will provide a
price range for the
       ADSs. Alternatively, please tell us why you do not believe this
information is material.
 Alberto Menache
FirstName LastNameAlberto Menache
Linx S.A.
Comapany NameLinx S.A.
May 28, 2019
May 28, 2019 Page 2
Page 2
FirstName LastName
Mangement's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 75

2.       We note your response to prior comment 6. Please revise to disclose
whether there are
         other material sources that contributed to the increase in your
subscription revenues
         during the year ended December 31, 2018. In this respect, you only
appear to provide
         qualitative and quantitative disclosures for approximately 64% of the
increase in your
         subscription revenues during the year ended December 31, 2018. In
addition, revise to
         explain whether there are any offsets to the material factors
identified for the increase in
         your subscription revenues during the year ended December 31, 2017. In
this respect,
         your disclosures indicate that your subscription revenues increased by
R$80.6 million
         during the year ended December 31, 2017 mainly from an increase of
R$75.8 million
         attributable to your ongoing cross-selling efforts to expand
additional products to existing
         customers and R$28.4 million attributable to the impact of
acquisitions.
3.       Your response to prior comment 7 indicates that you deleted the
reference to the change in
         net operating revenue attributable to changes in the number of your
customers during the
         relevant period since your accounting records cannot quantify the
increase or decrease in
         net operating revenue attributable to a specific change in the number
of customers. Please
         revise to disclose the number of customers for each period presented.
This appears to be
         important information necessary to understanding your business and
operating results.
Description of Capital Stock
Arbitration, page 162

4.       You state that your company and shareholders, among others are
required to resolve
         disputes through arbitration proceedings before the Chamber of Market
Arbitration.
         Please revise your disclosure to provide a description of the
arbitration provision and any
         effects on the rights of ADS holders to pursue claims under United
States federal
         securities laws.
Consolidated Financial Statements
3.13 Revenue from contracts with clients, page F-75

5.       Your revised disclosures in response to prior comment 17 indicate that
consulting services
         (implementation, installation, customization and training services)
are recognized as
         rendered and billed on a per-hour basis. Please further clarify the
nature of your
         implementation, installation and customization services. Explain in
detail how you
         determined that the consulting services are a separate stand-alone
performance obligation.
         Describe the significant judgments you made in determining that the
consulting services
         are a separate stand-alone performance obligation.

       You may contact Morgan Youngwood, Staff Accountant, at 202-551-3479 or
Stephen
Krikorian, Accounting Branch Chief, at 202-551-3488 if you have questions
regarding
 Alberto Menache
Linx S.A.
May 28, 2019
Page 3

comments on the financial statements and related matters. Please contact Folake
Ayoola, Special
Counsel, at 202-551-3673, or Barbara Jacobs, Assistant Director, at
202-551-3735 with any other
questions.



                                                          Sincerely,

FirstName LastNameAlberto Menache                         Division of
Corporation Finance
                                                          Office of Information
Technologies
Comapany NameLinx S.A.
                                                          and Services
May 28, 2019 Page 3
cc:       John Guzman
FirstName LastName