Mail Stop 4628 June 21, 2019 Via E-Mail Peter Hovenier Chief Financial Officer Boingo Wireless, Inc. 10960 Wilshire Blvd., 23rd Floor Los Angeles, CA 90024 Re: Boingo Wireless, Inc. Form 10-K for the Fiscal Year Ended December 31, 2018 Filed March 1, 2019 File No. 1-35155 Dear Mr. Hovenier: We refer you to our comment letter dated May 29, 2019 regarding business contacts with Syria, Sudan and North Korea. We have completed our review of this subject matter. 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. Sincerely, /s/ Cecilia Blye Cecilia Blye, Chief Office of Global Security Risk cc: Larry Spirgel Assistant Director