March 30, 2020

Apostolos Zervos
Chief Executive Officer
Akazoo S.A.
One Heddon Street
W1B 4BD, London, UK

       Re: Akazoo S.A.
           Registration Statement on Form F-3
           Filed March 25, 2020
           File No. 333-237385

Dear Mr. Zervos:

       This is to advise you that we have not reviewed and will not review your
registration
statement.

       Please refer to Rule 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 Jeff Kauten, Attorney-Advisor, at (202) 551-3447, or in
his absence, Jan
Woo, Legal Branch Chief, at (202) 551-3453, with any questions. If you require
further
assistance, please contact Larry Spirgel, Office Chief, at (202) 551-3815.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Technology
cc:    Mark L. Hanson