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                            October 5, 2020

       Daniel Hodges
       Chief Executive Officer
       ComSovereign Holding Corp.
       5000 Quorum Drive, STE 400
       Dallas, TX 75254

                                                        Re: ComSovereign
Holding Corp.
                                                            Amendment No. 1 to
                                                            Registration
Statement on Form S-1
                                                            Filed September 28,
2020
                                                            File No. 333-248490

       Dear Mr. Hodges:

             We have reviewed your amended 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 amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
September 8, 2020 letter.

       Amendment No. 1 to Registration Statement on Form S-1

       Selected Financial Information, page 6

   1.                                                   We note your revisions
made in response to our prior comment 2. Please consider moving
                                                        the historical line
item of weighted average shares outstanding to place directly beneath
                                                        the basic and diluted
loss per share historical line item. In addition, for the second pro
                                                        forma basic and diluted
loss per share line item and its related footnote (4), please
                                                        consider revising the
title to be supplemental pro forma basic and diluted loss per share.
                                                        Further, for both the
pro forma and newly revised named supplemental pro forma basic
                                                        and diluted loss per
share line items, please provide their separate pro forma weighted
                                                        average shares
outstanding.
 Daniel Hodges
ComSovereign Holding Corp.
October 5, 2020
Page 2
Exhibits

2.    We note your listing of Exhibits at page II-10 discloses that the Exhibit
23.1 consent of
      Haskell & White is filed herewith. However, we are unable to locate the
filing of this
      exhibit. In the next amendment, please include an updated accountants'
consent from your
      independent auditors.

        You may contact Beverly Singleton at 202-551-3328 or Melissa Raminpour
at 202-551-
3379 if you have questions regarding comments on the financial statements and
related
matters. Please contact Erin Purnell at 202-551-3454 or Geoffrey Kruczek at
202-551-3641 with
any other questions.



                                                          Sincerely,
FirstName LastNameDaniel Hodges
                                                          Division of
Corporation Finance
Comapany NameComSovereign Holding Corp.
                                                          Office of
Manufacturing
October 5, 2020 Page 2
cc:       Eric M. Hellige
FirstName LastName