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                            March 17, 2021

       Robert A. Rositano, Jr.
       Chief Executive Officer
       Friendable, Inc.
       1821 S. Bascom Ave., Suite 353
       Campbell, CA 95008

                                                        Re: Friendable, Inc.
                                                            Amendment No. 1 to
                                                            Offering Statement
on Form 1-A
                                                            Filed March 5, 2021
                                                            File No. 024-11427

       Dear Mr. Rositano:

              We have reviewed your amended offering statement and have the
following
       comment. In our comment, we may ask you to provide us with information
so we may better
       understand your disclosure.

              Please respond to this letter by amending your offering statement
and providing the
       requested information. If you do not believe our 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 offering statement and the
information you
       provide in response to this comment, we may have additional comments.
Unless we note
       otherwise, our reference to a prior comment is to a comment in our
February 23, 2021 letter.

       Amendment No. 1 to Offering Statement on Form 1-A

       Risk Factors, page 11

   1.                                                   We note your response
to prior comment 1 and we reissue it in part. Please include risk
                                                        factor disclosure to
describe the risks associated with your revenues being materially
                                                        dependent on a single
source of revenue.
 Robert A. Rositano, Jr.
Friendable, Inc.
March 17, 2021
Page 2

       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
comments on the financial statements and related matters. Please contact
Michael C.
Foland, Attorney-Advisor at (202) 551-6711 or Jan Woo, Legal Branch Chief, at
(202) 551-
3453 with any other questions.



                                                       Sincerely,
FirstName LastNameRobert A. Rositano, Jr.
                                                       Division of Corporation
Finance
Comapany NameFriendable, Inc.
                                                       Office of Technology
March 17, 2021 Page 2
cc:       Jonathan D. Leinwand
FirstName LastName