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                             August 13, 2021

       Kevin Brian Cox
       Chief Executive Officer
       SurgePays, Inc.
       3124 Brother Boulevard, Suite 104
       Bartlett, TN 38133

                                                        Re: SurgePays, Inc.
                                                            Amendment No. 3 to
Registration Statement on Form S-1
                                                            Filed August 2,
2021
                                                            File No. 333-233726

       Dear Mr. Cox:

              We have reviewed your amended registration 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 registration
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 registration statement and
the information you
       provide in response to this comment, we may have additional comments.
Unless we note
       otherwise, any reference to prior comments are to comments in our July
21, 2021 letter.

       Amendment No. 3 to Registration Statement on Form S-1 filed August 2,
2021

       Financial Statements
       Consolidated Statements of Operations, page F-3

   1.                                                   We note your response
to comment 5. SAB Topic 11:B states, in part: "depreciation,
                                                        depletion and
amortization should not be positioned in the income statement in a manner
                                                        which results in
reporting a figure for income before depreciation." Therefore, if you
                                                        present a subtotal
income measure, such as gross profit, it should not exclude depreciation
                                                        and amortization since
such exclusion would result in the presentation of a "figure for
                                                        income before
depreciation." Accordingly, you can revise either by not presenting a gross
                                                        margin subtotal on the
face of the income statement or by disclosing that you allocate
                                                        depreciation and
amortization to cost of revenues, along with the amount allocated,
 Kevin Brian Cox
SurgePays, Inc.
August 13, 2021
Page 2
      and the types of costs and expenses classified as cost of revenues.
        You may contact Joseph Cascarano at (202) 551-3376 or Robert Littlepage
at (202) 551-
3361 if you have questions regarding comments on the financial statements and
related
matters. Please contact Cara Wirth at (202) 551-7127 or Mara Ransom at (202)
551-3264 with
any other questions.



                                                            Sincerely,
FirstName LastNameKevin Brian Cox
                                                            Division of
Corporation Finance
Comapany NameSurgePays, Inc.
                                                            Office of Trade &
Services
August 13, 2021 Page 2
cc:       Steven Lipstein
FirstName LastName