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                              August 15, 2022

       James A. McCarthy
       Chief Financial Officer
       Wilhelmina International, Inc.
       5420 Lyndon B Johnson Freeway, Box #25
       Dallas, Texas 75240

                                                        Re: Wilhelmina
International, Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2021
                                                            Response dated July
14, 2022
                                                            File No. 001-36589

       Dear Mr. McCarthy:

              We have reviewed your July 14, 2022 response to our comment
letter 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 these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

               After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       June 6, 2022 letter.

       Form 10-K for Fiscal Year Ended December 31, 2021

       Note 2. Summary of Significant Accounting Policies
       Revenue Recognition, page F-8

   1.                                                   We note your response
to comment 1. Please tell us which parties in your direct bookings
                                                        are your customer(s)
under ASC 606 and how you arrived at your conclusion, including
                                                        your contemplation of
sources of consideration and services provided in exchange for the
                                                        consideration received.
   2.                                                   For your direct
bookings, please tell us what your performance obligations are and how
                                                        you identified those
performance obligations under ASC 606.
   3.                                                   In your response to
comment 1, you state that you consider various indicators including
                                                        discretion in talent
selection in your assessment of whether you are acting as a principal or
 James A. McCarthy
Wilhelmina International, Inc.
August 15, 2022
Page 2
         an agent. Please explain to us in further detail what you mean by
discretion in talent
         selection.
4.       Please provide us with copies of standard talent and client
agreements. To the extent
         contracts vary materially between different categories of customers,
please separately
         provide copies of those contracts.
       You may contact Stephen Kim at 202-551-3291 or Lyn Shenk at 202-551-3380
if you
have questions.



FirstName LastNameJames A. McCarthy                            Sincerely,
Comapany NameWilhelmina International, Inc.
                                                               Division of
Corporation Finance
August 15, 2022 Page 2                                         Office of Trade
& Services
FirstName LastName