United States securities and exchange commission logo November 21, 2022 Massimo Barone Chief Executive Officer SmartCard Marketing Systems Inc. 20C Trolley Square Wilmington, DE 19806 Re: SmartCard Marketing Systems Inc. Amendment No. 3 to Draft Registration Statement on Form S-1 Submitted November 16, 2022 CIK No. 0000900475 Dear Massimo Barone: We have reviewed your amended draft 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 providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. 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 the information you provide in response to this comment and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment No. 3 to Draft Registration Statement on Form S-1 Consolidated Financial Statements, page F-1 1. Please update your financial statements in accordance with Article 8.08 of Regulation S- X. Massimo Barone FirstName SmartCard LastNameMassimo Barone Marketing Systems Inc. Comapany 21, November NameSmartCard 2022 Marketing Systems Inc. November Page 2 21, 2022 Page 2 FirstName LastName You may contact Patrick Kuhn at 202-551-3308 or Joel Parker at 202-551-3651 if you have questions regarding comments on the financial statements and related matters. Please contact Nicholas Nalbantian at 202-551-7470 or Dietrich King at 202-551-8071with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Evan Costaldo, Esq.