November 19, 2018

Robert H. Turner
Executive Chairman
Pareteum Corporation
1185 Avenue of the Americas, 37th Floor
New York, NY 10036

       Re: Pareteum Corporation
           Registration Statement on Form S-3
           Filed October 19, 2018
           File No. 333-227912

Dear Mr. Turner:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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.

Form S-3 filed October 19, 2018

General

1.     You disclose here that your "blockchain-enabler platform is focused on
delivering
       enabling technology to all of [your] customers and partners" and that
the platform will
       "change how [your] customers leverage blockchain technology, and will
include support
       for smart-contracts and cryptocurrencies." Please revise to describe how
your blockchain-
       enabler platform will include support for smart-contracts and
cryptocurrencies and address
       the current stage of development of your blockchain-enabler platform,
including whether
       you are currently offering this platform to your customers and whether
you are generating
       any revenue from it. Also, address whether your blockchain-enabler
platform is or will be
       dependent on another blockchain and, if so, the risks and challenges
related to such
       reliance. Lastly, ensure that you discuss any related business risks and
challenges,
 Robert H. Turner
FirstNameCorporation
Pareteum LastNameRobert H. Turner
Comapany 19, 2018
November NamePareteum Corporation
November 19, 2018 Page 2
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FirstName LastName
         including any known trends or uncertainties that are reasonably
expected to have a
         material impact on your results of operations or financial condition.
2.       Page 10 of your blockchain-enabler platform whitepaper dated January
31, 2018 suggests
         that your blockchain-enabler platform will allow your customers to
deploy a
         cryptocurrency payment gateway and deploy their own or existing
digital tokens. We also
         note the statement on page 11 of the whitepaper that you are
"investigating a mining
         solution for customers who wish to make use of the TEAX token
blockchain." Please tell
         us whether your business entails, or will entail, the creation,
issuance or use of digital
         assets and, if so, how these digital assets will be used.
Additionally, clarify whether your
         business entails, or will entail, solutions that provide transaction
verification services (e.g.,
         mining or forging services) to your customers.
3.       Your blockchain-enabler platform whitepaper discusses your
relationship with AirFox, a
         cryptocurrency provider. Please describe any agreements you have with
AirFox and tell
         us what services AirFox provides to the company.
Incorporation of Documents by Reference, page 29

4.       Please specifically incorporate by reference each report filed
pursuant to Section 13(a) or
         15(d) of the Exchange Act since December 31, 2017, including each
quarterly report on
         Form 10-Q and each current report on Form 8-K that was filed after
December 31, 2017.
Selling Stockholders, page SS-5

5.       You disclose here that certain of the resale shares relate to shares
of common stock that
         are issuable to certain of the selling stockholders upon the exercise
of warrants.
         However, it is unclear how the selling stockholders acquired these
warrants. Please revise
         to describe the transactions in which each selling stockholder
acquired the warrants and
         ensure you revise footnote 7 to the fee table to define "the
Offering." Additionally, please
         file or incorporate by reference any agreements related to the selling
stockholders'
         purchase of the warrants.
6.       Please ensure that you disclose the nature of any position, office or
other material
         relationship which any selling stockholder has had with you within the
past three years.
Exhibits

7.       You disclose that you are registering debt securities and note that
"an indenture has been
         filed as an exhibit to the registration statement." As we were unable
to locate the
         indenture exhibit, please file a form of indenture as an exhibit with
your next amendment.
         For further guidance, consider Interpretations 201.02 and 201.04 of
our Trust Indenture
         Act of 1939 Compliance and Disclosure Interpretations.

       We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
 Robert H. Turner
Pareteum Corporation
November 19, 2018
Page 3

action by the staff.

        Refer to Rule 461 regarding requests for acceleration. Please allow
adequate time for us
to review any amendment prior to the requested effective date of the
registration statement.

      Please contact Mitchell Austin, Staff Attorney, at (202) 551-3574 or, in
his absence, Jan
Woo, Legal Branch Chief, at (202) 551-3453 with any questions.



                                                            Sincerely,

FirstName LastNameRobert H. Turner                          Division of
Corporation Finance
                                                            Office of
Information Technologies
Comapany NamePareteum Corporation
                                                            and Services
November 19, 2018 Page 3
cc:       Darrin M. Ocasio, Esq.
FirstName LastName