December 10, 2018

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

       Re: Pareteum Corporation
           Amendment No. 1 to Registration Statement on Form S-3
           Filed November 30, 2018
           File No. 333-227912

Dear Mr. Turner:

      We have reviewed your amended registration statement 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 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. Unless
we note
otherwise, our references to prior comments are to comments in our November 19,
2018 letter.

Form S-3/A filed November 30, 2018

General

1.     We note your response to prior comment 1. Please further explain whether
your pseudo-
       enterprise resource planning cloud currently allows for your customers
to deploy their
       own or existing blockchain functionality. Additionally, your response
states you "don't
       believe any services have been launched as of yet that will accept
crypto currency for
       payment." Please confirm whether any such services have been launched or
explain why
       you are unable to provide such a confirmation. Lastly, we note your
press release dated
       July 18, 2018 concerning your contract with a "mobile and cryptocurrency
enterprise."
       Specifically, explain whether this customer currently uses "[y]our
artificial Insights
       Engine, along with [y]our advanced, software based, computer API
applications, for
 Robert H. Turner
Pareteum Corporation
December 10, 2018
Page 2
      payment services that utilize blockchain, as well as digital payments and
settlements."
      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 other questions.



                                                           Sincerely,

FirstName LastNameRobert H. Turner                         Division of
Corporation Finance
                                                           Office of
Information Technologies
Comapany NamePareteum Corporation
                                                           and Services
December 10, 2018 Page 2
cc:       Darrin M. Ocasio, Esq.
FirstName LastName