Mail Stop 4628

                                                             May 29, 2019

Via E-Mail
Peter Hovenier
Chief Financial Officer
Boingo Wireless, Inc.
10960 Wilshire Blvd., 23rd Floor
Los Angeles, CA 90024

       Re:     Boingo Wireless, Inc.
               Form 10-K for the Fiscal Year Ended December 31, 2018
               Filed March 1, 2019
               File No. 1-35155

Dear Mr. Hovenier:

        We have limited our review of your filing to your contacts with
countries that have been
identified as state sponsors of terrorism, and we have the following comments.
Our review with
respect to this issue does not preclude further review by the Assistant
Director group with respect
to other issues. In our comments, we 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.

General

   1. In your letter to us dated January 6, 2017, you discussed contacts with
Syria and Sudan.
      We note also that your website lists a Wi-Fi hot spot location in North
Korea. Syria,
      Sudan and North Korea are designated by the State Department as state
sponsors of
      terrorism and are subject to U.S. economic sanctions and/or export
controls. Your Form
      10-K does not provide disclosure about those countries. Please describe
to us the nature
      and extent of any past, current, and anticipated contacts with North
Korea, and any such
      contacts with Syria and Sudan since the 2017 letter, including contacts
with those
      countries' governments, whether through subsidiaries, telecom operators,
affiliates, or
      other direct or indirect arrangements.
 Peter Hovenier
Boingo Wireless, Inc.
May 29, 2019
Page 2

      2. Please discuss the materiality of any contacts with Syria, Sudan and
North Korea, in
         quantitative terms and in terms of qualitative factors that a
reasonable investor would
         deem important in making an investment decision. Tell us the
approximate dollar
         amounts of any revenues, assets and liabilities associated with those
countries for the last
         three fiscal years and the subsequent interim period. Please address
the potential impact
         of the investor sentiment evidenced by divestment and similar
initiatives that have been
         directed toward companies that have operations associated with state
sponsors of
         terrorism.

        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
action by the staff.

        You may contact Jennifer Hardy, Special Counsel, at (202) 551-3767 or
me at (202) 551-
3470 if you have any questions about the comments or our review.

                                                               Sincerely,

                                                               /s/ Cecilia Blye

                                                               Cecilia Blye,
Chief
                                                               Office of Global
Security Risk

cc:      Larry Spirgel
         Assistant Director