April 9, 2019

Robert Plaschke
Chief Executive Officer
Sonim Technologies, Inc.
1875 South Grant Street
Suite 750
San Mateo, CA 94402

       Re: Sonim Technologies, Inc.
           Amendment No. 1 to
           Draft Registration Statement on Form S-1
           Submitted April 3, 2019
           CIK No. 0001178697

Dear Mr. Plaschke:

      We have reviewed your amended draft 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 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 comments apply 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 these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Amendment No. 1 to Draft Registration Statement on Form S-1

Risk Factors
Risks Related to this Offering and Our Common Stock
Our amended and restated certificate of incorporation will designate the Court
of Chancery of the
State of Delaware as the sole..., page 35

1.     We note your response to comment 8 and your disclosure on page 103 that
your
       amended and restated certificate of incorporation will provide that the
federal district
       courts of the United States of America will be the exclusive forum for
resolving any
       complaint asserting a cause of action arising under the Securities Act.
Please bifurcate
 Robert Plaschke
Sonim Technologies, Inc.
April 9, 2019
Page 2
         your risk factor disclosure as to the two choice of forum provisions
and discuss the risks
         of each and questions of enforceability separately.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Years Ended December 31, 2017 and 2018, page 54

2.       Please disclose the extent to which your 129.8% revenue growth was
attributable to
         AT&T's FirstNet contract, which was referenced elsewhere in your
filing.
Liquidity and Capital Resources, page 55

3.       Considering that your borrowings per the Statement of Cash Flows as of
December 31,
         2018 are materially different than the period-end amounts recorded in
your Balance Sheet,
         please provide additional narrative regarding intra-period variations
in your borrowings to
         facilitate investor understanding of your liquidity position. Please
refer to Section II.A of
         the Commission Guidance on Presentation of Liquidity and Capital
Resources Disclosures
         in Management's Discussion and Analysis (September, 2010) at
         https://www.sec.gov/rules/interp/2010/33-9144fr.pdf.
Note 1 - The Company and its Significant Accounting Policies
Revenue Recognition , page F-9

4.       We note your response to comment 18 and your revised disclosures
throughout the filing.
         For design, certification and approval activities that do not involve
significant
         customization, please revise to clarify if these costs are
reimbursable and if you consider
         them to be pre-production expenses related to a long-term supply
agreement. Please
         separately address costs incurred before and after receipt of a
product award letter. Refer
         to ASC 340-10-25-1.
Note 4 - Borrowings, page F-22

5.     We note that some of your financial covenants were temporarily suspended
and/or
       changed during 2018. Please revise to clarify if you continue to have a
positive EBITDA
       covenant as of December 31, 2018 and beyond. If so, please disclose the
covenant
       requirements. If not, please revise to disclose that it has been
temporarily suspended,
FirstName LastNameRobertis not required. Please also disclose if you were in
compliance with
       waived or otherwise Plaschke
Comapany NameSonim Technologies, Inc. of December 31, 2018. Similarly revise
your MD&A
       all applicable financial covenants as
       liquidity disclosures beginning on page 55.
April 9, 2019 Page 2
FirstName LastName
 Robert Plaschke
FirstName LastNameRobert Plaschke
Sonim Technologies, Inc.
Comapany NameSonim Technologies, Inc.
April 9, 2019
Page 9,
April 3 2019 Page 3
FirstName LastName
        You may contact Kathryn Jacobson, Staff Accountant, at (202) 551-3365
or Lisa
Etheredge, Staff Accountant, at (202) 551-3424 if you have questions regarding
comments on
the financial statements and related matters. Please contact Joshua Shainess,
Attorney-Adviser,
at (202) 551-7951 or Celeste M. Murphy, Legal Branch Chief, at (202) 551-3257
with any other
questions.



                                                           Sincerely,

                                                           Division of
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