United States securities and exchange commission logo





                          September 29, 2021

       Kevin Sherlock
       General Counsel
       COMSovereign Holding Corp.
       5000 Quorum Drive, Suite 400
       Dallas, TX 75254

                                                        Re: COMSovereign
Holding Corp.
                                                            Registration
Statement on Form S-3
                                                            Filed September 27,
2021
                                                            File No. 333-259819

       Dear Mr. Sherlock:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

                                                        Please contact Gregory
Herbers at 202-551-8028 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Manufacturing
       cc:                                              Eric Hellige